Janis v. Sacramento Housing and Redevelopment Agency CA3

CourtCalifornia Court of Appeal
DecidedMarch 25, 2024
DocketC098094
StatusUnpublished

This text of Janis v. Sacramento Housing and Redevelopment Agency CA3 (Janis v. Sacramento Housing and Redevelopment Agency CA3) 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
Janis v. Sacramento Housing and Redevelopment Agency CA3, (Cal. Ct. App. 2024).

Opinion

Filed 3/25/24 Janis v. Sacramento Housing and Redevelopment Agency CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 THIRD APPELLATE DISTRICT (Sacramento) ----

LYLE JANIS, C098094

Plaintiff and Appellant, (Super. Ct. No. 34-2022- 00326831-CU-PT-GDS) v.

SACRAMENTO HOUSING AND REDEVELOPMENT AGENCY,

Defendant and Respondent.

This appeal arises out of the failure to comply with the claim presentation requirements of the Government Claims Act (Gov. Code, § 810 et seq.) (the Act).1 The Act provides that no suit for money or damages may be brought against a public entity unless a claim has first been presented to the public entity and rejected by it. (§ 945.4.) A claim for personal injuries must be presented within six months of the accrual of the

1 Further undesignated statutory references are to the Government Code.

1 cause of action. (§ 911.2, subd. (a).) If it is not, the injured party may file an application with the public entity for leave to present a late claim. (§ 911.4, subd. (b).) If the application is denied, the injured party may file a petition in the superior court seeking relief from the claim presentation requirements of the Act. (§ 946.6, subd. (a).) The superior court “shall” grant the petition if, among other things, “[t]he failure to present the claim was through mistake, inadvertence, surprise, or excusable neglect.” (§ 946.6, subds. (b)(2) & (c)(1).) In this case, plaintiff and appellant Lyle Janis appeals the trial court’s decision denying his petition seeking relief from the claim presentation requirement of the Act. Finding no abuse of discretion, we affirm. FACTUAL AND PROCEDURAL BACKGROUND In ruling on a petition for relief from the claim presentation requirements, the trial court considers “the petition, any affidavits in support of or in opposition to the petition, and any additional evidence received at the hearing on the petition.” (§ 946.6, subd. (e).) The facts below thus come from these sources. On September 21, 2021, Janis sustained personal injuries when the bicycle he was riding was struck by a motor vehicle driven by Wilfredo Buenafe. Janis contended the accident was Buenafe’s fault because he failed to make a complete stop at a stop sign and failed to yield the right of way to Janis. Janis retained counsel sometime in September 2021, and in November 2021, his attorney requested a copy of the traffic collision report (the Report). Janis’s attorney stated the Report was delivered to her office sometime in December, and that it identified a public entity—namely, defendant and respondent Sacramento Housing and Redevelopment Agency (SHRA)—that was potentially liable for Janis’s injuries.2 The

2 In particular, the Report states Buenafe was driving the vehicle that hit Janis, and that the vehicle was owned by SHRA.

2 attorney also stated her secretary failed to give her the Report when it was delivered. The attorney acknowledged the deadline to present a timely claim to SHRA was March 21, 2022, but she stated her secretary “failed to calendar the . . . claim,” and the claim thus was not timely presented “[d]ue to a calendaring mistake” by “clerical staff.” She stated she first learned of the mistake when “the attorney representing [SHRA] called and left a message inquiring about the status of the claim,” and she then “[i]mmediately” filed an application to present a late claim on April 22, 2022. SHRA denied the application on May 19, 2022. Janis then filed a petition for relief from the claim presentation requirements. He argued the failure to file a timely claim was due to a “calendaring mistake by [his] attorney’s clerical staff,” and the mistake was “excusable.” He supported his petition with a declaration from his attorney that recounted the facts set forth above. SHRA opposed the petition but did not submit any additional declaration(s) or evidence. The court denied the petition, finding Janis failed to present sufficient evidence that the failure to file a timely claim was due to mistake, inadvertence, surprise or excusable neglect within the meaning of section 946.6. In particular, the court found Janis’s attorney was not diligent because although she requested the Report in November 2021, she never followed up on the request to see if the Report had been received, and thus did not know until after the claim presentation deadline had expired that it had been sitting in her office for months and showed SHRA’s involvement in the accident. Janis filed a timely notice of appeal. DISCUSSION I Standard of Review The decision to grant or deny a petition seeking relief from the claim presentation requirements “is within the sound discretion of the trial court and will not be disturbed on appeal except for an abuse of discretion.” (Bettencourt v. Los Rios Community College

3 Dist. (1986) 42 Cal.3d 270, 275.) The abuse of discretion standard is deferential, and we may not substitute our own judgment for that of the trial court whose job it is to decide these petitions. (Munoz v. State of California (1995) 33 Cal.App.4th 1767, 1783.) “ ‘[W]e are not interested in the question as to whether the trial court could have granted relief based on the claimed mistake . . . , but, since the trial court denied relief, only in whether such holding was within its discretion.’ ” (Tammen v. County of San Diego (1967) 66 Cal.2d 468, 476.) Janis acknowledges the denial of the petition is reviewed for an abuse of discretion, but he emphasizes our Supreme Court has stated, “Section 946.6 is a remedial statute intended to provide relief from technical rules which otherwise provide a trap for the unwary claimant. [Citation.] The remedial policies underlying the statute are ‘that wherever possible cases be heard on their merits, and any doubts which may exist should be resolved in favor of the application.’ [Citation.] Thus, ‘[a]n appellate court will be more rigorous in examining the denial of such relief than its allowance.’ ” (Ebersol v. Cowan (1983) 35 Cal.3d 427, 435; see also Bettencourt v. Los Rios Community College Dist., supra, 42 Cal.3d at p. 276 [“In light of the policy considerations underlying section 946.6, a trial court decision denying relief will be scrutinized more carefully than an order granting relief”].) This is true, and, as directed, we have rigorously reviewed the trial court’s decision in this case. We note, however, that being “more rigorous” does not change the underlying standard of review, which remains the deferential abuse of discretion standard. We also note, “The general policy favoring trial on the merits cannot be applied indiscriminately so as to render ineffective the statutory time limits” (Department of Water & Power v. Superior Court (2000) 82 Cal.App.4th 1288, 1293 (Department of Water & Power)), and, “It is not the purpose of remedial statutes to grant relief from [mistakes] which are the result of inexcusable neglect of parties or their attorneys in the performance of the latter’s obligation to their clients” (Tammen v. County of San Diego, supra, 66 Cal.2d at p. 478).

4 II Section 946.6 “Before a court may relieve a claimant from the [Act’s] claim filing requirements, the claimant must demonstrate by a preponderance of the evidence . . . that the failure to file a timely claim was due to mistake, inadvertence, surprise or excusable neglect. [Citation.] [¶] The mere recital of mistake, inadvertence, surprise or excusable neglect is not sufficient to warrant relief.

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Related

Bettencourt v. Los Rios Community College District
721 P.2d 71 (California Supreme Court, 1986)
Ebersol v. Cowan
673 P.2d 271 (California Supreme Court, 1983)
Cole v. City of Los Angeles
187 Cal. App. 3d 1369 (California Court of Appeal, 1986)
Flores v. Board of Supervisors of Los Angeles County
13 Cal. App. 3d 480 (California Court of Appeal, 1970)
Munoz v. State of California
33 Cal. App. 4th 1767 (California Court of Appeal, 1995)
Department of Water & Power v. Superior Court
99 Cal. Rptr. 2d 173 (California Court of Appeal, 2000)
Tammen v. County of San Diego
426 P.2d 753 (California Supreme Court, 1967)

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Bluebook (online)
Janis v. Sacramento Housing and Redevelopment Agency CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/janis-v-sacramento-housing-and-redevelopment-agency-ca3-calctapp-2024.