Sanchez v. Thompson CA2/1

CourtCalifornia Court of Appeal
DecidedNovember 24, 2025
DocketB334619
StatusUnpublished

This text of Sanchez v. Thompson CA2/1 (Sanchez v. Thompson CA2/1) 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
Sanchez v. Thompson CA2/1, (Cal. Ct. App. 2025).

Opinion

Filed 11/24/25 Sanchez v. Thompson CA2/1 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION ONE

CARISSA SANCHEZ et al., B334619

Plaintiffs and Appellants (Los Angeles County Super. Ct. No. BC622709) v.

JAMES P. THOMPSON,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Kristin S. Escalante, Judge. Affirmed. Campbell & Farahani, Frances M. Campbell and Nima Farahani for Plaintiffs and Appellants. No appearance for Defendant and Respondent.

_______________________ Defendant James P. Thompson, as the attorney for Carol Burch, filed three successive unlawful detainer actions seeking to evict plaintiffs and appellants Carissa Sanchez and Ramielyn Milo from the Santa Monica apartment plaintiffs rented from Burch. In the unlawful detainer actions, the complaints filed by Thompson alleged that plaintiffs violated their lease and Santa Monica law by subleasing a portion of the apartment on a short- term basis via Airbnb. All three unlawful detainer actions ended in favor of the tenants, who then filed suit against Thompson and others1 for violating Santa Monica’s tenant harassment ordinance, alleging Thompson sought to evict them despite knowing there was no basis for doing so. Before the trial court, both sides agreed that plaintiffs’ case was equivalent to an action for malicious prosecution, and that Thompson’s liability for violating the ordinance depended on plaintiffs’ proving he lacked probable cause for filing the unlawful detainer actions. After a bench trial on the issue of probable cause, the court entered judgment in favor of Thompson. Although Santa Monica law does not allow tenants to be evicted for illegal use of a property unless they have been convicted of a crime for doing so (see Santa Monica Rent Control Charter Amend., § 1806(a)(6)) (Charter Amendment section 1806), the court determined that an attorney might reasonably conclude that state law preempted Santa Monica law on this issue, and Thompson therefore had probable cause to file suit.

1 The other named defendants were Burch and Burch’s property manager, Miller & Desatnik Management Co., Inc. (Miller & Desatnik). Burch and Miller & Desatnik are not parties to this appeal.

2 Plaintiffs now challenge that conclusion. They argue that Thompson lacked probable cause for seeking to evict them for breaching their lease, and that the trial court erred by finding Thompson had a tenable argument for preemption. In addition, they contend their Airbnb activity at most amounted to a regulatory violation, not an unlawful use of the property sufficient to justify eviction. Finally, they contend the trial court erred by justifying its finding of probable cause in part on another superior court judge’s conclusion that state law preempted Santa Monica’s restriction on evictions for illegal activity. We find plaintiffs’ arguments unpersuasive and affirm. FACTS AND PRIOR PROCEEDINGS A. Trial Court Proceedings On June 9, 2016, plaintiffs filed a complaint alleging that Thompson and Burch violated the Santa Monica tenant harassment ordinance by seeking to evict them from their apartment without justification.2 Thompson filed a special motion to strike the complaint under the anti-SLAPP statute (Code Civ. Proc., § 416.25).3 He argued plaintiffs’ complaint was based on activity protected by the statute, i.e., his filing of the unlawful detainer actions, and that plaintiffs could not show a probability of prevailing on the merits because, among other reasons, the Santa Monica

2 The complaint also alleged retaliation by a landlord in violation of Civil Code section 1942.5 against Burch and Miller & Desatnik. Because those defendants are not party to this appeal, we do not address that portion of the complaint. 3 Unspecified statutory references are to the Code of Civil Procedure.

3 ordinance restricting eviction on the basis of illegal activity was preempted by state landlord-tenant law (§ 1161, subd. (4)). The trial court (Judge Barbara A. Meiers) granted the anti- SLAPP motion. The court agreed with Thompson that state law preempted Santa Monica’s restriction on evictions based on illegal activity because the ordinance imposed an additional procedural barrier to eviction not included in the state unlawful detainer statutes. We reversed. We concluded that “plaintiffs’ complaint sets forth facts stating a cause of action for malicious prosecution, and plaintiffs have demonstrated a probability of prevailing on that cause of action.” (Sanchez v. Thompson (June 12, 2018, B279708) [nonpub. opn.].) Our opinion did not address the issue of preemption. Instead, we reasoned that plaintiffs had “shown a probability of establishing that Thompson lacked probable cause to file the third unlawful detainer action after the court sustained plaintiffs’ demurrer in the first action on the merits and Thompson could not cure the defect by amendment. To the extent Thompson believed the court’s ruling in the first unlawful detainer action was incorrect, his recourse was to appeal the ruling, not file duplicate unlawful detainer actions against plaintiffs, hoping to achieve a different result for his client.” (Ibid.) Furthermore, “[p]laintiffs also made a prima facie showing of malice, sufficient to establish a probability of prevailing on a malicious prosecution claim. A reasonable inference from the evidence is that Thompson filed the third unlawful detainer action knowing it lacked probable cause (after his client’s defeat in the first action) to see if plaintiffs would give up and vacate the apartment, as plaintiffs allege in the complaint—i.e., for an improper purpose.” (Ibid.)

4 After our reversal of the order granting the special motion to strike, proceedings resumed in the trial court, and the case was assigned to Judge Kristin S. Escalante. The parties agreed to bifurcate the case, beginning with a bench trial on the issue of probable cause. If plaintiffs succeeded in showing that Thompson lacked probable cause to bring the unlawful detainer claims, the case would proceed to a jury trial on the remaining issues. B. Bench Trial Findings of Fact In its statement of decision at the conclusion of the bench trial, the court described the facts of the case as follows. Plaintiffs raise no substantial evidence challenge to these factual findings; on appeal they dispute only the legal implications that flow from them. “Ms. Sanchez testified she leased a two-level unit in Santa Monica at 519 Idaho Avenue, Number 4 . . . . Paragraph 14 of the rental agreement provided: ‘Tenant shall not let or sublet all or any part of the premises, or assign this lease or any interest in it without the prior written consent of the [l]andlord. This includes any and all roommate changes.’ “Ms. Sanchez lived in the unit with her roommate plaintiff Ramielyn Milo, who had been approved by the landlord. The top floor contained Ms. Sanchez’s bedroom, the common areas, and kitchen. The downstairs had a separate entrance. It was about the size of a studio apartment and had Ms. Milo’s bedroom and her bathroom. “Ms. Sanchez and Ms. Milo listed the downstairs portion of the apartment on Airbnb. The upstairs portion was not part of the Airbnb rental. Ms. Milo stayed at her boyfriend’s when her portion of the apartment was rented by an Airbnb patron. Ms. Sanchez and Ms. Milo rented out the downstairs portion of the

5 apartment approximately four times, each time for a few days. They did this for about a month prior to October 8, 2015.

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Sanchez v. Thompson CA2/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-v-thompson-ca21-calctapp-2025.