Nelson v. Eastern Municipal Water District CA4/1

CourtCalifornia Court of Appeal
DecidedDecember 31, 2024
DocketD083321
StatusUnpublished

This text of Nelson v. Eastern Municipal Water District CA4/1 (Nelson v. Eastern Municipal Water District 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.

Bluebook
Nelson v. Eastern Municipal Water District CA4/1, (Cal. Ct. App. 2024).

Opinion

Filed 12/31/24 Nelson v. Eastern Municipal Water District CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

JEFFREY NELSON, D083321

Plaintiff and Appellant,

v. (Super. Ct. No. CVRI2203741)

EASTERN MUNICIPAL WATER DISTRICT,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Riverside County, Carol A. Greene, Judge. Affirmed.

Best Best & Krieger, Gregory G. Snarr, and Michael Thies for Plaintiff and Appellant. Graves & King, Harvey W. Wimer III, and Bethany J. Ring for Defendant and Respondent. This case highlights the importance of a critical skill for all attorneys— attention to detail. For a plaintiff’s counsel, it is essential to make sure you sue the correct party. True, there may be times when it is difficult for a plaintiff to identity the entity that is causing injury. This is not one of those cases. On the other side of the coin, a defense counsel must carefully read the complaint to ensure he or she knows what entity has been sued. This may sound like a most basic task (and it is), but, in this case, it did not happen. Not surprisingly, confusion permeated the dispute, and this appeal is now before us.

The Government Claims Act (the Act) (Gov. Code,1 § 810 et seq.) requires that an individual who believes he or she has been injured by a public entity file a claim against that public entity before initiating a lawsuit in California superior court. (See § 911.2.) Here, Jeffrey Nelson believed that he was being injured by the acts of a neighboring landowner, the Eastern Municipal Water District (District). Per the Act and with the apparent help of counsel, Nelson filed the appropriate claim against the District. The District denied the claim in writing, which then required Nelson to sue the District within six months. (See § 945.6, subd. (a)(1).) Three months after the denial, Nelson filed suit in the Superior Court of Riverside County. However, instead of naming the District as a defendant, he named the Eastern Municipal Water District Facilities Corporation (Facilities Corporation). As Nelson alleged, the Facilities Corporation is not a public entity but “a California nonprofit mutual benefit corporation.” After Nelson served the Facilities Corporation with the complaint, an attorney who claimed to represent the District sent a meet and confer letter to Nelson’s counsel, explaining why he believed the complaint did not state a valid claim against a public entity. However, the District had not been sued. Further, Nelson had not named a public entity as a defendant in his complaint. Not surprisingly, tumult followed.

1 Statutory references are to the Government Code unless otherwise specified. 2 Nelson filed a first amended complaint, attempting to address the issues defense counsel noted. Yet, despite adding additional language related to suing a public entity, the amended complaint neither sued a public entity nor added the District as a defendant. These shortcomings did not stop defense counsel from again claiming that he represented the District in the action and again noting certain deficiencies in the complaint regarding claims against a public entity. Only after the Facilities Corporation demurred to the first amended complaint did Nelson’s counsel and defense counsel apparently understand the litigation quagmire that had been created. Nelson filed a second amended complaint, finally naming the District as a defendant but did so beyond the six month time limit of the Act. After the District’s successful demurrer, the court granted Nelson leave to amend so he could allege why his suit against the District was not time-barred. Nelson thus filed a third amended complaint to which the District also demurred. The superior court sustained the demurrer without leave to amend and subsequently entered a judgment of dismissal. Nelson appeals, arguing that the superior court erred in sustaining the demurrer because equitable estoppel and/or equitable tolling prohibit the application of the statute of limitations here. We are not persuaded and thus affirm the judgment. FACTUAL AND PROCEDURAL BACKGROUND Nelson owns two homes located a little more than 1,000 feet from certain real property owned by the District. The District is a public entity that provides water, wastewater, and recycled water to about 880,000 people in Riverside County.

3 In 1979, the District created the Facilities Corporation under California’s mutual non-profit public benefit corporation law “ ‘for the purpose of rendering financial assistance to [the District] by acquiring, constructing, and operating or providing for the operation of water and wastewater facilities, including . . . treatment plants and related facilities for the use, benefit and enjoyment of the public within [the District’s] boundaries.” The District and the Facilities Corporation have been engaging in certain improvement projects on the District’s property, including expanding an outdoor pond used to store treated wastewater. As part of that project, the District and the Facilities Corporation have excavated about 1.65 million cubic yards of dirt and remain in the process of selling that dirt. Nelson believes that the excavated dirt has “collected harmful chemicals and other hazardous materials.” Accordingly, “[t]he excavation and on-site storage of the contaminated soil from the construction of [the pond] allowed for fine, inhalable particles and dust to be raised in the air by wind or other atmospheric conditions and carried into surrounding communities,” including the two homes owned by Nelson. The “ ‘fugitive emissions’ ” and “ ‘fugitive dust’ ” allegedly pose a threat to the environment and human health, causing damages to Nelson’s homes and having a “significant impact to . . . Nelson’s health.” The District hired Commodity Trucking Acquisition, LLC doing business as Dispatch Transportation (Dispatch Transportation) to remove some of the excavated dirt from the District’s property, but Nelson alleged that neither the District nor Dispatch Transportation “use[d] adequate or proper methods to prevent dust and other materials from escaping [the District’s] [p]roperty.” This caused additional harm to Nelson’s homes and

4 his health. Specifically, because of the actions of the District, the Facilities Corporation, and Dispatch Transportation, Nelson has had a more difficult time recovering from throat cancer. On April 27, 2022, Nelson, in compliance with the Act, submitted a claim to the District on the District’s “official claim form,” a pre-printed form requiring a claimant to provide certain information, including name, address, and injury. The claim form was addressed only to the District and included the District’s mailing address (a P.O. Box) and a physical address where claims could be submitted. Nelson asserted that he and his homes had been damaged “[o]n account of improper dirt removal activities and resulting fugitive dust” on property owned by the District. Nelson sought damages in the amount of $2.7 million. In this claim, there was no mention of the Facilities Corporation whatsoever. On June 2, 2022, the District, through its general counsel, denied Nelson’s claim. In doing so, the District informed Nelson that he had six months from the date of the denial “to file a Court action on this claim.” Moreover, the District referred Nelson specifically to the statutes governing such claims, Government Code sections 900 et seq. and 945.6.

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

Related

Scott v. JPMorgan Chase Bank
214 Cal. App. 4th 743 (California Court of Appeal, 2013)
In Re Marriage of Comer
927 P.2d 265 (California Supreme Court, 1996)
Blank v. Kirwan
703 P.2d 58 (California Supreme Court, 1985)
Kleinecke v. Montecito Water District
147 Cal. App. 3d 240 (California Court of Appeal, 1983)
Bertorelli v. City of Tulare
180 Cal. App. 3d 432 (California Court of Appeal, 1986)
Martin v. Bridgeport Community Assn., Inc.
173 Cal. App. 4th 1024 (California Court of Appeal, 2009)
Orr v. City of Stockton
58 Cal. Rptr. 3d 662 (California Court of Appeal, 2007)
Christopher P. v. Mojave Unified School District
19 Cal. App. 4th 165 (California Court of Appeal, 1993)
Fundamental Investment Growth Shelter Realty Fund v. Gradow
28 Cal. App. 4th 966 (California Court of Appeal, 1994)
Paniagua v. ORANGE COUNTY FIRE AUTHORITY
56 Cal. Rptr. 3d 746 (California Court of Appeal, 2007)
Cantu v. Resolution Trust Corp.
4 Cal. App. 4th 857 (California Court of Appeal, 1992)
Shirk v. Vista Unified School District
164 P.3d 630 (California Supreme Court, 2007)
Tammen v. County of San Diego
426 P.2d 753 (California Supreme Court, 1967)
Driscoll v. City of Los Angeles
431 P.2d 245 (California Supreme Court, 1967)
Long v. Forty Niners Football Co.
244 Cal. Rptr. 3d 887 (California Court of Appeals, 5th District, 2019)
United Grand Corp. v. Malibu Hillbillies, LLC
248 Cal. Rptr. 3d 294 (California Court of Appeals, 5th District, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Nelson v. Eastern Municipal Water District CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nelson-v-eastern-municipal-water-district-ca41-calctapp-2024.