SARAH SANDOVAL VS. STATE OF CALIFORNIA, A CALIFORNIA PUBLIC ENTITY ET AL

Matter on the Law & Motion / Discovery calendar for Thursday, August 21, 2025, Line 6. DEFENDANT CITY AND COUNTY OF SAN FRANCISCO's DEMURRER to 1ST Amended COMPLAINT.

Defendant the City and County of San Francisco's demurrer to Sarah Sandoval's first amended complaint is sustained with leave to amend. Sandoval's complaint pleads legal conclusions that the City owned or controlled a premises on which she was injured by a dangerous dog, but it pleads insufficient facts from which the City can discern Sandoval's theory of the City's liability. Sandoval offers additional facts she could plead, such as that she was a member of a vulnerable population housed at an apartment building managed by a city agency.

These facts do not appear in the complaint, and as presently pled the complaint is unclear as to what the purported basis for the City's liability is. Sandoval may plead ultimate facts, but she must plead facts rather than conclusions of law, and she must provide sufficient information in the complaint for the City to understand the theory on which it is being sued.

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