JBS Carriers v. Mendoza CA4/1

CourtCalifornia Court of Appeal
DecidedJune 23, 2025
DocketD083415
StatusUnpublished

This text of JBS Carriers v. Mendoza CA4/1 (JBS Carriers v. Mendoza 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.

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JBS Carriers v. Mendoza CA4/1, (Cal. Ct. App. 2025).

Opinion

Filed 6/23/25 JBS Carriers v. Mendoza CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

JBS CARRIERS, INC., D083415

Plaintiff and Respondent,

v. (Super. Ct. No. CIVDS2017102)

MICHAEL MENDOZA, et al.,

Defendants and Appellants.

APPEAL from judgment and posttrial orders of the Superior Court of San Bernardino County, Gilbert G. Ochoa, Judge. Affirmed. Haight Brown & Bonesteel, Arezoo Jamshidi, Krsto Mijanovic, Patrick F. McIntyre and Kaitlyn A. Jensen for Defendants and Appellants. Wood Smith Henning & Berman, Stephen M. Caine, Wyeth E. Burrows and Steven D. Stutsman for Plaintiff and Respondent.

INTRODUCTION A JBS Carriers Inc. (JBS) tractor trailer crashed and tipped over on its side on the I-15 freeway, resulting in damage to the JBS truck and destruction of the load of lamb meat it was carrying. JBS sued Cindy Ann Diamond (the driver of a passenger vehicle) and Michael Mendoza (the driver of another tractor trailer), alleging their negligent driving caused the accident. JBS also sued Mendoza’s employers, Mesilla Valley Transportation, Inc. (Mesilla) and OEP Holdings, LLC (OEP), on a respondeat superior theory. By special verdict, the jury found Diamond, Mendoza, and Mesilla were negligent and their negligence was a substantial factor in causing JBS harm in the total amount of $204,528. The jury found JBS and OEP were not negligent. After being instructed that if Mendoza was acting within the scope of his employment when the accident occurred, “then his employer is responsible for any harm caused by . . . Mendoza’s negligence,” and the allocation of fault must total 100 percent, the jury assigned 80 percent fault to Diamond and 20 percent fault to Mesilla. The trial court entered a joint and several judgment for $204,528 against Mendoza, Mesilla, and Diamond. On appeal, as they did in their motion for judgment notwithstanding the verdict (JNOV), Mendoza, Mesilla, and OEP (collectively, the Mesilla

defendants)1 argue the jury’s assignment of zero “percentage of responsibility” to Mendoza was a verdict in favor of Mendoza, which then precludes a finding of vicarious liability against Mesilla. They argue the trial court’s interpretation of the jury’s special verdict and its subsequent costs award are erroneous. We conclude the trial court did not err and we affirm.

1 Diamond is not a party to this appeal.

2 FACTUAL AND PROCEDURAL BACKGROUND I. The Accident The evidence at trial established an accident occurred in April 2018 on the I-15 freeway, a four-lane highway, in San Bernardino County in California. The JBS tractor trailer was in front, driving in the right lane of the two-lane highway. Mendoza was operating a Mesilla-owned tractor trailer in the same lane behind the JBS truck. Diamond was driving a passenger sedan in the left lane, further behind Mendoza. Mendoza testified at trial that he sought to pass the JBS truck by moving into the left lane occupied by Diamond, and he saw Diamond’s car in his mirror at a time when she was far enough away to safely change lanes. According to Diamond, she was “push[ed] . . . into the center of the freeway” when Mendoza’s truck began to change lanes. Both the JBS and Mesilla tractor trailers were equipped with a “dashcam” that recorded the events surrounding the accident. A JBS accident reconstructionist analyzed the video recordings and testified to his conclusions. According to the expert’s calculations and review of the videos, as Mendoza began to initiate the lane change, Diamond “floored” her accelerator and tried to pass him before he could move over. Diamond was traveling at 88 miles per hour, or within a range of 80 to 90 miles per hour. Mendoza continued to move to the left without noticing Diamond’s car in his mirror. As he moved over, Diamond was unable to speed ahead of his truck. She lost control and her car veered onto the left shoulder of the highway. Once there, the left wheels of her car were no longer on the paved surface of the road. Instead, they were on the “sandy gravel area of the center median.” Diamond’s car continued to accelerate until she passed

3 Mendoza’s truck, but lost control again when she re-entered the paved portion of the highway. Her car then struck the JBS truck, causing it to crash and tip over onto its side. The accident damaged the JBS truck and trailer and destroyed its cargo of lamb meat. II. The Pleadings JBS’s complaint asserted causes of action for negligence and negligence per se against Mendoza, Mesilla, and Diamond. JBS alleged Mendoza and Diamond failed to exercise reasonable care while driving on the I-15 freeway, specifically they were both driving inattentively “at a speed unsafe for the traffic conditions.” JBS sought $204,517.51 in economic damages. Significant here, JBS’s complaint asserted Mesilla was vicariously liable for JBS’s damages because Mendoza was employed by Mesilla and driving on the highway at the time of the collision within the scope of his employment. In response to discovery propounded by JBS, Mendoza stated he was employed by OEP. JBS then added OEP as a named defendant. The sole theory for liability asserted in the complaint against Mesilla and OEP was respondeat superior. The complaint did not allege independent tort liability on the part of either company. All four defendants filed cross-complaints for comparative equitable indemnity against one another: Diamond against Mendoza and Mesilla, and Mendoza, Mesilla and OEP against Diamond. III. Jury Instructions At trial, the jury was provided with standard instructions on the principles of ordinary negligence and negligence per se.

4 A. Causation Relevant here, three jury instructions addressed the element of causation. As part of this series, at the defendants’ request, the trial court specifically instructed the jury on the elements of the affirmative defense that another party’s conduct (Diamond’s) was a superseding cause of JBS’s harm. The trial court used a modified version of CACI No. 432, as follows:

432[.] Affirmative Defense – Causation: Party’s Conduct as Superseding Cause

Michael Mendoza claims that he is not responsible for JBS’s harm because of the later misconduct of Cindy Diamond. To avoid legal responsibility for the harm, Michael Mendoza must prove all of the following:

1. That Cindy Diamond’s conduct occurred after the conduct of Michael Mendoza; 2. That a reasonable person would consider Cindy Diamond’s conduct a highly unusual or an extraordinary response to the situation; 3. That Michael Mendoza did not know and had no reason to expect that Cindy Diamond would act in a negligent manner; and 4. That the kind of harm resulting from Cindy Diamond’s conduct was different from the kind of harm that could have been reasonably expected from Michael Mendoza’s conduct.

B. Respondeat Superior Consistent with the complaint, the only theory at trial for Mesilla and OEP’s liability was vicarious liability. The parties agree JBS did not produce any evidence of independent negligence by Mesilla or OEP. The trial court provided the jury with two instructions that addressed the principle of respondeat superior, CACI No. 3700 and CACI No. 3703.

5 3700. Introduction to Vicarious Responsibility

An employer is responsible for harm caused by the wrongful conduct of its employees while acting within the scope of their employment.

3703. Legal Relationship

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