Mitchell v. Hutchinson

CourtCalifornia Court of Appeal
DecidedJuly 10, 2025
DocketG063331
StatusPublished

This text of Mitchell v. Hutchinson (Mitchell v. Hutchinson) 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
Mitchell v. Hutchinson, (Cal. Ct. App. 2025).

Opinion

Filed 6/11/25; Certified for Publication 7/10/25 (order attached)

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

ANTHONY MITCHELL et al.,

Plaintiffs and Appellants, G063331

v. (Super. Ct. No. 30-2020- 01173441) GAIL B. HUTCHINSON, OPINION Individually and as Trustee, etc.,

Defendant and Respondent.

Appeal from a judgment of the Superior Court of Orange County, Walter P. Schwarm, Judge. Affirmed. Law Offices of Gene J. Goldsman, Gene J. Goldsman and Ernest J. Lingenfelter for Plaintiffs and Appellants. Lewis Brisbois Bisgaard & Smith, Jeffry A. Miller, and Daniel R. Velladao for Defendant and Respondent. This tort case involves application of the alternative liability theory of causation—first approved by the California Supreme Court in the landmark case of Summers v. Tice (1948) 33 Cal.2d 80 (Summers)—in the context of a summary judgment motion. While driving his Ferrari on a street in Dana Point, plaintiff Anthony Mitchell ran over and dragged with the 1 underside of his vehicle one or more large rocks that had rolled onto the roadway from the adjacent slope, causing extensive damage to Mitchell’s car 2 and unspecified personal injuries. Unable to determine the precise location from which the rocks fell, plaintiffs elected to sue multiple parties, each of whom owns a portion of the slope, for negligence and premises liability, including defendant Gail B. Hutchinson, trustee of the Hutchinson Family Trust (Hutchinson).3

1 Plaintiffs refer to the rocks that Mitchell drove over as boulders, and Hutchinson refers to them as rocks. The difference in terminology has no bearing on the resolution of this appeal. Accordingly, for the sake of simplicity and consistency, we refer to them as rocks.

2 Mitchell’s passenger, Scott Sieverts, also was named as a plaintiff in the action. It is unclear from the record what, if any, personal injuries he and Mitchell are alleged to have suffered.

3 Plaintiffs named Gail B. Hutchinson and the Gail B.

Hutchinson Trust as defendants in the action, and alleged both are the owners of certain property adjacent to the roadway where the incident occurred. “[A] trust itself can neither sue nor be sued in its own name. Instead, the real party in interest in litigation involving a trust is always the trustee.” (Presta v. Tepper (2009) 179 Cal.App.4th 909, 914.) Hutchinson submitted evidence in support of the summary judgment motion that the property is an asset of the trust, which was not disputed by plaintiffs. We assume, therefore, that plaintiffs intended to sue Hutchinson solely in her capacity as trustee.

2 Hutchinson moved for summary judgment on the issue of causation. The trial court granted the motion and entered judgment in favor of Hutchinson. Plaintiffs appeal that order and the resulting judgment in favor of Hutchinson. We affirm. Hutchinson met her initial burden pursuant to Code of Civil Procedure section 437c, subdivision (p)(2) of showing plaintiffs cannot 4 prove the element of causation as to both of their causes of action. The burden then shifted to plaintiffs to show the existence of a triable issue of material fact as to (1) whether the rocks came from Hutchinson’s property or, alternatively, (2) whether Hutchinson and the other owners of the adjacent hillside acted negligently in maintaining their slopes such that the burden of proof on the issue of causation would shift to defendants at trial under Summers. Because plaintiffs did neither, Hutchinson was entitled to summary judgment. FACTUAL AND PROCEDURAL HISTORY In their operative first amended complaint filed January 29, 2021, plaintiffs alleged the subject rocks came from “one of” several properties and that defendants “breached their duty of care when they failed to maintain their property . . . to prevent boulders from becoming hazards to motorists by failing to erect fencing or barriers to keep said boulders from rolling down the hill.” Plaintiffs further alleged defendants “had notice of the boulders on their property and failed to protect against them rolling into the

4 All further statutory references are to the Code of Civil Procedure unless otherwise stated.

3 below roadway” and that it was “foreseeable that boulders would roll onto the 5 roadway.” After conducting discovery on the issue of causation and securing an expert to opine that “[t]he physical location of the rocks prior to the accident will never be known with any certainty” and the rocks “could have come from any number of properties,” Hutchinson moved for summary judgment on plaintiffs’ complaint. Plaintiffs opposed the motion and included a declaration from an expert who opined that “the subject rocks . . . likely 6 came from one of the three Defendants’ properties.” (Italics added.) Plaintiffs’ expert also opined that the movement of the rocks down the hillside slope was triggered by rain preceding the incident, the rocks entered the roadway “due to unencumbered passage from a lack of barriers and/or landslide suppression methods,” and defendants were aware the hillside is prone to releasing rocks due to earth shifting, irrigation, or a myriad of other factors that contribute to loose bedrock. The motion was heard concurrently with motions for summary judgment filed by the other owners of the adjacent hillside. The trial court granted summary judgment in favor of all of the property owners, including Hutchinson. As to Hutchinson, the court concluded she had met her initial burden on summary judgment and the evidence “show[ed] only that

5 Plaintiffs also sued the city of Dana Point.

6 We notified the parties of our intent to augment the record on appeal to include plaintiffs’ opposition to Hutchinson’s motion for summary judgment pursuant to California Rules of Court, rule 8.155(a)(1)(A), and invited the parties to submit supplemental briefing addressing these additional documents. Hutchinson filed supplemental briefing and objected to the augmentation. We overrule the objection.

4 [Hutchinson’s] property was a potential source of the rocks that rolled onto the roadway.” The trial court also concluded plaintiffs’ evidence did not create a triable issue of material fact that defendants negligently maintained their respective properties so as to shift the burden on the issue of causation to defendants. Plaintiffs timely appealed the order and resulting judgment. DISCUSSION I. STANDARD OF REVIEW Summary judgment is properly granted if “there is no triable issue as to any material fact and . . . the moving party is entitled to a judgment as a matter of law.” (§ 437c, subd. (c).) “A defendant seeking summary judgment must show that the plaintiff cannot establish at least one element of the cause of action.” (Regents of University of California v. Superior Court (2018) 4 Cal.5th 607, 618; see § 437c, subd. (p)(2).) If the defendant makes this showing, “the burden shifts to the plaintiff . . . to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.” (§ 437c, subd. (p)(2).) “‘On review of an order granting or denying summary judgment, we examine the facts presented to the trial court and determine their effect as a matter of law.’ [Citation.] We review the entire record, ‘considering all the evidence set forth in the moving and opposition papers except that to which objections have been made and sustained.’ [Citation.] Evidence presented in opposition to summary judgment is liberally construed, with any doubts about the evidence resolved in favor of the party opposing the motion.” (Regents of the University of California v. Superior Court, supra, 4 Cal.5th at p. 618.) “Summary judgment is appropriate only ‘where no triable issue of

5 material fact exists and the moving party is entitled to judgment as a matter of law.’” (Ibid.) II.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sargon Enterprises, Inc. v. University of Southern California
288 P.3d 1237 (California Supreme Court, 2012)
Castellon v. U.S. Bancorp
220 Cal. App. 4th 994 (California Court of Appeal, 2013)
Summers v. Tice
199 P.2d 1 (California Supreme Court, 1948)
Haft v. Lone Palm Hotel
478 P.2d 465 (California Supreme Court, 1970)
CDF FIREFIGHTERS v. Maldonado
70 Cal. Rptr. 3d 667 (California Court of Appeal, 2008)
Presta v. Tepper
179 Cal. App. 4th 909 (California Court of Appeal, 2009)
Consumer Cause, Inc. v. Smilecare
110 Cal. Rptr. 2d 627 (California Court of Appeal, 2001)
Dumin v. Owens-Corning Fiberglas Corp.
28 Cal. App. 4th 650 (California Court of Appeal, 1994)
Aguilar v. Atlantic Richfield Co.
24 P.3d 493 (California Supreme Court, 2001)
Saelzler v. Advanced Group 400
23 P.3d 1143 (California Supreme Court, 2001)
Shiffer v. CBS Corp.
240 Cal. App. 4th 246 (California Court of Appeal, 2015)
Sanchez v. Kern Emergency Medical Transportation Corp.
8 Cal. App. 5th 146 (California Court of Appeal, 2017)
The Regents of the University of California v. Superior Court
413 P.3d 656 (California Supreme Court, 2018)
Rutherford v. Owens-Illinois, Inc.
941 P.2d 1203 (California Supreme Court, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
Mitchell v. Hutchinson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-hutchinson-calctapp-2025.