Hoffman v. Fossa CA2/3

CourtCalifornia Court of Appeal
DecidedMay 20, 2026
DocketB347878
StatusUnpublished

This text of Hoffman v. Fossa CA2/3 (Hoffman v. Fossa CA2/3) 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
Hoffman v. Fossa CA2/3, (Cal. Ct. App. 2026).

Opinion

Filed 5/20/26 Hoffman v. Fossa CA2/3 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 THREE

ISAIAH HOFFMAN, B347878

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. 24STCV29811) v.

TRICIA FOSSA,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Jon Takasugi, Judge. Reversed in part, affirmed in part, and remanded with directions. PLC Law Group, Na’shaun L. Neal, Peter L. Carr, and Lauren K. McRaae for Plaintiff and Appellant. Law Office of Cleidin Z. Atanous, Cleidin Z. Atanous; Bretoi, Lutz & Stele and Brian S. Dewey for Defendant and Respondent. ‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗

Plaintiff and appellant Isaiah Hoffman filed a complaint against defendant and respondent Tricia Fossa on the final day of the two-year limitations period for his personal injury claim. A clerk of the trial court rejected the complaint the following day because of a mistake on an addendum to the complaint’s cover sheet. Hoffman refiled the complaint that same day and the clerk accepted it the next day. The trial court sustained demurrers to Hoffman’s original and amended complaints on the ground that the applicable limitations period had expired. We conclude the amended complaint sufficiently alleged that the statute of limitations was tolled pursuant to Code of Civil Procedure section 1010.6, subdivision (e)(4)(E) (section 1010.6(e)(4)(E)), and Hoffman filed the complaint within the limitations period as tolled.1 The trial court also sustained the demurrer to a bad faith insurance cause of action against Fossa, on independent grounds. Hoffman does not challenge this aspect of the trial court’s ruling on appeal. We reverse in part, affirm in part, and remand with instructions. FACTUAL AND PROCEDURAL BACKGROUND On November 12, 2022, Fossa’s car allegedly rear-ended Hoffman’s car on the 110 freeway. On November 12, 2024, Hoffman filed a complaint against Fossa, which asserted a cause of action of general negligence and alleged that Hoffman sustained injuries as a result of the car accident. Hoffman also

1 All undesignated statutory references are to the Code of Civil Procedure.

2 asserted a cause of action against Mercury Insurance Company (Mercury), which he later dismissed as a defendant. The following day, the clerk of court rejected the complaint. The “Notice of Court Rejection of Electronic Filing” (notice of rejection) stated that the complaint had been electronically submitted on November 12, 2024, and that the notice of rejection was generated on November 13. The notice provided the following reason for the rejection: “Per Cover Sheet Addendum Step 4, case is a Class Action suit. If so, please resubmit and select Spring Street Courthouse to ensure docs are routed to proper workflow for timely processing.” Hoffman refiled the complaint on November 13, 2024. Fossa demurred to the complaint on the ground that it was filed two years and one day after the accident occurred. Under section 335.1, an action for injury caused by the neglect of another must be brought within two years. The trial court sustained the demurrer on the ground that it was bound by the pleadings when ruling on a demurrer, and the complaint did not allege any facts to support tolling the statute of limitations. The court granted Hoffman leave to amend. In the first amended complaint, under a heading titled “TOLLING STATUTE OF LIMITATIONS DUE TO COURT’S ADMINISTRATIVE REJECTION,” Hoffman alleged he filed his complaint on November 12, 2024; the clerk rejected it on November 13; Hoffman refiled it on November 13; and the clerk accepted it on November 14. He further alleged: “Therefore, Plaintiff’s complaint was timely filed. See CCP § 1016(e)(4)(E).”2

2 Section 1016 has no subdivisions and states: “The foregoing provisions of this Chapter do not apply to the service of a

3 In addition to general negligence and motor vehicle personal injury causes of action, the amended complaint asserted a cause of action for bad faith insurance practices, nominally against Fossa. Fossa demurred to all causes of action on the ground that the applicable statute of limitations had expired. Fossa argued that section 1016 “has nothing to do with the issues at hand” and did not establish the statute of limitations should be tolled. Fossa also demurred to the bad faith insurance cause of action on the ground that she is not an insurer. Hoffman submitted a declaration attaching the notice of rejection with his opposition. His opposition memorandum did not cite section 1010.6(e)(4)(E) or address the bad faith insurance cause of action. At the hearing on the demurrer, Hoffman’s attorney argued the statute of limitations should be tolled pursuant to section 1010.6(e)(4)(E), the text of which he quoted, although he referred to it as “California Civil Procedure 1010.6, . . . subsection 4(C).” Fossa’s attorney argued the trial court could not consider the statute because Hoffman had not raised it in his opposition papers. In its order sustaining the demurrer, the trial court observed that Hoffman had presumably intended to assert the bad faith insurance cause of action against Mercury, rather than Fossa, and concluded that Hoffman lacked standing to assert the cause of action against Mercury. The court also sustained the demurrer as to all causes of action without leave to amend on statute of limitations grounds. It concluded that Hoffman “did

summons or other process, or of any paper to bring a party into contempt.” Hoffman presumably intended to cite section 1010.6(e)(4)(E).

4 not allege any facts which could show the statute of limitations was tolled for any reason.” The order did not address section 1010.6(e)(4)(E). The court dismissed the action and Hoffman timely appealed. DISCUSSION I. Standard of Review “Because the function of a demurrer is to test the sufficiency of a pleading as a matter of law, we apply the de novo standard of review in an appeal following the sustaining of a demurrer without leave to amend. [Citation.] We assume the truth of the allegations in the complaint, but do not assume the truth of contentions, deductions, or conclusions of law. [Citation.] It is error for the trial court to sustain a demurrer if the plaintiff has stated a cause of action under any possible legal theory . . . .” (California Logistics, Inc. v. State of California (2008) 161 Cal.App.4th 242, 247.) “ ‘ “Moreover, the allegations must be liberally construed with a view to attaining substantial justice among the parties,” ’ and ‘ “[o]ur primary task is to determine whether the facts alleged provide the basis for a cause of action . . . under any theory.” ’ [Citation.]” (Packard v. Packard (2025) 108 Cal.App.5th 1284, 1290–1291.) “[T]he ‘any possible legal theory’ standard encompasses a legal theory presented for the first time in an opening appellant’s brief” and “also includes legal theories first raised by the reviewing court.” (Gutierrez v. Carmax Auto Superstores California (2018) 19 Cal.App.5th 1234, 1244, 1245 (Gutierrez).) In ruling on a demurrer, “[r]elevant matters that are properly the subject of judicial notice may be treated as having

5 been pled.” (Ross v. Creel Printing & Publishing Co. (2002) 100 Cal.App.4th 736, 742; § 430.30, subd. (a).) On our own motion, we take judicial notice of the notice of rejection. (Evid. Code, §§ 452, subd. (d), 455, subd. (a), 459, subds. (a), (b); Bai v.

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Related

Ross v. Creel Printing & Publishing Co.
122 Cal. Rptr. 2d 787 (California Court of Appeal, 2002)
CALIFORNIA LOGISTICS, INC. v. State
73 Cal. Rptr. 3d 825 (California Court of Appeal, 2008)
People v. Toney
82 P.3d 778 (California Supreme Court, 2004)
In Re Marriage of Arceneaux
800 P.2d 1227 (California Supreme Court, 1990)
Gutierrez v. Carmax Auto Superstores Cal.
228 Cal. Rptr. 3d 699 (California Court of Appeals, 5th District, 2018)

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Bluebook (online)
Hoffman v. Fossa CA2/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoffman-v-fossa-ca23-calctapp-2026.