Bell v. Louie CA2/7

California Court of Appeal·Decided September 11, 2026·No. B343209·Unpublished

Opinion

Filed 9/11/26 Bell v. Louie CA2/7 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SEVEN

B343209

SANDRA BELL, (Los Angeles County

Plaintiff and Appellant, Super. Ct. No.

23STCV15396)

v.

NETANEL LOUIE et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Los Angeles County, Rupert A. Byrdsong, Judge. Reversed with directions.

Pease & Ijadi, Bryan W. Pease; Law Offices of G. David Tenenbaum and G. David Tenenbaum, for Plaintiff and Appellant.

First Liberty Institute, Stephanie N. Taub; Wilmer Cutler Pickering Hale and Dorr and Leah M. Fugere, for Defendants and Respondents.

Dechert, Jay Bhimani and Gary Dreyer for The Jewish Coalition for Religious Liberty as Amicus Curiae on behalf of Defendants and Respondents.

INTRODUCTION

Sandra Bell appeals from a judgment of dismissal after the trial court sustained a demurrer by Rabbi Netanel Louie and the Hebrew Discovery Center (HDC) to her second amended complaint without leave to amend. Bell sued Rabbi Louie and HDC for civil rights violations and several torts after Rabbi Louie allegedly destroyed Bell’s protest signs to prevent her from peacefully protesting Kapparot, an Orthodox Jewish atonement ritual that involves slaughtering a chicken. We conclude the trial court erred in sustaining the demurrer without leave to amend to Bell’s causes of action under the Bane Civil Rights Act, Civil Code section 52.1,1 and the Ralph Civil Rights Act, section 51.7. We also conclude that, while the trial court did not err in sustaining the demurrer to Bell’s cause of action for civil conspiracy, the court should have given Bell leave to amend to allege her conspiracy allegations in an appropriate cause of action. Therefore, we reverse.

1 Undesignated statutory references are to the Civil Code.

FACTUAL AND PROCEDURAL BACKGROUND

A. Bell Protests HDC’s Kapparot Ritual In October 2022, when Bell was 77 years old, she protested HDC’s Kapparot ritual on the sidewalk in front of HDC.2 Rabbi Louie runs HDC and organized the Kapparot ritual. Bell protested with signs that stated: “CHICKENS Cannot Atone for YOUR Sins—Primitive, Cruel Nonsense” and “bloody cruel senseless useless—ANIMAL SACRIFICE done here!”

Bell alleged that, when she put her signs down on a bush beside her, Rabbi Louie came outside, saw the signs, went behind Bell, and ripped up her signs, rendering them unusable. Bell alleged that, when Rabbi Louie destroyed her signs, he intended to intimidate and coerce her, interfere with her First Amendment

2 While Bell’s second amended complaint describes the practice as a “chicken killing ritual,” Kapparot is a Jewish ritual practiced by some orthodox communities in the days immediately preceding Yom Kippur. Adherents of Kapparot believe that it is “required by religious law and that it brings atonement and redemption. The ritual entails grasping a live chicken and swinging the bird three times overhead while saying a prayer that symbolically asks God to transfer the practitioners’ sins to the birds.” (Alliance to End Chickens as Kaporos v. New York City Police Dept. (N.Y. App. Div. 2017) 152 A.D.3d 113, 115; see United Poultry Concerns v. Chabad of Irvine (9th Cir. 2018) 743 Fed.Appx. 130, fn. 1 [“Kapparot is an atonement ritual that involves recitation of prayer and results in the Kosher killing of chickens.”].) When the prayer is complete, “the chicken is killed in accordance with the kosher dietary laws, by slitting the chicken’s throat. Its meat is . . . donated to the poor and others in the community.” (Alliance, at p. 115.)

right to protest, and destroy the medium on which Bell displayed her “message of compassion.”

Bell alleged Israel Shamoni (who is not a party to this appeal), an employee of HDC and Rabbi Louie, approached her, screamed at her, and spat saliva and mucus on her face and sweater. Bell alleged Shamoni worked with Rabbi Louie to “intimidate, threaten, ridicule, and interfere with [Bell] and other protesters’ . . . rights to peaceful[ly] protest.” Bell alleged Shamoni, rather than joining the other Kapparot participants, stood next to Rabbi Louie, “laughing at and mocking the protesters.”

Bell also alleged that Rabbi Louie employed and supervised Shamoni and was thus vicariously liable for Shamoni’s actions and that HDC was vicariously liable for Shamoni’s and Rabbi Louie’s actions because they were acting in the “course and scope of their employment when they engaged in these violent acts.” Bell also alleged Shamoni and Rabbi Louie acted in concert as “accomplices” to “disrupt and antagonize” Bell and other protesters.

B. Bell Files This Action, and the Trial Court Sustains a Demurrer by Rabbi Louie and HDC Without Leave To Amend

Bell sued Rabbi Louie, HDC, and Shamoni, alleging in her operative second amended complaint five causes of action: (1) violation of the Bane Act, (2) violation of the Ralph Act, (3) assault and battery, (4) abuse of an elder person in violation of Welfare & Institutions Code section 15610.63, and (5) civil conspiracy to commit a tort. Rabbi Louie and HDC demurred, arguing Bell did not state causes of action for violation of the

Bane Act, violation of the Ralph Act, assault and battery against HDC, or conspiracy against Rabbi Louie. They also argued Bell could not attribute Shamoni’s conduct to Rabbi Louie or HDC under a vicarious liability or accomplice theory.3 The trial court sustained the demurrer to the second amended complaint without leave to amend, and Bell timely appealed from the ensuing judgment. Bell challenges the court’s order sustaining the demurrer to her causes of action for violation of the Bane Act, violation of the Ralph Act, and conspiracy. She does not challenge the trial court’s order sustaining the demurrer to her causes of action for assault and battery and for elder abuse.

DISCUSSION

A. Applicable Law and Standard of Review “‘We independently review the ruling on a demurrer and determine de novo whether the pleading alleges facts sufficient to state a cause of action.’” (Association for Los Angeles Deputy Sheriffs v. County of Los Angeles (2023) 94 Cal.App.5th 764, 776; see Allied Anesthesia Medical Group, Inc. v. Inland Empire Health Plan (2022) 80 Cal.App.5th 794, 801-802.) “On appeal, ‘[w]hen a demurrer [has been] sustained, we determine whether the complaint states facts sufficient to constitute a cause of action. [Citation.] And when it is sustained without leave to

3 Rabbi Louie and HDC apparently also filed a motion to strike, but the record on appeal does not include that motion. The trial court took a motion to strike off calendar, and the court’s order does not indicate what allegations Rabbi Louie and HDC moved to strike.

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.’ [Citations.] We follow the well-settled rule that ‘[w]hen reviewing a judgment dismissing a complaint after the granting of a demurrer without leave to amend, courts must assume the truth of the complaint’s properly pleaded or implied factual allegations.’ [Citation.] On the other hand, the reviewing court ‘does not . . . assume the truth of contentions, deductions or conclusions of law.’” (Loeffler v. Target Corp. (2014) 58 Cal.4th 1081, 1100; see Schifando v. City of Los Angeles (2003) 31 Cal.4th 1074, 1081; City of Norwalk v. City of Cerritos (2024) 99 Cal.App.5th 977, 985.)

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