Black v. L.A. County Metropolitan Transp. Authority

CourtCalifornia Court of Appeal
DecidedDecember 2, 2025
DocketB339694
StatusPublished

This text of Black v. L.A. County Metropolitan Transp. Authority (Black v. L.A. County Metropolitan Transp. Authority) 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
Black v. L.A. County Metropolitan Transp. Authority, (Cal. Ct. App. 2025).

Opinion

Filed 12/2/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

ANDREW BLACK, B339694

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. 22STCV36213) v.

LOS ANGELES COUNTY METROPOLITAN TRANSPORTATION AUTHORITY et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Los Angeles County, Randolph M. Hammock, Judge. Affirmed in part and reversed in part. Law Offices of William B. Hanley and William B. Hanley for Plaintiff and Appellant. Peterson, Bradford, Burkwitz, Gregorio, Burkwitz, & Su and Avi Burkwitz for Defendants and Respondents. ____________________________

Plaintiff Andrew Black appeals from the judgment after the trial court sustained a demurrer in favor of defendants Los Angeles County Metropolitan Transportation Authority (MTA) and Public Transportation Services Corporation (PTSC). The trial court found plaintiff had failed to allege he had complied with the Government Claims Act (Gov. Code, § 810 et. seq.; GCA), which requires plaintiffs to provide written claims for damages to public entities before filing suit against those entities. On appeal, plaintiff does not challenge the judgment in favor of MTA. As to PTSC, plaintiff argues: 1) PTSC is not a public entity entitled to a prelitigation claim under the GCA; and 2) assuming PTSC is a public entity, plaintiff is excused from the GCA’s claims presentation requirement because PTSC did not register on the Registry of Public Agencies. We disagree with plaintiff that PTSC is not a public entity for purposes of the GCA’s claims presentation requirement. MTA created PTSC, a nonprofit public benefit corporation, to provide retirement benefits to workers who otherwise would be ineligible for those benefits if employed directly by MTA. PTSC thus manages and supplies the workers who carry out MTA’s mission, and its powers are limited to those MTA authorizes. Under applicable case law, the circumstances of PTSC’s creation and its relationship with MTA establish PTSC’s public entity status. We agree with plaintiff, however, that PTSC’s alleged failure to register on the Registry of Public Agencies would excuse plaintiff’s noncompliance with the GCA. Although defendants have provided evidence PTSC is on the registry maintained by the Secretary of State, they have yet to

2 demonstrate PTSC also has registered with the clerks of each county in which PTSC maintains an office, as is required by statute. Plaintiff therefore is entitled to amend his complaint to allege PTSC’s failure to register. Accordingly, we affirm the judgment in favor of MTA, and reverse the judgment in favor of PTSC.

BACKGROUND Plaintiff filed a complaint against defendants alleging wrongful termination in violation of public policy and violation of Labor Code section 970. After answering the complaint, defendants filed a motion for judgment on the pleadings asserting that plaintiff had failed to plead compliance with the claims presentation requirements of the GCA. Defendants argued that requirement applies because MTA is a “public entity created pursuant to the County Transportation Commissions Act,” and PTSC is both “a public corporation” and “a public agency.” Alternatively, defendants argued as public entities, they are immune from common law liability for wrongful termination in violation of public policy and also immune from causes of action for misrepresentation under Labor Code section 970. In his opposition, plaintiff conceded MTA is a public entity, but argued PTSC, as a nonprofit public benefit corporation, is distinct from a “public corporation” and therefore not protected by the GCA. The trial court granted the motion. The court agreed plaintiff had not pleaded facts addressing the claims presentation requirement, and indeed “apparently concede[d] he ha[d] not filed a claim” under the GCA. The court found plaintiff also had conceded MTA is a public entity. The court further found PTSC is a “local public entity under the [GCA]” as “either a ‘public

3 corporation’ or ‘public agency.’ ” The court granted plaintiff leave to amend. The court did not address defendants’ alternative arguments that as public entities, they are immune from plaintiff’s causes of action. Plaintiff then filed his first amended complaint (FAC). The FAC now asserted causes of action for wrongful termination and Labor Code violations against PTSC only, alleging PTSC is not a public entity and therefore the GCA is inapplicable to PTSC. The FAC also added a new cause of action for breach of contract against both defendants, with no allegations concerning the GCA. Defendants filed a demurrer, again arguing plaintiff had not pleaded compliance with the GCA, MTA is a governmental entity, and as both a public agency and a public corporation, PTSC is entitled to the protections of the GCA. Defendants reasserted their alternative argument that as public entities they are immune from plaintiff’s wrongful termination and Labor Code section 970 causes of action. Defendants also filed a motion to strike the new breach of contract cause of action, which defendants contended was not within the scope of the trial court’s order permitting amendment. Plaintiff opposed the demurrer, arguing as he had before that PTSC is not a public entity. He also argued, assuming arguendo PTSC were a public entity, he was nonetheless excused under Government Code section 946.4 from the claims presentation requirement because “[t]here is no evidence [o]f PTSC being listed on the Registry of Public Agencies” as required by Government Code section 53051. Plaintiff also opposed the motion to strike, arguing his amendments were within the scope of the trial court’s prior order.

4 In reply, defendants argued, inter alia, that plaintiff’s assertions concerning Government Code sections 946.4 and 53051 were procedurally improper for having been raised for the first time in opposition to the demurrer rather than in the FAC. Defendants further argued PTSC is an “organizational unit” of MTA, and “a subdivision need not comply with” the registration requirement of Government Code section 53051. The trial court sustained the demurrer without leave to amend. Citing its earlier ruling on the motion for judgment on the pleadings, the court again found “each Defendant is a public entity subject to the claim presentation requirements.” Quoting the MTA’s administrative code, the court found PTSC, “ ‘[w]hen serving as an organizational unit of the MTA, . . . is subject to all governmental privileges and immunities enjoyed by the MTA . . .’ [Citation.]” Accordingly, the court found, “Plaintiff has provided no authority requiring PTSC to register separately” under Government Code section 53051. Even if PTSC were required to register, “Plaintiff did not allege facts to support this contention in his FAC, and instead, only raised it for the first time in his opposition.” The court did not address defendants’ alternative argument regarding public entity immunity from wrongful termination and Labor Code section 970 causes of action. The court ruled the motion to strike was moot. The trial court entered judgment in favor of defendants. Plaintiff timely appealed. In responding to supplemental briefing we requested, defendants asked us to take judicial notice of a “Statement of Facts” for the “Roster of Public Agencies” submitted on behalf of PTSC to the Secretary of State on August 3, 2000, as well as a letter from the Secretary of State confirming filing of the

5 statement of facts as of August 7, 2000. We take judicial notice of these documents, noting plaintiff’s objection to the request.1 (Evid. Code, §§ 452, subd. (c), 459, subd. (a).)

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Black v. L.A. County Metropolitan Transp. Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/black-v-la-county-metropolitan-transp-authority-calctapp-2025.