Judge: William A. Crowfoot, Case: 23AHCV02782, Date: 2024-04-11 Tentative Ruling
Case Number: 23AHCV02782 Hearing Date: April 11, 2024 Dept: 3
SUPERIOR COURT OF THE STATE OF
CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - NORTHEAST
DISTRICT
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Plaintiff(s), vs. Defendant(s). |
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[TENTATIVE]
ORDER RE: Dept.
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a.m. |
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I.
INTRODUCTION
On November 30, 2023, plaintiffs Arthur
Carlisle and Harriet Carlisle (collectively, “the Carlisles”) filed this
unlawful detainer action against defendants David Ventimiglia and Anita
Ventimiglia (collectively, “the Ventimiglias”) relating to the property located
at 2320 South Garfield Avenue in Monterey Park, California (the “Property”).
On December 8, 2023, the Ventimiglias
filed this demurrer on the grounds that there is another action pending between
the same parties regarding the rights to the Property, captioned Anita Ruby
Ventimiglia, et al. v. Arthur Carlisle, et al., Case No. 23AHCV02147 (the “Ventimiglia
Action”), pending in Department X of the Alhambra Courthouse.
II.
LEGAL
STANDARD
Code of Civil Procedure section
430.10(c) provides that a party against whom a complaint is filed may object by
demurrer to the pleading on the ground that “[t]here is another action pending
between the same parties on the same cause of action.” This plea in abatement
may be made by demurrer or answer when there is another action pending between
the same parties on the same cause of action. (Plant Insulation Co. v.
Fibreboard Corp. (1990) 224 Cal.App.3d 781, 789.) The later-filed suit is
“abated” (stayed) pending resolution of the earlier action which, if concluded
on the merits will be res judicata; if not, the later action can proceed. (Id.
at 788-89.) The court can take judicial
notice of the court files in determining the basis for this ground. (See
Bistawros v. Greenberg (1987) 189 Cal.App.3d 189, 191-192.)
III.
REQUEST
FOR JUDICIAL NOTICE
The Court takes judicial notice of the
complaint filed in the Ventimiglia Action.
IV.
DISCUSSION
First, the Ventimiglias argue that the
Carlisles lack standing to sue because they are not landlords and there is no
landlord-tenant relationship between the parties. Instead, the Ventimiglias
claim, the Carlisles are sellers with a sellers’ carry-back loan and the
Ventimiglias are buyers. This assertion is contradicted by the rental agreement
attached to the complaint which begins, “We [sic] Anita and David Ventimiglia,
agree to rent to own the property at 2320 South Garfield Avenue, Monterey Park,
California, 91754.”
Second, the Ventimiglias argue that
this unlawful detainer action should not proceed because of their earlier-filed
complaint, which asserts ten causes of action surrounding the Subject Property
including breach of purchase agreement, breach of express oral trust,
promissory estoppel, quiet title, promissory fraud, equitable estoppel, quantum
meruit, declaratory relief, negligence, and preliminary and permanent
injunction. “In order to sustain the plea of another action pending it is
essential that it shall appear: (1) That both suits are predicated upon the
same cause of action; (2) that both suits are pending in the same jurisdiction;
and (3) that both suits are contested by the same parties. [Citation.] . . .
The only relief to which a litigant is entitled upon the plea, whether by
demurrer or answer, is that the second action abate.” (Colvig v. RKO
General, Inc. (1965) 232 Cal.App.2d 56, 70-71.) It is a “universal rule
that a plea in abatement may be maintained only where the claim sued upon the
second action is such that a final judgment in the first one could be pleaded
in bar as a former adjudication. (Lord
v. Garland (1946) 27 Cal.2d 840, 848.)
The instant action is an unlawful
detainer and involves questions of possession, whereas the Ventimiglia Action
is not an unlawful detainer and involves questions of title. Therefore, both
suits are not predicated on the same cause of action and in fact, are
inherently based on separate causes of action because questions of title cannot
be litigated in unlawful detainer, which is a summary proceeding. (Evans v.
Superior Court (1977) 67 Cal.App.3d 162, 171 [unlawful detainer action is
not “a bar to the simultaneous maintenance of quiet title actions”].)
V.
CONCLUSION
In light of the foregoing, the demurrer
is OVERRULED.
Dated
this
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William A.
Crowfoot Judge of the Superior Court |
Parties who intend to submit on this
tentative must send an email to the Court at ALHDEPT3@lacourt.org indicating
intention to submit on the tentative as directed by the instructions provided
on the court website at www.lacourt.org. Please be advised that if you submit
on the tentative and elect not to appear at the hearing, the opposing party may
nevertheless appear at the hearing and argue the matter. Unless you receive a
submission from all other parties in the matter, you should assume that others
might appear at the hearing to argue. If the Court does not receive emails from
the parties indicating submission on this tentative ruling and there are no
appearances at the hearing, the Court may, at its discretion, adopt the
tentative as the final order or place the motion off calendar.