Watson v. Noda CA4

CourtCalifornia Court of Appeal
DecidedJune 12, 2026
DocketD087163
StatusUnpublished

This text of Watson v. Noda CA4 (Watson v. Noda CA4) 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
Watson v. Noda CA4, (Cal. Ct. App. 2026).

Opinion

Filed 6/12/26 Watson v. Noda CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

JOSEPH C. WATSON, D087163

Plaintiff and Appellant,

v. (Super. Ct. No. CIVDS2019209)

RAYMOND NODA et al.,

Defendants and Respondents.

APPEAL from an order of the Superior Court of San Bernardino County, Donald R. Alvarez, Judge. Reversed and remanded with instructions. Kassouni Law and Timothy V. Kassouni for Plaintiff and Appellant. Gordon Rees Scully Mansukhani, Matthew G. Kleiner, Tara N. Swanson, and John P. Cogger for Defendant and Respondent Raymond Noda. Kulik Gottesman Siegel & Ware and Gerard R. Kilroy for Defendant and Respondent Nicole Natalie Sams as Trustee of the Pickett Family Trust. I. INTRODUCTION Joseph C. Watson appeals from the trial court’s order granting anti- SLAPP motions filed by Raymond Noda, and by Nicole Natalie Sams as Trustee of the Pickett Family Trust (Sams). We find the trial court should have denied Sams’s motion as untimely because 60-day statutory timeline to file the motion expired years earlier against her predecessor in this action, and Sams’s substitution as a successor in interest did not revive that deadline or give the trial court discretion to hear the untimely motion. We further find that the trial court should have denied Noda’s motion because the conduct underlying the challenged causes of action concerned a 13-member homeowners association (HOA) and therefore, in this case, did not involve a “public issue” or “issue of public interest.” We reverse and remand with instructions. II. BACKGROUND A. Litigation Between the Parties Montara Estates, Inc., (Montara) is an HOA that governs a 36-lot, common interest development in San Bernardino County. Lot owners have a membership interest in Montara, and each lot is entitled to one vote in association matters. During the relevant time, there were 13 owners of the

lots within Montara.1 Watson owned 15 lots, Nathaniel Pickett owned six lots, and Noda owned three lots. Between approximately 2007 and 2018, Watson served on Montara’s board of directors and was Montara’s attorney. In 2016, Watson filed a lawsuit on behalf of Montara alleging that Pickett failed to pay association assessments (case No. CIVDS1611475). This started a 10-year period during which several HOA members filed lawsuits and counter-lawsuits against each other. In 2018, Pickett sued Montara, Watson, and another association

1 During oral argument, there was disagreement about the number of lot owners. However, an uncontradicted declaration from Watson reflects there were 13 owners. Noda also acknowledged in his reply brief that Montara was “comprised of 13 different lot owners.”

2 member named Patty Biggerstaff for breach of contract, breach of fiduciary duty, and conversion (case No. CIVDS1818100). Pickett alleged that the association paid various amounts to Watson and Biggerstaff without following the proper procedures to approve those payments. Pickett also alleged that Montara did not properly authorize the lawsuit against Pickett or the collection and increase of association assessments. Watson responded with a cross-complaint against Pickett, Noda, and Diego Seglin, another association member. Two years later, on September 14, 2020, Watson initiated the current case (case No. CIVDS2019209). In his first amended complaint (FAC) filed on September 22, 2020, Watson named Noda, Pickett, and Seglin as defendants. The FAC contains four causes of action: (1) violations of the Davis Sterling Act, (2) defamation, (3) breach of fiduciary duty, and (4) intentional infliction of emotional distress (IIED). In the first and third causes of action, Watson challenged various actions that Noda, Pickett, and Seglin took as Montara board members following their election in 2018. As for his defamation and IIED claims, Watson alleged that the defendants made “numerous false statements both orally and in writing to the effect that . . . Watson was ‘going to jail,’ ‘going to jail for stealing money from [Montara],’ ‘stealing money from [Montara],’ ‘was misusing [Montara] funds,’ and ‘was making vital decisions regarding [Montara] without consulting other members of the HOA.’ ” These statements were allegedly made to “other owners and tenants in the [Montara] complex,” in an attempt “to bully, harass, and intimidate [Watson] and [Montara] members in to not pursing collections against Defendants.” On August 4, 2021, Montara sued Watson in yet another case (case No. CIVSB2122422), alleging several causes of action stemming from

3 Watson’s service on Montara’s board. On October 12, 2021, Watson cross- complained. In his first amended cross-complaint (FACC) filed weeks later, Watson asserted various causes of action, including defamation and IIED against Noda and Sams based on substantially similar allegations as the FAC. The trial court consolidated case numbers CIVSB2122422 and CIVDS2019209. In 2022, the two earlier cases (case Nos. CIVDS1611475 and CIVDS1818100) were dismissed in connection with a settlement. Later that year, Pickett filed a motion for judgment on the pleadings in the current case asserting that the first and third causes of action in FAC were barred because those matters had been adjudicated in case numbers CIVDS1611475 and CIVDS1818100. The trial court granted the motion as the first cause of action with leave to amend and denied it as to third cause of action. On March 8, 2023, Watson filed a second amended complaint (SAC). The defamation and IIED allegations remained the same, while Watson revised the dates for the alleged violations of the Davis Sterling Act and breach of fiduciary duties. Pickett died on February 28, 2023. On September 12, 2023, the trial court granted Watson’s motion to substitute Sams as Pickett’s successor in interest. B. Anti-SLAPP Motions On March 14, 2023, Noda filed an anti-SLAPP motion seeking to strike the defamation and IIED causes of action in the FACC. Sams then filed her anti-SLAPP motion on October 17, 2023, seeking to strike the defamation and IIED causes of action in the SAC. Watson opposed the motions, arguing they were untimely and lacked merit. In his supporting declarations, Watson stated that Pickett began

4 making his allegedly defamatory statements around 2015 and 2016 when Watson pursued Pickett for unpaid association assessments. Watson declared that Noda’s allegedly defamatory statements started in 2018 when Watson insisted that Noda pay a special assessment that Noda voted against. Watson also filed declarations from one association member and one tenant stating they heard the challenged statements, and one declaration from a friend describing Watson’s reaction to the statements. The trial court granted both motions, finding that “the defamation and IIED causes of action arose from protected speech and Watson fail[ed] to meet his burden of demonstrating a probability of prevailing as the litigation privilege applies.” Watson timely appealed. III. DISCUSSION Watson argues the trial court should have denied both anti-SLAPP motions as untimely. He further contends the trial court erred in both prongs of the two-pronged anti-SLAPP analysis. We find Sams’s motion untimely. Noda’s motion was timely, but the trial court erred in finding that the anti- SLAPP statute protected Noda’s conduct underlying the defamation and IIED causes of action. We therefore reverse. A.

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Watson v. Noda CA4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watson-v-noda-ca4-calctapp-2026.