Nguyen v. Cramer CA4/3

California Court of Appeal·Decided August 14, 2026·No. G065995·Unpublished

Opinion

Filed 8/13/26 Nguyen v. Cramer CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

PETER NGUYEN,

Plaintiff and Appellant, G065995

v. (Super. Ct. No. 30-2024-

01381650)

RITA CRAMER et al., OPINION

Defendants and Respondents.

Appeal from a judgment of the Superior Court of Orange County, Sheila Recio, Judge. Affirmed. Appellant’s Motion Re Appealability, Structural Error and Judicial Bias, and Objections to Costs. Denied.

Peter Nguyen, in pro. per., on behalf of Plaintiff and Appellant. Woodruff & Smart, Caroline A. Byrne and Roberta A. Kraus, on behalf of Defendants and Respondents.

Plaintiff Peter Nguyen appeals the judgment entered against him in favor of defendants Rita Cramer, Rafael Avila, Jake Tran, and Lisa L. Kim (respondents) after the trial court sustained their demurrer to his operative third amended complaint (TAC) without leave to amend.1 Plaintiff failed to designate key documents necessary to our review of the trial court’s order sustaining respondents’ demurrer, including the demurrer papers; failed to provide record citations to support his assertions; and failed to provide developed legal argument with citation to authority with respect to his challenge to key aspects of the trial court’s ruling. We conclude plaintiff has forfeited his arguments challenging the judgment, which we presume to be correct. And even assuming plaintiff did not forfeit his arguments on appeal, we have considered the allegations of the TAC in the light most favorable to plaintiff and find no error on the face of the order sustaining respondents’ demurrer or the judgment. We affirm.

STATEMENT OF FACTS AND PROCEDURAL HISTORY During an inspection of solar panels at plaintiff’s residential property, representatives of the City of Garden Grove (City) noticed several violations of the Garden Grove Municipal Code. When plaintiff refused the City’s request to further inspect the property with respect to those violations, the City obtained an inspection warrant from the Orange County Superior

1

Plaintiff filed this action in Orange County Superior Court while another case he had filed against the same defendants arising from the same set of alleged facts was already pending in that court. (See Nguyen v. Hutchins, Orange County Superior Court case No. 30-2024-01374287.) Plaintiff’s appeal from a judgment entered against plaintiff in that other case is also pending before us (case No. G065994). Although related, the cases have not been consolidated.

Court.2 Pursuant to the warrant, the City conducted a second inspection of the property, which plaintiff alleges was a “forcible entry.”

Plaintiff filed his initial complaint in this action on February 28, 2024, and his TAC on August 12, 2024.3 The TAC includes 11 causes of action against seven defendants, including the four respondents in this appeal, as well as the City of Garden Grove (City), city attorney Nicholas A. Hutchins, and chief building official David Dent. The causes of action included (1) violation of 42 United States Code section 1983,4 (2) perjury, (3) contempt of court, (4) obstruction of justice, (5) unlawful search, (6) retaliation, (7) aiding and abetting, (8) malicious prosecution, (9) intentional misrepresentation, (10) false imprisonment, and (11) intentional infliction of emotional distress. Among other things, plaintiff alleged defendants caused damage to portions of his property during the inspection performed pursuant to the warrant, the inspection warrant was deficient and obtained through false statements, defendants caused plaintiff and members of his family to

2

Plaintiff alleges defendant Avila told him the warrant was obtained based on a third party’s complaint about plaintiff’s property.

3

Plaintiff did not designate the TAC as part of the record on appeal, but instead designated his first amended complaint filed March 14, 2024, which was superseded by the second amended complaint filed August 8, 2025, which in turn was superseded by the TAC filed August 12, 2025. Respondents added the TAC to the record pursuant to their motion to augment, which we previously granted.

4

This cause of action was alleged only against the City, Hutchins, and Dent.

stand outside in the rain during the inspection and to suffer distress, and defendants exceeded the scope of permissible inspections.

On March 28, 2025, before respondents had been served in the action, the trial court sustained without leave to amend the demurrer to the TAC filed by the City, Hutchins, and Dent. The court determined (1) plaintiff had failed to allege compliance with the Government Claims Act (Gov. Code, § 810 et seq., Tort Claims Act); (2) plaintiff failed to allege facts sufficient to show the doctrine of estoppel applied to preclude defendants from invoking the Tort Claims Act; (3) plaintiff continues to allege causes of action for perjury, contempt of court, and obstruction of justice, which are not valid causes of action; (4) the court previously found Hutchins and Dent are entitled to absolute immunity but plaintiff had failed to address that ruling in the TAC; and (5) despite having had a prior opportunity to amend and rectify these deficiencies in his prior pleading, plaintiff failed to do so.5 On April 16, 2025, the court issued a minute order that stated it was declining to enter judgment because respondents had not been served and also ordered plaintiff to show cause why the court should not impose sanctions against him, including dismissal of the action, for failure to serve respondents and prosecute the case against them.

On September 19, 2025, after respondents were brought into the action, the trial court entered an order sustaining their demurrer to the TAC

5

The court’s March 28, 2025 order indicated that, although the court had sustained demurrers to plaintiff’s prior pleadings on the grounds plaintiff had failed to comply with the Tort Claims Act and Hutchins and Dent were entitled to absolute immunity, the allegations in plaintiff’s TAC remained “essentially unchanged.” The court referenced a minute order issued August 1, 2024, but plaintiff did not include that order as part of the record on appeal.

on the same grounds set forth in its March 28, 2025 minute order. The court also denied plaintiff’s motion for reconsideration of the April 16, 2025 order, noting the order “simply reflect[ed] that (1) the court declined signing a proposed judgment at that time because the case was not yet resolved as to [m]oving [d]efendants and (2) the court set an Order to Show [Cause re] Sanctions for failure to serve and prosecute as to the [m]oving [d]efendants.”6 Plaintiff filed a notice of appeal seeking review of the September 19, 2025 minute order. The court entered judgment on October 10, 2025.7 DISCUSSION

I.

PLAINTIFF FORFEITED HIS ARGUMENTS CHALLENGING THE JUDGMENT Plaintiff makes multiple arguments on appeal. He contends (1) the trial court erred in finding the TAC lacked sufficient allegations of

6

Although plaintiff designated the September 19, 2025 order as part of the record on appeal, he did not designate any of the documents filed in support of or in opposition to any of the demurrers; nor did he designate any of the papers filed in support of or in opposition to his motion for reconsideration of the April 16, 2025 order.

7

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