Kinsella v. Kinsella

CourtCalifornia Court of Appeal
DecidedFebruary 19, 2020
DocketD074989
StatusPublished

This text of Kinsella v. Kinsella (Kinsella v. Kinsella) 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
Kinsella v. Kinsella, (Cal. Ct. App. 2020).

Opinion

Filed 2/19/20

CERTIFIED FOR PUBLICATION

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

KEVIN KINSELLA, D074989

Plaintiff and Appellant,

v. (Super. Ct. No. 37-2018-00006622- CU-MC-CTL) TAMARA KINSELLA,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of San Diego County, Ronald L.

Styn, Judge. Reversed and remanded with directions.

Mazzarella & Mazzarella and Mark C. Mazzarella for Plaintiff and Appellant.

Wolfe Legal Group, Deborah A. Wolfe and Brian P. Worthington for Defendant

and Respondent.

In this lawsuit, the trial court ruled that the malicious prosecution complaint was a

SLAPP and struck it pursuant to Code of Civil Procedure section 425.16 (section 425.16).1 Plaintiff Kevin Kinsella appeals, arguing that the trial court erred in

determining that he did not establish the requisite probability of prevailing on the merits

of his claim against defendant Tamara Kinsella.2 We agree and will reverse the

judgment.

I. INTRODUCTION

To establish a cause of action for malicious prosecution, one of the elements the

plaintiff must prove is that the defendant lacked probable cause to bring the prior action.

(Parrish v. Latham & Watkins (2017) 3 Cal.5th 767, 775 (Parrish).) One way the

malicious prosecution defendant can establish probable cause for having brought the

prior action, thereby defeating the later malicious prosecution claim, is by showing an

interim victory on the merits in the prior action—such as the denial of a motion for

summary judgment by the defendant (i.e., the plaintiff in the malicious prosecution

action)—even where the prior action is ultimately terminated in favor of the defendant.

(Id. at pp. 776-777; Wilson v. Parker, Covert & Chidester (2002) 28 Cal.4th 811, 819

(Wilson).) This is known as the interim adverse judgment rule. The rule will not be

applied, however, where the interim victory in favor of the plaintiff in the prior action

1 " ' "SLAPP" is an acronym for "strategic lawsuit against public participation." ' " (Sweetwater Union High School Dist. v. Gilbane Building Co. (2019) 6 Cal.5th 931, 939, fn. 5 (Sweetwater).) The SLAPP statute, which sets forth the standards and procedure (anti-SLAPP motion) for striking the complaint in a SLAPP, is found at section 425.16.

2 Kevin and Tamara are former spouses who share the same surname. To avoid confusion, and consistent with the parties' appellate briefing, we shall refer to them by their first names.

2 (i.e., the defendant in the malicious prosecution action) was obtained by means of fraud,

perjury, or other unfair conduct. (Carpenter v. Sibley (1908) 153 Cal. 215, 218

(Carpenter); Wilson at pp. 817, 820, 825; Parrish, at pp. 776-778, 782.) This is known

as the fraud exception to the interim adverse judgment rule.

In the present case, these issues arise in the procedural context of an anti-SLAPP

motion brought by Tamara, the defendant in Kevin's malicious prosecution complaint.

Shortly after Tamara initiated dissolution of marriage proceedings against Kevin, Tamara

sued Kevin based on what she contended was his promise, prior to their marriage, that the

property and income they acquired during their relationship would belong equally to both

of them (Marvin Action). After Tamara voluntarily dismissed the Marvin Action, Kevin

sued her for malicious prosecution in the present action.

Seeking to have Kevin's malicious prosecution complaint stricken as a SLAPP,

Tamara responded with a section 425.16 anti-SLAPP motion. In her effort to establish

that Kevin could not show she lacked probable cause to prosecute the Marvin Action,

Tamara relied on the interim adverse judgment rule: She (1) presented evidence that the

trial court in the Marvin Action denied Kevin's motion for summary judgment, and

(2) argued that this interim victory on Kevin's summary judgment motion precluded

Kevin from establishing that Tamara lacked the requisite probable cause to file and

prosecute the Marvin Action. In opposition, Kevin relied on the fraud exception to the

interim adverse judgment rule: He argued that, because Tamara defeated Kevin's

summary judgment motion in the Marvin Action by having submitted materially false

facts on which the court relied in denying the motion, Tamara was not entitled to rely on

3 the interim adverse judgment rule's presumption that resulted from the denial of his

summary judgment motion in the Marvin Action.

The trial court granted Tamara's anti-SLAPP motion. In relevant part, the court

ruled as follows: By the application of the interim adverse judgment rule, Tamara met

her burden of establishing that Kevin cannot show that she lacked the requisite probable

cause to have prosecuted the Marvin Action; and Kevin did not meet his responsive

burden to allow the application of the fraud exception to the interim adverse judgment

rule.

As we explain, because Kevin set forth facts that establish a prima facie

application of the fraud exception, the court erred in applying the interim adverse

judgment rule to conclude that Kevin did not establish the requisite probability of

prevailing on his claim. Accordingly, we will reverse the judgment and remand with

directions that the court vacate its order granting Tamara's anti-SLAPP motion and enter

a new order denying the motion.

II. FACTUAL AND PROCEDURAL BACKGROUND

As we explain at part III., post, the issues in the present appeal all arise from the

second stage of the anti-SLAPP proceedings, during which the court determines whether

the plaintiff can establish a probability of prevailing on the merits of the claim.

(§ 425.16, subd. (b).) At this stage, "the court may consider affidavits, declarations, and

their equivalents if it is reasonably possible the proffered evidence set out in those

statements will be admissible at trial." (Sweetwater, supra, 6 Cal.5th at p. 949; see

§ 425.16, subd. (b)(2).) "Conversely, if the evidence relied upon cannot be admitted at

4 trial, because it is categorically barred or undisputed factual circumstances show

inadmissibility, the court may not consider it in the face of an objection." (Sweetwater, at

p. 949.)

In the present case, the parties rely on the following evidence contained in the

record on appeal: a declaration from Tamara's attorney; a declaration from Kevin;

various exhibits introduced by the two declarations; and Kevin's amended verified

complaint in this malicious prosecution action (verified complaint). Because the record

on appeal does not contain any evidentiary objections (or rulings denying the admission

of any proffered evidence), we consider all of the evidence submitted to the trial court

(see Sweetwater, supra, 6 Cal.5th at p. 949; Gallagher v. Connell (2004) 123 Cal.App.4th

1260, 1268 (Gallagher) [objections to evidence not made in the trial court's anti-SLAPP

proceedings are forfeited on appeal3])—as have the parties in their appellate briefing.

A. The Marvin Action: Tamara v. Kevin (Dec. 2013 - July 2015)

Tamara and Kevin lived together for 23 years, from a date in 1989 until May

2012. Kevin proposed marriage in May 1990; the parties married in April 1997 and

separated in May 2012; and Tamara filed for divorce in December 2012. According to

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Kinsella v. Kinsella, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kinsella-v-kinsella-calctapp-2020.