Rosette vs. Uppal

proving relatedness is present through the presentation of “competent evidence of jurisdictional facts.” (LG Chem, Ltd. v. Superior Court of San Diego County (2022) 80 Cal.App.5th 348, 365.)

As described, above, Plaintiffs allege in the FAC that SPFI is liable for the wrongful death of the Decedent because of the “hazing ritual” that occurred in Lake Havasu, Arizona. The Defendants allegedly “directed, encouraged, authorized, ratified, and/or contributed to the hazing that occurred on the day of the incident” and “negligently organized, managed, supervised, advertised, and trained in connection with the boat trip which resulted in the death of [Decedent].” (FAC at ¶¶ 26-27.) Nevertheless, Plaintiffs have not proffered any evidence that SPFI, beyond granting a charter to the CSUF chapter, had anything to do with the “hazing” incident, which gives rise to Plaintiffs’ wrongful death and survival claims.

The allegations in Plaintiffs’ pleading are not evidence that the Court considers in ruling on this motion. (Rivelli v. Hemm (2021) 67 Cal.App.5th 380, 393 [“To meet this burden, a plaintiff must do more than make allegations.... Allegations in an unverified complaint are insufficient to satisfy this burden of proof.”].)

Although relatedness is an “intensely fact-specific inquiry,” the Court finds the record does not bear resemblance to cases where the relatedness inquiry has been satisfied. (See, e.g., Hirsch v. Blue Cross, Blue Shield of Kansas City (9th Cir. 1986) 800 F.2d 1474, 1480 [breach of contract claim was forum-related by virtue of the parties having entered into the contract]; In re Fuel Industry Climate Cases (2026) 117 Cal.App.5th 882, 894 [relatedness inquiry satisfied where the evidence showed the company was “directly involved in distributing fossil fuel products to California consumers,” even if it did not sell the gasoline directly to the consumers, and product liability claims were based on the distribution of the gasoline]; People ex rel.

Harris v. Native Wholesale Supply Co. (2011) 196 Cal.App.4th 357, 365 [relatedness requirement was readily met where the State is alleging the non- resident cigarette distributor is violating state law by distributing the cigarettes to the California public]; SK Trading International Co. Ltd. v. Superior Court of San Francisco County (2022) 77 Cal.App.5th 378, 390 [relatedness requirement satisfied where evidence showed that officers of oil and gas firm were directly involved in the formulation of the policies that the complaint alleges constituted an anticompetitive scheme].)

Unlike in those cases, here, it would be a leap to say there is a connection between SPFI’s connection with California and the specific claims at issue. Plaintiffs are not alleging any claims based on SPFI’s granting of a charter to the CSUF chapter, or any claims relating to its collection of dues. Rather, Plaintiffs claims specifically arise from the events surrounding the hazing incident in Lake Havasu. Despite being given an opportunity to conduct jurisdictional discovery, Plaintiffs have not proffered any evidence that there was any direct conduct by SPFI that led to the tragic events of that day.

Aside from showing that SPFI granted a charter to the local chapter, that SPFI issued policies and guidelines re: hazing, and that SPFI could discipline a chapter by revoking its charter, there is no evidence that SPFI urged, fostered, or encouraged the event at Lake Havasu, much less the alleged hazing incident that took place that day. As such, Court grants the motion to quash and quashes the service of the summons and the FAC served on SPFI.

The case management conference is continued to November 2, 2026 at 2:00 p.m. in Department C27.

SPFI is ordered to give notice of the ruling.

111 2024-01401763 1. Demurrer to Amended Complaint

2. Demurrer to Amended Cross-Complaint Rosette vs. Uppal 3. Motion to Strike – Anti-SLAPP 4. Motion to Strike Portions of Cross-Complaint 5. Case Management Conference

Continued to August 26, 2026 at 1:30 p.m. in Department C27.