People v. PKS, INC.

26 Cal. App. 4th 400, 31 Cal. Rptr. 2d 543, 94 Cal. Daily Op. Serv. 5070, 1994 Cal. App. LEXIS 679
CourtCalifornia Court of Appeal
DecidedJune 29, 1994
DocketA061437
StatusPublished
Cited by2 cases

This text of 26 Cal. App. 4th 400 (People v. PKS, INC.) 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
People v. PKS, INC., 26 Cal. App. 4th 400, 31 Cal. Rptr. 2d 543, 94 Cal. Daily Op. Serv. 5070, 1994 Cal. App. LEXIS 679 (Cal. Ct. App. 1994).

Opinions

Opinion

ANDERSON, P. J.

— On October 3, 1991, the San Francisco District Attorney, acting on behalf of the People of the State of California (appellant), filed a civil action against PKS, Inc. The complaint sought injunctive relief, restitution of moneys paid and civil penalties from PKS, based on certain alleged unfair business practices: (a) charging more for the recovery of towed vehicles than allowed by Vehicle Code1 sections 21100, subdivision (g), and 22658, subdivision (i), and San Francisco Traffic Code2 section 172.04; (b) towing parked vehicles from private property without the request or authorization of the property owner to tow each specific vehicle in violation of section 22658, subdivisions (a) and (f), and section 10851; and (c) towing parked vehicles from private property held open to the public for parking at no fee within one hour of the time the vehicles were parked in violation of section 22953, subdivision (a). The complaint was later amended to assert the same claims against Peter Koehler, president of PKS, Inc., on “alter ego” grounds.

[403]*403Following a court trial, judgment was entered against appellant and in favor of PKS, Inc., and Peter Koehler (respondents). Appellant seeks reversal of that judgment. We affirm.

I. Procedural History

A. Summary of Appellant’s Case

As developed through extensive pretrial briefing, argument, and evidence introduced at trial, appellant attempted to demonstrate that respondents engaged in three practices which were allegedly barred under the state and local statutes set forth in the introduction to this opinion. Appellant’s first claim was that respondents violated Traffic Code section 172.043 by charging $100 per tow for vehicles towed from private property. Per appellant, it was illegal for respondents to charge more than $80 per (private) tow because the agreement between the San Francisco Police Department and the towing company with which the police had contracted set a fee of $80.4

Appellant next charged that respondents had violated the provisions of section 22658, subdivision (a), by engaging in “patrol towing.” Per appellant, respondents traveled a prescribed circuit of lots owned by private businesses with which respondents had contractual arrangements and towed cars from those lots without securing prior approval from the lot owners for each individual tow. Third, appellant charged that respondents engaged in a practice of “quick towing” — removing vehicles from lots which provide free parking to the public less than one hour after the vehicles had been parked.

B. Decision of the Trial Court

Pursuant to appellant’s request, the trial court issued a statement of decision. On the claim that respondents charged excessive fees for towing under Traffic Code section 172.04, the court found that the Legislature had preempted the field where the issue of excessive charges by towing companies is concerned. The court determined that the enactment of section 22658, [404]*404subdivisions (i) and (j)5 precluded San Francisco’s enactment of a statute which attempted to set a standard fee or a maximum fee, employing a formula different from the one established by the Legislature. Moreover, the court noted that the provisions of section 21100, subdivision (g), which permit local authorities to license and regulate tow truck services and drivers, enable those authorities to regulate only those entities whose principal place of business or employment is within their jurisdiction. The court found that respondents’ principal place of business and employment was in San Mateo County (South San Francisco). Thus, reasoned the court, San Francisco was not expressly authorized to regulate respondents under section 21100, subdivision (g).

As to “patrol towing,” the court found that appellant failed to prove that respondents violated the provisions of section 22658, subdivision (a) or (f). The court found that appellant failed to introduce any competent evidence that respondents towed vehicles without the permission of the private property owners from whose lots the vehicles were towed. Moreover, the court determined that the 1991 enactment of subdivision (Z) of section 22658 (effective Jan. 1, 1992)6 reflected a change in existing law and that prior to January 1, 1992, a towing company was not required to obtain specific authorization for each tow.

As to appellant’s “quick tow” claim, the court determined that appellant failed to prove that respondents towed vehicles in violation of section 22953, subdivision (a). The court also determined that section 22658, subdivision (f) provided immunity for tows (including “quick tows”) requested by a property owner.7

[405]*405H. Arguments and Standards for Review

A. Contentions on Appeal

Appellant first argues that the trial court erred in determining that section 22658, subdivision (i), has the effect of invalidating Traffic Code section 172.04. Appellant goes on to argue that section 21100, subdivision (g),8 constitutes legislative authorization for enactment of local legislation dealing with towing charges from private lots and that the trial court erred in determining that respondents’ principal place of business and employment was in San Mateo County, thus precluding San Francisco’s regulation of respondents’ business.

Appellant next contends that the trial court erred in determining that respondents’ “patrol towing” did not violate the provisions of section 22658 because (per appellant) the statute clearly requires that each tow be authorized/initiated by an individual lot owner. Finally, appellant contends with reference to the “quick tow” issue that the trial court erred in determining that towing companies, as agents of lot owners, are beyond the reach of section 22953, subdivision (a) — at least where injunctive relief is concerned.

B. Standards for Review

Appellant asserts that the issues raised on appeal involve questions of law (only) and that, consequently, this court should examine the trial court’s determination “de nova.” In our view, appellant mischaracterizes certain of the trial court’s determinations. Where the trial court relied on matters of law, we review its determinations de nova. (Goddard v. South Bay Union High School Dist. (1978) 79 Cal.App.3d 98, 105 [144 Cal.Rptr. 701].) However, where its determinations were factual, we apply a “substantial evidence” test. (Crawford v. Southern Pacific Co. (1935) 3 Cal.2d 427, 429 [45 P.2d 183].)

[406]*406HI. Analysis

A. The Question of What Constitutes an “Excessive” Charge for Private Tows Has Been Determined by the Legislature

“The people of California have made a limited delegation of the police power to cities. It is found in the state’s Constitution, article XI, section 7, which declares: ‘A . . . city may make and enforce within its limits all local, police, sanitary, and other ordinances and regulations not in conflict with general laws.’ ” (City of Lafayette v.

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Related

California Tow Truck Ass'n v. City & County of San Francisco
225 Cal. App. 4th 846 (California Court of Appeal, 2014)
People v. PKS, INC.
26 Cal. App. 4th 400 (California Court of Appeal, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
26 Cal. App. 4th 400, 31 Cal. Rptr. 2d 543, 94 Cal. Daily Op. Serv. 5070, 1994 Cal. App. LEXIS 679, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-pks-inc-calctapp-1994.