Bartholomew v. Parking Concepts, Inc.

CourtCalifornia Court of Appeal
DecidedFebruary 5, 2026
DocketA171546
StatusPublished

This text of Bartholomew v. Parking Concepts, Inc. (Bartholomew v. Parking Concepts, Inc.) 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
Bartholomew v. Parking Concepts, Inc., (Cal. Ct. App. 2026).

Opinion

Filed 2/5/26 CERTIFIED FOR PARTIAL PUBLICATION *

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FIVE

BRENDAN P. BARTHOLOMEW, A171546 Plaintiff and Appellant, v. (San Francisco City & County Super. Ct. No. CGC-24-612624) PARKING CONCEPTS, INC., Defendant and Respondent.

Brendan P. Bartholomew (Plaintiff) sued Parking Concepts, Inc. (Parking Concepts), alleging that it automatically collected his license plate information when he parked his vehicle in its parking garage. Plaintiff claimed Parking Concepts violated a statutory scheme governing automated license plate recognition systems (Civ. Code, §§ 1798.90.5–1798.90.55 1; hereafter ALPR Law), by failing to implement and make publicly available a policy governing the collection and use of this data. 2

* Pursuant to California Rules of Court, rules 8.1105(b) and 8.1110, this

opinion is certified for publication with the exception of parts II and III. 1 All undesignated statutory references are to the Civil Code.

2 Plaintiff also alleged claims under the unfair competition law (Bus. &

Prof. Code, § 17200 et seq.; hereafter UCL), and the California Constitution’s right to privacy (Cal. Const., art. I, § 1), which we address in the unpublished portion of this opinion.

1 The trial court sustained Parking Concepts’ demurrer without leave to amend, in part on the ground that Plaintiff failed to allege harm within the meaning of the ALPR Law. We hold that the collection and use of license plate information, without implementing the statutorily required policy governing this collection and use, constitutes such harm. BACKGROUND Plaintiff parked his vehicle in a parking garage owned and/or operated by Parking Concepts (the Garage) “multiple times” in 2022 and 2023. 3 When Plaintiff and other customers arrived at the Garage, they “press[ed] a button on a kiosk” and took a printed “parking ticket.” The printed ticket displayed, among other information, the “license plate number” of the vehicle, along with the date and time of entry into the Garage. When leaving the Garage, customers paid at “a pay station” and then drove to the exit, where a kiosk was located in front of a barrier arm. A screen on the kiosk displayed the vehicle’s license plate number and “the barrier arm would automatically lift” to allow the vehicle to exit. Plaintiff sued on behalf of himself and others similarly situated, alleging claims for violations of the ALPR Law, the UCL, and the California Constitution’s right to privacy. The trial court sustained Parking Concepts’ demurrer without leave to amend and issued judgment for Parking Concepts. DISCUSSION “ ‘ “ ‘ “On appeal from a dismissal after an order sustaining a demurrer, we review the order de novo, exercising our independent judgment about

3 “ ‘ “ ‘ “ ‘We treat the demurrer as admitting all material facts properly

pleaded, but not contentions, deductions or conclusions of fact or law.’ ” ’ ” ’ ” (Vann v. City and County of San Francisco (2023) 97 Cal.App.5th 1013, 1019 (Vann).)

2 whether the complaint states a cause of action as a matter of law.” ’ ” ’ ” (Vann, supra, 97 Cal.App.5th at p. 1019.) “ ‘Although our review is de novo, it is plaintiffs’ burden to affirmatively demonstrate that the demurrer was erroneously sustained as a matter of law . . . .’ ” (Id. at p. 1020.) “[W]hen a complaint ‘is sustained without leave to amend, we decide whether there is a reasonable possibility that the defect can be cured by amendment: if it can be, the trial court has abused its discretion and we reverse; if not, there has been no abuse of discretion and we affirm.’ [Citation.] ‘ “[T]he burden is on the plaintiff to demonstrate that the trial court abused its discretion. [Citations.] Plaintiff must show in what manner he can amend his complaint and how that amendment will change the legal effect of his pleading.” ’ ” (Ibid.) I. ALPR Law A. Legal Background The ALPR Law, enacted in 2015, governs the operation and use of an “ ‘[a]utomated license plate recognition system’ or ‘ALPR system,’ ” which is defined as “a searchable computerized database resulting from the operation of one or more mobile or fixed cameras combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data.” (§ 1798.90.5, subd. (d); see Stats. 2015, ch. 532, § 3, eff. Jan. 1, 2016.) The “information or data collected through the use of an ALPR system” is called “ ‘ALPR information.’ ” (§ 1798.90.5, subd. (b).) The ALPR Law requires persons operating an ALPR system (with exceptions not relevant here) to “[m]aintain reasonable security procedures and practices . . . to protect ALPR information from unauthorized access, destruction, use, modification, or disclosure.” (§ 1798.90.51, subd. (a); see also § 1798.90.5, subd. (c).) Such persons are also required to implement “a

3 usage and privacy policy in order to ensure that the collection, use, maintenance, sharing, and dissemination of ALPR information is consistent with respect for individuals’ privacy and civil liberties.” (§ 1798.90.51, subd. (b)(1).) This policy must address various enumerated subjects, including “[t]he authorized purposes for using the ALPR system and collecting ALPR information”; “[a] description of how the ALPR system will be monitored to ensure the security of the information and compliance with applicable privacy laws”; “[t]he purposes of, process for, and restrictions on, the sale, sharing, or transfer of ALPR information to other persons”; and “[t]he length of time ALPR information will be retained.” (Id., subd. (b)(2).) The policy must be made “available to the public in writing, and, if the ALPR operator has an Internet Web site, the usage and privacy policy shall be posted conspicuously on that Internet Web site.” (Id., subd. (b)(1).) 4 In addition, “[i]f an ALPR operator accesses or provides access to ALPR information,” it shall “[m]aintain a record of that access,” including “[t]he username of the person who accesses the information, and, as applicable, the organization or entity with whom the person is affiliated,” and “[t]he purpose for accessing the information.” (§ 1798.90.52, subd. (a).) The ALPR operator must further “[r]equire that ALPR information only be used for the authorized purposes described in the usage and privacy policy required by subdivision (b) of Section 1798.90.51.” (Id., subd. (b).) B. Analysis Plaintiff alleges that Parking Concepts is an ALPR operator but has not implemented or made publicly available a usage and privacy policy as

4 Similar requirements are imposed on persons who access or use ALPR

systems. (§§ 1798.90.5, subd. (a), 1798.90.53.) Additional provisions governing public agencies are not applicable here. (§ 1798.90.55.)

4 required by the ALPR Law. 5 The trial court sustained Parking Concepts’ demurrer on the grounds that Plaintiff failed to allege Parking Concepts operated an ALPR system and failed to allege harm within the meaning of the ALPR Law. We agree with Plaintiff that the trial court erred. 1. ALPR System Parking Concepts demurred on the ground that Plaintiff failed to include sufficient facts alleging the operation of an ALPR system. “A complaint must contain ‘[a] statement of the facts constituting the cause of action, in ordinary and concise language.’ (Code Civ. Proc., § 425.10, subd. (a)(1).)” (Thomas v. Regents of University of California (2023) 97 Cal.App.5th 587, 610.) “ ‘[A] plaintiff is required only to set forth the essential facts with “ ‘ “ ‘particularity sufficient to acquaint a defendant with the nature, source and extent of [the plaintiff’s] cause of action.’ ” ’ ” ’ ” (Id. at p.

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