He v. University of San Diego CA4/1

CourtCalifornia Court of Appeal
DecidedDecember 24, 2025
DocketD083219
StatusUnpublished

This text of He v. University of San Diego CA4/1 (He v. University of San Diego 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
He v. University of San Diego CA4/1, (Cal. Ct. App. 2025).

Opinion

Filed 12/24/25 He v. University of San Diego 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NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

GILLIAN JINGRAN HE, D083219

Plaintiff and Appellant,

v. (Super. Ct. No. 37-2021-00025073-CU-BC-CTL) UNIVERSITY OF SAN DIEGO et al.,

Defendants and Respondents.

APPEAL from a judgment and order of the Superior Court of San Diego County, Eddie C. Sturgeon, Judge. Affirmed. Gillian Jingran He, in pro. per., for Plaintiff and Appellant. Quarles & Brady, Michael C. Sullivan, Joanne Alnajjar Buser, and Kelly E. Kagan, for Defendants and Respondents. Gillian Jingran He was academically disqualified from the University of San Diego School of Law at the end of her first year. She filed suit as a self-represented litigant, alleging that the school did not accommodate her medical conditions before disenrolling her. The merits of her claims were not tested, however, because her case was dismissed as a sanction for willfully violating three discovery orders and for her conduct while taking depositions of witnesses for the law school. The court also denied as untimely a motion to set aside the resulting judgment. Plaintiff appeals the judgment of dismissal and the denial of her postjudgment set-aside motion. She attacks the findings of misconduct underlying the imposition of terminating sanctions or, alternatively, claims the order imposing this sanction was invalid because the court failed to (1) give notice that her deposition conduct would factor into its choice of sanction and (2) consider a less severe remedy than dismissal. She also contends her motion to set aside the judgment was timely filed and thus should have been evaluated on its substance. We confirm that plaintiff committed sanctionable discovery misconduct. And while it is almost always preferable to seek a plaintiff’s compliance by first imposing an intermediate sanction short of dismissal, on the particular circumstances of this case we cannot say the trial court abused its discretion in dismissing the lawsuit and denying the set-aside motion after concluding that any lesser sanction would have been ineffective. Accordingly, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Plaintiff enrolled at the University of San Diego School of Law (USD) in August 2019. She was academically disqualified at the end of her first year for maintaining a deficient grade point average. In 2021, representing

2 herself, plaintiff sued the university, its president, and the then-vice dean of the law school (collectively, USD or defendants), alleging several claims grounded in the theory that the school failed to accommodate her medical conditions before disenrolling her. In a May 24, 2023 written order (sanctions order), the court found that plaintiff violated its prior discovery orders compelling (1) her deposition by November 15, 2022 (first deposition order); (2) her deposition on January 20, 2023 (second deposition order); and (3) supplementation of her responses to USD’s demands for the production of documents (document demands) by February 18, 2023 (documents order). The court also found that plaintiff misused the discovery process during her depositions of three USD witnesses. At the same time as it imposed the terminating sanction, the court assessed monetary sanctions on plaintiff, something it had not done previously in the case. Based on the sanctions order, a judgment of dismissal was entered in July 2023. The court subsequently deemed as untimely plaintiff’s motion to set aside the judgment under the discretionary provision of Code of Civil

Procedure section 473, subdivision (b).1 Plaintiff appeals both the judgment and the denial of her postjudgment motion.

DISCUSSION

Plaintiff’s broad-based attack on the court’s sanctions order starts by claiming that none of the referenced discovery orders was valid. Were she to fail in that endeavor, she also asserts that none was violated. In the event we conclude that plaintiff committed sanctionable misconduct, she urges us to set aside the sanctions order because the court neither gave her proper

1 Subsequent undesignated statutory references are to the Code of Civil Procedure. 3 notice of all the grounds for imposing sanctions, nor considered less severe alternatives to dismissal. Finally, plaintiff requests that we review the trial court’s denial of her section 473 motion. Resolving these issues requires that we evaluate the trial court’s exercise of discretion for abuse. (Britts v. Superior Court (2006) 145 Cal.App.4th 1112, 1123 (Britts) [discovery orders]; Doppes v. Bentley Motors, Inc. (2009) 174 Cal.App.4th 967, 992 (Doppes) [selection of a discovery sanction]; Henderson v. Pacific Gas & Electric Co. (2010) 187 Cal.App.4th 215, 230 [order denying motion for discretionary relief under § 473, subdivision (b)].) “The trial court’s findings of fact are reviewed for substantial evidence, its conclusions of law are reviewed de novo, and its application of the law to the facts is reversible only if arbitrary and capricious.” (Haraguchi v. Superior Court (2008) 43 Cal.4th 706, 711–712.) We “ ‘view the entire record in the light most favorable to the court’s ruling, and draw all reasonable inferences in support of it.’ ” (Sabetian v. Exxon Mobil Corp. (2020) 57 Cal.App.5th 1054, 1084.)

A. The Trial Court’s Imposition of a Terminating Sanction

1. The First Deposition Order

a. Additional Background Under the trial court’s original scheduling order, USD’s deadline to file its summary judgment motion was in September 2022, with trial set to begin in March 2023. After the summary judgment filing deadline had passed, defendants applied ex parte for an order continuing these and other trial- related dates because the parties for months had been unsuccessful in scheduling plaintiff’s deposition. USD also wanted some extra time in the schedule in case a motion to compel plaintiff’s deposition was required. The

4 court granted the requested continuance following a hearing conducted in early October 2022. Before concluding the hearing, the court confirmed with USD that its inability to take plaintiff’s deposition was “the hold up” in filing its summary judgment motion. The court wanted to “get this case going” by immediately setting a date for plaintiff’s deposition. When plaintiff declined the court’s request to pick a date in October 2022—she claimed she was not sure of her schedule—the court instead ordered plaintiff to sit for her deposition by November 15, 2022:

“[The Court:] Ready? I want the deposition of the . . . plaintiff done by November 15th. That gives you six weeks to work it out. Fair enough?

“[Ms. He:] Yes. Your Honor, I hope we can get all these depositions done by then, but –

“[The Court:] Well, we just got to make sure yours gets done. And you can schedule whatever deps you think is [sic] important, Ms.—Ms. He. Okay?”

A minute order memorializing the court’s ruling issued that day. In addition to amending the case schedule, it also contained the first deposition order, which stated that after “[h]aving heard from the parties, the court orders plaintiff’s deposition to be completed by November 15, 2022.” Shortly thereafter, USD proposed by e-mail five dates for plaintiff’s deposition—November 1, 7, 8, 9, or 14—and told her they would pick a date if she would not agree to one.

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He v. University of San Diego CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/he-v-university-of-san-diego-ca41-calctapp-2025.