BROWN vs SPRATLEY, et al.

24CV024859: BROWN vs SPRATLEY, et al. 06/08/2026 Hearing on Motion for Leave to File a Cross-Complaint in Department 8C

Tentative Ruling

NOTICE:

PLEASE TAKE NOTICE that any oral arguments regarding this tentative ruling will be heard at 1:30 p.m. in Department 8C in the Tani G. Cantil-Sakauye Courthouse at 500 G Street, Sacramento, CA, the Hon. Richard C. Miadich presiding.

Any party who wishes to contest the tentative ruling below must:

(1) request a hearing by calling the Law and Motion Oral Argument Request Line at (916) 874-2615, by 4:00 p.m. the Court day before the noticed hearing date, and leave a voicemail message (a) identifying themselves as the party requesting oral argument; (b) indicating the specific matter/motion for which they are requesting oral argument; and (c) confirming that they have notified the opposing party of their intention to appear; and

(2) advise the opposing party of the location and time of hearing pursuant to Local Rule 1.06.

If a hearing is not requested by 4:00 p.m. on the Court day before the noticed hearing date, the tentative ruling will become the final order of the Court.

If a hearing is requested, the Court prefers in-person attendance by the parties. However, parties may appear by Zoom unless the Court specifically orders in-person attendance. Parties choosing to appear by Zoom are reminded, however, that a Zoom appearance is still a formal appearance before the Court. Parties appearing via Zoom should do so from a quiet location, free from undue distractions, and wear attire suitable for an in-person court appearance.

The parties may join the Zoom session for hearing on the tentative ruling by audio and/or video through the following link:

https://saccourt-ca-gov.zoomgov.com/j/16039062174

SIP Address:

16039062174@sip.zoomgov.com

(833) 568-8864

ID: 16039062174

24CV024859: BROWN vs SPRATLEY, et al. 06/08/2026 Hearing on Motion for Leave to File a Cross-Complaint in Department 8C

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.Pdf

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will be forward the form to the Court Reporter’s Office and an official reporter will be provided.

TENTATIVE RULING

***NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G STREET SACRAMENTO, CA. ALL MOTIONS NOTICED FOR DEPARTMENT 28 WILL BE HEARD IN DEPARTMENT 8C OF THE NEW COURTHOUSE. ALL PAPERS FOR THIS DEPARTMENT MUST BE FILED AT THIS NEW LOCATION AND WILL NOT BE ACCEPTED AT THE HALL OF JUSTICE. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION***

Defendants Jason Spratley and Xochil Spratley’s (collectively, “Defendants”) motion for leave to file a cross-complaint is UNOPPOSED and GRANTED.

Plaintiff Latasha Brown (“Plaintiff”) filed this quiet title action on December 6, 2024. On March 7, 2025, Defendant Jason Spratley, proceeding in pro per, filed an Answer. On July 17, 2025, in its ruling on Defendants’ motion for leave to file an amended answer, the Court acknowledged that Plaintiff had stipulated to permitting Defendants to file an amended answer. Thus, on July 22, 2025, Defendant Jason Spratley filed the First Amended Answer, and Defendant Xochil Spratley filed her initial Answer. At that time, Defendants remained unrepresented. On August

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV024859: BROWN vs SPRATLEY, et al. 06/08/2026 Hearing on Motion for Leave to File a Cross-Complaint in Department 8C

28, 2025, Defendants retained their current counsel and filed a substitution of attorney. Defendants filed the present motion on December 19, 2025. Trial in this matter is currently set for April 6, 2027.

Defendants seek leave to file a compulsory cross-complaint with claims arising from an alleged series of agreements executed in 2019 related to the real property that is the subject of Plaintiff’s quiet title action.

If a party fails to file a compulsory cross-complaint, the court shall grant leave to file a crosscomplaint so long as “the party who failed to plead the cause acted in good faith.” (Code Civ. Proc. § 426.50.) The Legislature has directed that section 426.50 “shall be liberally construed to avoid forfeiture of causes of action.” (Ibid.) “A motion to file a cross-complaint at any time during the course of the action must be granted unless bad faith of the moving party is demonstrated where forfeiture would otherwise result. Factors such as oversight, inadvertence, neglect, mistake or other cause, are insufficient grounds to deny the motion unless accompanied by bad faith.” (Silver Orgs. v. Frank (1990) 217 Cal.App.3d 94, 99.)

Here, since the motion is unopposed, there is no indication that the failure to file a timely crosscomplaint was due to Defendants’ bad faith. Thus, Defendants’ motion must be granted.

Defendants shall file and serve the proposed Cross-Complaint submitted with the moving papers by no later than June 15, 2026.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. § 1019.5; Cal. Rules of Court, rule 3.1312.)