Grace v. Mansourian CA4/3
240 Cal. App. 4th 523, 192 Cal. Rptr. 3d 551, 2015 Cal. App. LEXIS 815 (2015)
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Rule of Law:
A party who denies a request for admission lacks a 'reasonable ground to believe they would prevail' under Code of Civil Procedure § 2033.420 if their denial is based on a subjective, uncorroborated belief that is contradicted by substantial, available evidence, thereby making them liable for the costs of proof.
Facts:
- Levik Mansourian drove a car into an intersection and collided with a vehicle driven by Timothy Grace.
- Mansourian told the traffic collision investigator that he believed the traffic light was yellow when he entered the intersection.
- An eyewitness, Kathryn Napoli, told the investigator that Mansourian had run a red light.
- A few weeks later, Napoli reiterated in a recorded interview with Mansourian's insurance company that he had run the red light.
- As a result of the accident, Grace suffered injuries, including a fractured ankle in two places which required surgery, as well as injuries to his back and neck.
- Defendants retained a medical expert, Dr. Robert Baird, who examined Grace and concluded that the ankle fracture and subsequent surgery were necessary and caused by the accident.
- Dr. Baird disagreed that Grace's back and neck pain or his back surgery were caused by the accident.
Procedural Posture:
- Timothy Grace and Michelle Blair (plaintiffs) filed a personal injury lawsuit against Levik Mansourian and Satina Mansourian (defendants) in a state trial court.
- During discovery, plaintiffs served requests for admission on defendants regarding liability, causation, and damages, which defendants denied.
- Following a trial, a jury found defendant Levik Mansourian negligent and awarded plaintiffs a total of over $440,000 in damages.
- Plaintiffs then filed a motion in the trial court to recover their costs of proof, arguing defendants had no reasonable basis for their prior denials.
- The trial court denied the plaintiffs' motion for costs of proof.
- Plaintiffs (appellants) appealed the trial court's order denying the motion to the California Court of Appeal.
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Issue:
Does a party's sincerely held but uncorroborated belief that they would prevail at trial, when contradicted by substantial evidence, constitute a 'reasonable ground' to deny requests for admission under Code of Civil Procedure section 2033.420, thereby precluding an award for costs of proof?
Opinions:
Majority - Thompson, J.
No. A party's subjective belief is insufficient to justify a denial of requests for admission if that belief is objectively unreasonable in light of substantial contrary evidence. The court reasoned that the standard under § 2033.420 is not whether the party subjectively believed they were correct, but whether they had a 'reasonable ground' to believe they would prevail at trial. A party has a duty to make a reasonable investigation before denying requests. Here, Mansourian's belief that the light was yellow was overwhelmed by contrary evidence, including an eyewitness, the police report, and an accident reconstruction expert, with no evidence corroborating his position. Thus, his denial regarding liability was unreasonable. Similarly, because defendants' own expert confirmed the ankle injury and the necessity of its treatment, it was unreasonable to deny those specific requests regarding causation and damages. However, it was reasonable to deny causation for the neck and back injuries, as their expert's opinion provided a good faith basis for that dispute.
Analysis:
This case clarifies that the 'reasonable ground' standard for denying requests for admission under § 2033.420 is an objective one, not subjective. It establishes that a party cannot avoid costs of proof by relying on a personal belief when faced with a significant amount of contradictory evidence. The ruling reinforces the discovery statute's purpose of streamlining litigation by compelling parties to admit facts not genuinely in dispute. Future litigants are now on notice that they must conduct a reasonable investigation and cannot use a denial as a strategic tool to force an opponent to prove an obvious truth without risking financial sanctions.
