HomeMy WebLinkAbout21CV-0734 - Tentative Ruling on DemurrerFILED
JUL 072022
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LUIS BISPO SUPERIOR COURTtau ~
NHC SLO,LLC v.City ofSan Luis Obispo,et aL,21CV-0734 ’”am”°'°°""°"'”99“”C'e
Hearing:Demurrer
Date:July 7,2022
TENTATIVE RULlNG
Background
In January 2019,Petitioner NHC SLO,LLC (Petitioner)applied for a cannabis operator permit
by filing a Commercial Cannabis Business Operators Permit Application (the'Application)with~
Respondent City of San Luis Obispo (the City).(Request for Judicial Notice [RFJN],Ex.3.)
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At that time,Helios Dayspring (Dayspring)was Petitioner’s chief executive officer and
managing member and signed a declaration on its behalf for theissuance of the permit.(Id.at
Ex.3,p.0035.)
On October 22,2019,Respondents grantedthe issuance of a permit,subject to Petitioner’s
compliance with the applicable Municipal Code provisions.
On October 20,2020,Dayspring transferred his interest in Petitioner to Valnette Garcia.(Pet,11
20,and Ex.F.at NHCSL0000046.)
On or around July 28,2021,Dayspring entered into a plea agreement with the United States
Attorney for the Central District of California.(Pet,Ex.H,at NHCSL0000078-000107.)
Dayspring pleaded guilty to bribing an elected San Luis Obispo County Supervisor from 2016 to
2019,and attempting to bribe a San Luis Obispo County mayor,as well as violations of the
federal tax code.(Pet,Ex.H,NHCSL000089-97.)2 -
On October 6,2021,Respondents terminated the permit,and issued a notice of automatic
disqualification to Petitioner.(Pet,Ex.E.)The reason cited for this action was Petitioner’s
submission of false or misleading information in obtaining and maintaining the permit.The
revelations in Dayspring’s plea agreement,in Respondents’View,rendered certain
representations made by Petitioner in the AppliCation false and misleading.
0n October 19,2021,the City issued is final memorandum Of-decision,reaffirming the
automatic disqualification of Petitioner.(Pet,Ex.H.)
On December 23,2021,Petitioner filed this lawsuit asserting one cause of action for “writ of
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mandate,prohibition,and declaratory relief.”
Respondents’request for judicial notice is granted.(Evid.Code,§452,subds.(b)-(d).)
The Court notes that a federal court accepting a guilty plea is required to “determine that
there is a factual basis for the plea.”(F ed;R.Crim.Proc.,rule 11,subd.(b)(3).)
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Now before the Court is Respondents’demurrer to the petition.Respondents demur on the basis
that the first cause of action is barred as a matter of law because it fails to state facts sufficient to
constitute a cause of action.(Code Civ.Proc.,§430.10,subd.(0).)
Legal Authorig
Mandamus proceedings are subject to the general rules of pleading applicable to civil
actions.(Chapman v.Superior Court (2005)130 Cal.App.4th 261,271.)A demurrer tests the
legal sufficiency of the allegations in a complaint.It raises issues of law,not fact,regarding the
complaint’s form or content.(Code Civ.Proc.,§§422.10,589;Donabedian v.Mercwjy Ins.C0.
2004)116 Cal.App.4th 968,994;Lewis v.Safeway (2015)235 Cal.App.4th 385,388.)A
demurrer “admits the truth of all material factual allegations in the complaint the question of
plaintiff’s ability to prove these allegations,or the possible difficulty in making such proof,does
not concern the reviewing court.”(Alcorn v.Anbro Engineering,Inc.(1970)2 Cal.3d 493,496.)
To survive a demurrer,the complaint need only allege facts sufficient to state a cause of action;
each evidentiary fact that might eventually form part of the plaintiff’s proof need not be alleged.”
CA.v.William S.Hart Union High School Dist.(2012)53 Cal.4th 861,872.)
With this action,Petitioner challenges the City’s automatic disqualification of Petitioner’s
permit.The standard of review in ordinary mandamus is highly deferential.(See Carrancho v.
Cal.Air Res.Bd.(2003)111 Cal.App.4th 1255,1265 [“Mandamus may issue to correct the
exercise of discretionary legislative power,but only if the action taken is so palpably
unreasonable and arbitrary as to show an abuse of discretion as a matter of law.This is a highly
deferential test.”].)'‘
Petitioner’s challenge involves the interpretation of the MuniCipal Code,and the City is
entitled to deference in its interpretation of its municipal code.(See,e.g.,Communities for a
Better Envt.v.State Water Resources Control Bd.(2003)109 Cal.App.4th 1089,1107 [Courts
extend considerable deference to an administrative agency’s interpretation of ...the regulatory
scheme which the agency implements or enforces.”].)
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Discussion
The Municipal Code
San Luis Obispo Municipal Code section 9.10.070(C)3 provides for automatic disqualification of
an applicant if the applicant “made-one or more false or misleading statements or omissions'in
the application proceSs‘.”(Pet.Ex.E at NHCSL0000039,citing Mun.Code,§9.10.070(C);see ,
also RFJN Ex.1.)In signing the Cannabis Permit Application,Dayspring (on Petitioner’s J
behalf)acknowledged the following statement:“Applicants providingfalse 0r misleading
information in the permitting process will result in the rejection of the application and/or
3 All statutory references are to the San Luis Obispo Municipal Code unless otherwise noted.
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nullification of any issued permit.”(RFJN,Ex.3,p.0035,emphasis in original.)
In signing the cannabis background check questionnaire,Dayspring acknowledged:
I acknowledge that by signing the documents contained in this Background
Package,that all information that I have provided is true and correct.I acknowledge
that any information omitted,not disclosed,or found to be false is subject to
disqualification for a Cannabis Business Operator Permit.
RPJN,Ex.5,p.2.)
Respondents argue that because the permit was never active,Petitioner has no operative permit
and can still be disqualified from obtaining the permit under Section 9.10.070(c).ReSpondents
rely on the general law of vested rights,which provides protection once a business has obtained
necessary land use entitlements and begins to operate.(Avco Community Developers,Inc.v.
South Coast Regional Com.(1976)l7 Cal.3d 785,797.)
Respondents argue that the permit provided to Petitioner was merely one step in the process to
operate a cannabis facility in the City,noting that an aspiring operator must also obtain a
conditional use permit and other approvals from the City.(RFJN,Ex.2,§17.86.080(E)(1)(a).)
Respondents note that the Municipal Code further states that licensure creates no vested right:
No person shall have any entitlement or vested right to operate a cannabis business
solely by virtue of licensing under these regulations.Operation of cannabis
activity(ies)requires both the approval of a conditional use permit and a r
commercial cannabis operator permit under Chapter 9.10,which is a revocable
privilege and not a right in the city.The applicant bears the burden of proving that
all qualifications for licensure have been satisfied and continuously maintained
prior to conducting a cannabis business at an otherwise allowed location within the ,
city.'
RJN Ex.2,§17.86.080(E)(2).)
In opposition,Petitioner argues that Section 9.10.070,“applies to Cannabis applications by its
express terms,”not permits.(Opp.,p.8,1.19.)
Section 9.10.070(C)states in relevant part:
Grounds for Automatic Disqualification.In addition to any other reason that may
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be established by the city council as a basis for disqualification,an applicant shall
be disqualified from applying for,or obtaining,a commercial cannabis operator
permit if:
4.The applicant made one or more false 0r misleading statements or omissions in
the application process.(Emphasis added.)
Petitioner argues that Section 9.10.070 provides for the disqualification of an applicant applying
for a permit or obtaining a permit.According to Petitioner,where a permit already has been
issued,the City must follow another provision of the Municipal Code,entitled “suspension or
revocation of permit,”which provides as follows:
In addition to any,other penalty authorized by law,a commercial cannabis
operator permit may be suspended or revoked if the cityfinds,after notice to the
permittee and opportunity to be heard,that the permittee or his or her agents or
employees have violated any condition of the permit imposed pursuant to,or any
provision of,this chapter.
A.Upon a finding by the city of a first permit violation within any five~year period,
the perrnit shall be suspended for thirty days.
B.Upon a finding by the city of a second permit Violation within any five—year
period,the permit shall be suspended for ninety days.
C.Upon a finding by the city of a third permit violation within any five—year
period,the permit shall be revoked.
Mun.Code,§9.10.090 (emphasis added).)
Petitioner argues that its claim survives demurrer because it was not provided notice and an
opportunity to be heard.
Respondents’position is that Petitioner’s permit was not “active,”relying on section
9.10.070(d):
Each commercial cannabis operator permit issued pursuant to this chapter shall
expire twelve months after the date of its activation.The perrnittee may apply for
renewal prior to expiration in accordance with this chapter.Each commercial
cannabis operator permit must be activated within twelve months of issuance.
The permit is activated by the issuance ofa use permit for the commercial cannabis
activity pursuant to Section 17.86.080,together with all other applicable city
permits and state licenses,and the commercial cannabis operator thereafter opening
and continuously operating the commercial cannabis activity.Failure to timely
activate the permit shall be deemed abandonment of the permit and the permit shall
automatically lapse.(Emphasis added.)
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Respondents argue that Petitioner did not comply with this Section,and thus the permit was not
active.”Respondents argue that until the permit is legally active,and the applicant proceeds
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through each step of that application process,the applicant remains an “applicant”with no
operative permit,and thus may still be disqualified from obtaining the permit under Section
9.10.070(c).)
Respondent’s interpretation of Section 9.10.070(c)is consistent with other provisions in the
Code,which as a whole provide for a multi-step process in commencing a commercial cannabis
operation.The approval of the operator permit is a precursor to the application for a use permit
under section 17.86.080,which provides that “[a]ny permit authorizing commercial cannabis
activity pursuant to this chapter shall be conditioned upon the holder obtaining and maintaining a
city commercial cannabis operator permit and the appropriate state license for the activity.”
Mun.Code,§17.86.080(E).)As discussed above,the same provision makes it clear that the
issuance of a permit does not create a vested right to operate a cannabis business.Moreover,the
requirement that the operator activate its permit within a specific period indicates that until the
permit is activated,it is a conditional permit,and may be revoked.Construing the Municipal
Code provisions as a whole,it is only after the operator permit,the use permit,and other required
licenses and permits are obtained that the provision in Section 9.10.090 governing suspension or
revocation comes into play.
The Parties’Agreement
Respondents argue that,in the Application,Petitioner contractually agreed that any false or
misleading representation or omission would result in disqualification and revocation of the
permit,and waived any inconsistent rights in the Municipal Code:“Applicants providing false
0r misleading information in the permitting process will result in rejection 0f the application
and/0r nullification or revocation 0f any issued permit.”(RFIN,Ex.3,p.0035,emphasis in
original.)
Respondents argue this provision evidences the City’s interpretation of its own ordinance,as
well as Petitioner’s acknowledgment and agreement with this interpretation,and its independent
contractual agreement and waiver of any broader rights provided in the Municipal Code..
Petitioner does not address this argument in its opposition.
The Court need not rule on the merits of this argument,but notes that the statement in the
Application is consistent with the Court’s interpretation of the Municipal Code provisions as a
whole,as outlined above.
Unclean Hands
Respondents argue that Petitioner only received a permit at all because of fraud,and that equity
should not allow Petitioner to profit from its fraud.
Although mandamus is “generally classed as a legal remedy,the question of .
whether it should be applied is largely controlled by equitable considerations.”
Dowell v.Superior Court,47 Cal.2d 483,487.)It has therefore been held that the
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writ should nOt issue in aid of one who does not come into court with clean hands
Wallace v.Board ofEducation,63 Ca1.App.2d 61 1,617),or “Where the conduct
of the party applying for the writ has been such as to render it inequitable to grant
him relief ...”(Bashore v.Superior Court,152 Cal.1,4.)
San Diego County Dept.of Pub.Welfare v.Superior Court (1972)7 Cal.3d 1,9.)
As the Court previously ruled in denying Petitioner’s application for a temporary restraining
order:
Petitioner fails to show a likelihood of success on the merits sufficient to warrant
temporary relief.Mr.Dayspring personally signed Petitioner’s application for a
cannabis op crator’s permit under penalty of perjury,and made other representations
during the permitting process.Respondents have presented persuasive evidence to
show that Mr.Dayspring made material misrepresentations in the application
process that adversely impacted the approval of the permit.Such acts violate the
San Luis Obispo City Municipal Code.The fact that Mr.Dayspring is no longer a
member or owner of Petitioner is of no moment,given that his statements formed
the basis of the approval.
Ruling,Feb.1,2022,p.3,11.17-25.)
Petitioner does not address this argument in its opposition and does not dispute‘that Dayspring
acted with unclean hands in securing the permit;The demurrer is sustained on this ground.
Mootness
Independent of Respondents’other arguments,ReSpondent also argues that the relief requested
in the petition is moot,because the permit at issue expired by operation of law on October 22,
2021.
As set forth above,Section 9.10.070(D)provides that,where a cannabis permit is not activated
within l2 months,it will terminate.Through three separate resolutions,the City granted
Petitioner a total of one additional year to activate its permit.(RFJN,Exs.7,8,9.)Petitioner’s
permit was issued October 22,2019.Because it was not activated by October 22,2021,the two-
year deadline,it was “deemed‘abandoned”under Section 9.10.070(D).
Petitioner does not address this argument in its opposition.Petitioner does not dispute that the
permit has been deemed abandoned and thus
any
requested relief1n the petition is moot.The
demurrer on this ground1s sustained.
Evidentiafl Objections
Respondents’evidentiary obj ectionvto the declaration of Helios Dayspringiis sustained and the
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declaration is disregarded in its entirety.The declaration is not signed under penalty of perjury,
and the Court is unable to consider it.(See Code Civ.Proc.,§2015.5;Kulshrestha v.First
Union Commercial Corp.(2004)33 Ca1.4th'601,610-611.)Even if the Court could consider the
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declaration,it is full of Speculation and averments not properly before the Court on demurrer.
Petitioner’s Sur-Reply
The Court is in receipt of a document filed on July 6,2022,entitled “Objection to New
Arguments.”Despite its caption,the document essentially asserts new argument and evidence in
support of Petitioner’s opposition.The document contains argument that could have been made
in opposition to the demurrer.The Court construes the document as a sur-reply and orders it
stricken as thereis no basis for the filing of such a document,and the Court did not grant leave to
Petitioner to file the document.v
okDERs (TENTATIVE)
l)The demurreris sustained with leave to amend.Petitioner shall file an amended
complaint on or before July 18,2022.(Cal.Rules of Court,rule 3.1320,subd (g).)
2)Petitioner’s “Objection t0 New Arguments,”filed July 6,2022,is stricken.