Nguyen v. Hutchins CA4/3

California Court of Appeal·Decided August 14, 2026·No. G065994·Unpublished

Opinion

Filed 8/13/26 Nguyen v. Hutchins 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NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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, G065994

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

01374287)

NICHOLAS A. HUTCHINS, OPINION

Defendant and Respondent.

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 Objection 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 Defendant and Respondent.

Plaintiff Peter Nguyen appeals the judgment entered against him in favor of defendant and respondent Nicholas A. Hutchins after the trial court sustained Hutchins’s demurrer to plaintiff’s operative second amended complaint (SAC) without leave to amend.1 Plaintiff failed to designate key documents necessary to our review of the trial court’s order sustaining respondent’s 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 SAC in the light most favorable to plaintiff and find no error on the face of the order sustaining Hutchins’s 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

While this case was pending, plaintiff filed another action in the Orange County Superior Court against the same defendants arising from the same set of alleged facts. (Nguyen v. Cramer, Orange County Superior Court case No. 30-2024-01381650.) Plaintiff’s appeal from a judgment entered against plaintiff in that case is also pending before us (case No. G065995). 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 refers to as a “forcible entry.”

Plaintiff filed his initial complaint in this action on January 24, 2024, and his SAC on August 12, 2024.3 Plaintiff’s SAC sought an award of damages against the City and multiple City employees based on allegations concerning both the original inspection and the later inspection conducted pursuant to the warrant. The individual defendants include respondent Hutchins (who was the Deputy City Attorney), Avila, code enforcement officers Rita Cramer and Jake Tran, chief building official David Dent, and city manager Lisa L. Kim. Among other things, plaintiff alleged defendants caused damage to portions of his property during the second inspection, the inspection warrant was deficient, defendants caused plaintiff and members of his family to stand outside in the rain during the second inspection and to suffer distress, and defendants exceeded the permissible scope of both inspections.

On March 28, 2025, before Hutchins was served and appeared in the action, the trial court sustained a demurrer to the SAC by all the other defendants without leave to amend. The court determined (1) plaintiff failed

2

Plaintiff alleges one of the defendants, code enforcement supervisor Rafael Avila, told him the warrant was obtained based on a third party’s complaint about plaintiff’s property.

3

The SAC is titled “Amended Complaint [for] Trespass to Land[;]

Intrusion Upon Seclusion[;] Wrongful Use of Civil Proceeding[;] Abuse of Process[;] Intentional Misrepresentation[;] Malicious Prosecution[;] Intentional Infliction of Emotional Distress [IIED;] Eggshell Skull Rule[; and] Vicarious Liability.” (Boldface and some capitalization omitted.) Plaintiff did not include his first amended complaint as part of the record on appeal, but the docket indicates it was filed on August 8, 2024, four days before plaintiff filed the SAC.

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 precludes defendants from invoking the Tort Claims Act; (3) plaintiff failed to allege any statutory basis for direct liability against the City; and (4) despite having had prior opportunities to cure the defects, plaintiff failed to do so.4 On September 19, 2025, after Hutchins was brought into the action, the trial court entered an order sustaining his demurrer to the SAC without leave to amend on the same grounds set forth in its March 28, 2025 minute order with respect to the other defendants. The court noted that plaintiff’s opposing papers did not address the issue of Hutchins’s immunity. In that same order, the court denied plaintiff’s motion for reconsideration of an order it had entered April 16, 2025, 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 Defendant Hutchins and (2) the court set an Order to Show [Cause re] Sanctions for failure to serve and prosecute Defendant Hutchins.”5

4

The court’s March 28, 2025 order indicated that, although the court had previously sustained demurrers on the grounds that plaintiff had failed to comply with the Tort Claims Act and Hutchins and Dent were entitled to absolute immunity, the allegations in plaintiff’s SAC 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.

5

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 the demurrer; 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. We previously granted respondent’s motion to augment the record to include the March 28, 2025 order, the request for

Plaintiff filed a notice of appeal seeking review of the September 19, 2025 minute order. Judgment was entered on October 10, 2025.6 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 SAC lacked sufficient allegations of equitable estoppel as to plaintiff’s failure to comply with the Tort Claims Act; (2) respondent is not immune from federal constitutional violations; (3) the court abused its discretion by denying leave to amend and denying the motion for reconsideration; and (4) the trial court violated plaintiff’s due process and first amendment rights by “cutting him off during hearings, disregarding the record, and entering Respondents’ proposed judgments—

judicial notice filed in support of the demurrer, and the April 16, 2025 order, but the appellate record is still lacking the demurrer itself, briefing on the demurrer, and the papers filed in connection with the motion for reconsideration.

6

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