Baird v. PulteGroup CA4/1

CourtCalifornia Court of Appeal
DecidedJune 2, 2026
DocketD085988
StatusUnpublished

This text of Baird v. PulteGroup CA4/1 (Baird v. PulteGroup CA4/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baird v. PulteGroup CA4/1, (Cal. Ct. App. 2026).

Opinion

Filed 6/2/26 Baird v. PulteGroup CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

MARK A. BAIRD et al., D085988

Plaintiffs and Appellants,

v. (Super. Ct. No. CVPS2201015)

PULTEGROUP, INC. et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Riverside County, Manuel Bustamante, Jr., Judge. Affirmed in part, reversed in part, and remanded with directions. Gelb Law, Yisrael Gelb; The Wright Law Firm and Jamie Wright, for Plaintiffs and Appellants. Morgan, Lewis & Bockius, Beth S. Joseph, Joseph D. Magrisso, Stephanie Schuster, Regina Agopian and Jason Mills, for Defendants and Respondents. Mark and Bradley Baird are a married couple who sought to buy a home from defendant Pulte Home Company, LLC. Mark is a veteran, and the couple intended to use a United States Department of Veterans Affairs (VA)-backed home loan (a VA loan) to finance the purchase. The Bairds applied for a VA loan from defendant Pulte Mortgage LLC, but were denied on the ground that they did not have sufficient monthly income. Pulte Home had a policy of limiting customization options for VA-loan purchasers to 10 percent of the base purchase price, ostensibly because VA appraisers were conservative in their appraisals and VA borrowers would too often cancel after the customizations were complete based on a low appraisal. This policy was communicated to the Bairds by their principal sales contact, defendant Brett Picano. The sales process did not proceed smoothly, and at one point Picano purported to “void the purchase agreement paperwork” after a dispute with the Bairds about the terms of the agreement. The Bairds claim Picano’s actions were retaliatory because they told Picano that Mark had filed a complaint with the Civil Rights Department (CRD) for anti- veteran discrimination. Picano and his supervisor were replaced by a different sales team, and the same or more generous terms were offered to the Bairds. Although the Bairds were ultimately preapproved for a VA loan from a second lender and signed a purchase agreement with Pulte Home, they withdrew from the contract a few days later, instead purchasing a home from a different company using a VA loan from a third lender. The Bairds sued Picano, Pulte Home Company, and Pulte Mortgage, as well as two affiliated entities, Del Webb Communities, Inc. and PulteGroup Inc., under the Fair Employment and Housing Act (FEHA), claiming

2 discrimination on the basis of veteran status. The Bairds argued Pulte Home’s 10 percent policy was discriminatory and that Pulte Mortgage had denied their mortgage application for discriminatory reasons. The superior court granted summary judgment in favor of all defendants. On appeal, the Bairds argue the Pulte Home policy constituted both unlawful disparate treatment and disparate impact. Because defendants did not seek summary adjudication of the Bairds’ disparate treatment theory separate from the disparate impact theory, and because their arguments do not negate the cause of action as a whole, Pulte Home is not entitled to summary judgment or adjudication of this claim. Because the claims are interrelated, we find Picano is not entitled to summary judgment or adjudication of the Bairds’ claim that he aided and abetted Pulte Home’s discrimination. As to the remaining defendants and claims, however, we find that summary judgment or summary adjudication was appropriate. The Bairds fail to make any arguments establishing that Del Webb or PulteGroup should be liable for the actions of any other defendant, thus forfeiting such arguments. Although the Bairds argue Pulte Mortgage discriminated against them by denying their loan application, we find Pulte Mortgage presented a legitimate, nondiscriminatory reason for denying the Bairds’ loan application, and the record does not raise a reasonable inference of discrimination. Thus, the trial court properly granted summary judgment to Del Webb, PulteGroup, and Pulte Mortgage. Finally, the Bairds seek to raise a new argument, claiming that Pulte Home and Picano retaliated against them for protected activity by temporarily voiding the sales contract. Because this argument was not

3 raised in the trial court, where the Bairds denied that their claim concerned the sales contract at all, we find it is not properly preserved for appeal. We affirm the judgment in favor of PulteGroup, Pulte Mortgage, and Del Webb, and reverse the judgment in favor of Pulte Home and Picano. We remand for further proceedings consistent with this opinion.

FACTUAL AND PROCEDURAL BACKGROUND

A. The Bairds’ Dealings with Pulte Home and Picano

Pulte Home owns a new housing development in Riverside County, called the Del Webb at Rancho Mirage. Buyers can select from several model home styles and then add optional upgrades to the basic model, such as higher-end cabinets, crown molding, or wood flooring. Pulte Home is an affiliate of Pulte Mortgage, which offers financing, although buyers are free to obtain financing through other companies. The Bairds sought to purchase a new Rancho Mirage home in 2021 using a VA loan. Though they are sold by private lenders like conventional mortgages, VA loans are guaranteed by the federal government and subject to certain terms. One benefit of using a VA loan is that an eligible buyer can borrow up to 100 percent of the loan’s value and thus does not need to make a down payment to purchase a home. But a home purchased with a VA loan must be appraised by a government-approved appraiser. According to the parties, these appraisers “have a reputation for being conservative in their property valuations.” After learning the Bairds intended to use a VA loan, the Pulte Home salesperson, Brett Picano, said that they “would not get one of the Rancho Mirage homes if Mark used a VA Loan … and started immediately trying to steer [the Bairds] to a conventional loan.” According to Picano, “with

4 conventional loans [the Bairds] would get all these upgrades,” but with a VA loan they “would be very limited with upgrades.” He showed the Bairds a folder comparing the upgrades available for buyers using conventional loans and the “significantly limited” upgrades available to purchasers using VA loans. Defendants dispute that Pulte Home has a policy of not allowing VA loan users to add certain upgrades, but claim it “permit[s]” salespeople “to counsel buyers intending to use a VA loan that upgrades of more than 10% of the home’s purchase price may result in a low appraisal that affects their ability to finance 100% of the purchase price.” As a Pulte Home employee explains, “when buyers add what an appraiser considers an excessive amount of optional upgrades and ‘over-improve[]’ the home, they can add tens of thousands of dollars to the total purchase price, while the appraiser may not value those options as adding the same amount to the home’s appraised value.” According to this employee, “[u]pgrades can pose a particular challenge for VA loan approvals where the buyer typically does not bring any down payment” and the appraisers are more conservative. This became a sticking point for the Bairds, as they wanted to add more than 10 percent of their base home value in upgrades and were given conflicting information about Pulte Home’s policy. Despite what he had said in their initial discussion, Picano told the Bairds their optional upgrades would not be capped at 10 percent, and they moved forward with a purchase agreement.

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Baird v. PulteGroup CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baird-v-pultegroup-ca41-calctapp-2026.