Rios v. Ford (2026)

Case details
Full caption
Alejandro Rios v. Puente Hills Ford
Country
United States
Jurisdiction
California (CA)
Court
California Supreme Court
Decided
2026
Disposition
Affirmed
Majority
Adams (J.) (unanimous Court)
ALEJANDRO RIOS, Plaintiff and Appellant, v. PUENTE..., Not Reported in... © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 445097Not Officially Published(Cal. Rules of Court, Rules 8.1105 and 8.1110, 8.1115)Only the Westlaw citation is currently available.California Rules of Court, rule 8.1115, restrictscitation of unpublished opinions in California courts.NOT TO BE PUBLISHED INTHE OFFICIAL REPORTSCourt of Appeal, Second District, California.DIVISION THREE.ALEJANDRO RIOS, Plaintiff and Appellant,v.PUENTE HILLS FORD, LLC,Defendant and Respondent.B344199|Filed 2/17/2026APPEAL from a judgment of the Superior Court of LosAngeles County, William A. Crowfoot, Judge. Affirmed. (LosAngeles County Super. Ct. No. 24NNCV00486)Attorneys and Law FirmsAlejandro Rios, in pro. per., for Plaintiff and Appellant.The Aguilera Law Group, Raymond E. Brown and LindseeB. Falcone for Defendant and Respondent.OpinionADAMS, J.*1 Alejandro Rios, in pro. per., appeals from the judgmententered against him after the trial court granted defendantPuente Hills Ford, LLC's motion to enforce a settlementagreement entered into by the parties, pursuant to Code ofCivil Procedure section 664.6.1 We affirm.FACTUAL AND PROCEDURAL BACKGROUND2Rios purchased a car from Puente Hills Ford. Under thepurchase agreement, Rios was entitled to four free oilchanges. Shortly after Rios obtained an oil change fromPuente Hills Ford, the oil sensor light in his car came on again.Rios's visual inspection of the oil revealed it to be “dark anddirty.” He had the oil drained from the car and submitted it forlaboratory analysis, which revealed that the oil present wasnot consistent with newly replaced oil.In March 2024, Rios filed this action against Puente HillsFord, asserting causes of action for breach of contract,negligence, and fraudulent misrepresentation.In April 2024, the parties entered into a settlement agreementand release. In exchange for $3,500, Rios agreed to releaseclaims concerning the oil change and to immediately dismissthe lawsuit with prejudice. Rios also waived his rights underCivil Code section 1542.Rios did not dismiss his complaint. Instead, beginning inSeptember 2024, Rios several times requested that default beentered against Puente Hills Ford. The court clerk entereddefault in October 2024, after rejecting Rios's prior requests.Rios also attempted, unsuccessfully, to obtain a defaultjudgment against Puente Hills Ford.In December 2024, Puente Hills Ford moved to enforce thesettlement agreement. In support of the motion, it submitteda declaration from its general manager and attached “[a]true and correct copy” of the parties’ settlement agreement.The general manager declared that he had negotiated thesettlement with Rios, arranged to have a written agreementprepared, reviewed the terms of the agreement in personwith Rios, signed the agreement, watched Rios sign theagreement, and handed Rios the $3,500 check. The generalmanager declared under penalty of perjury that the contentsof the declaration were true and correct. Puente Hills Fordalso submitted a declaration from its service director, whowitnessed Rios sign the agreement and saw the generalmanager hand Rios the settlement check.Rios filed an objection to the motion but did not submita supporting declaration. He thereafter filed “answers” tothe motion and two exhibit lists. Puente Hills Ford filed anobjection to the answers and exhibit lists on the grounds thatthey were untimely and unauthorized.The trial court granted the motion to enforce the settlement,vacated the default, and entered a judgment of dismissalwith prejudice. The court found that the settlement agreementhad been properly authenticated and resolved Rios's claimsagainst Puente Hills Ford. It observed that, “[c]ritically,” Rios
ALEJANDRO RIOS, Plaintiff and Appellant, v. PUENTE..., Not Reported in... © 2026 Thomson Reuters. No claim to original U.S. Government Works.2did not deny signing the settlement agreement or receivingthe settlement payment. The court rejected Rios's assertionthat the settlement agreement was not valid because it wasnot notarized and that there was no meeting of the mindsbecause the agreement did not contain Rios's full legalname. The court further concluded the plain language of theagreement contradicted Rios's claim that the $3,500 paymentwas “partial” and that he did not execute a comprehensiverelease.*2 Rios timely appealed.DISCUSSIONIt is a fundamental rule of appellate review that an appealedjudgment or order is presumed correct, and error must beaffirmatively shown. (Jameson v. Desta (2018) 5 Cal.5th594, 609 (Jameson); Denham v. Superior Court (1970) 2Cal.3d 557, 564.) “ ‘In the absence of a contrary showingin the record, all presumptions in favor of the trial court'saction will be made by the appellate court.’ ” (Jameson, atp. 609.) To overcome this presumption, the appellant hasthe burden of providing the appellate court with an adequaterecord demonstrating error. (Ibid.; Maria P. v. Riles (1987)43 Cal.3d 1281, 1295.) It is also the appellant's burden toprovide reasoned argument and citations to relevant legalauthority to support that argument. (Lee v. Kim (2019) 41Cal.App.5th 705, 721; Hernandez v. First Student, Inc. (2019)37 Cal.App.5th 270, 277.) Accordingly, “[w]hen an appellantfails to raise a point, or asserts it but fails to support itwith reasoned argument and citations to authority, we treatthe point as forfeited.” (Delta Stewardship Council Cases(2020) 48 Cal.App.5th 1014, 1075.) These “same rules applyto a party appearing in propria persona as to any otherparty.” (Flores v. Department of Corrections & Rehabilitation(2014) 224 Cal.App.4th 199, 205.)Rios's opening brief contains no citations to the record andthe record he designated is inadequate. Notably, it does notcontain the declaration attaching the settlement agreement,on which the trial court necessarily relied. The failure toprovide an adequate record for appellate review requires thatwe affirm the lower court's order. (Jameson, supra, 5 Cal.5that p. 609.)Rios also repeatedly cites cases for propositions they do notsupport. Troublingly, Rios misquotes 10 existing cases (i.e.,the quoted language appears nowhere in the decisions) andcites two cases that do not exist.3 Rios's self-represented statusdoes not excuse him from compliance with the CaliforniaRules of Court, including rule 8.204(a)(1)(B), which requiresthat citations to legal authority support all assertions of lawin a brief. (See Kobayashi v. Superior Court (2009) 175Cal.App.4th 536, 543 [“[p]ro. per. litigants are held to thesame standards as attorneys”; applying rules of professionalconduct to pro. per. litigant].) Just as attorneys are requiredto verify that the citations in their briefs are accurate, sotoo are self-represented litigants. (Noland v. Land of theFree, L.P. (2025) 114 Cal.App.5th 426, 446 (Noland).) “‘ “Honesty in dealing with the courts is of paramountimportance, and misleading a judge is, regardless of motives,a serious offense.” ’ [Citation.]” (People v. Alvarez (2025) 114Cal.App.5th 1115, 1119 (Alvarez).)*3 This court and other appellate courts have imposedmonetary sanctions on attorneys for conduct similar to thatreflected in Rios's briefing. (Noland, supra, 114 Cal.App.5that pp. 442–447; Alvarez, supra, 114 Cal.App.5th at pp. 1119–1120; Schlichter v. Kennedy (2025) 116 Cal.App.5th 24, 32–34.) Although we decline to impose sanctions in this matter,we strongly caution Rios that the future submission of a briefto this court containing fabricated cases or quotations mayresult in sanctions or having the offending brief stricken.(Shayan v. Shakib (2025) 116 Cal.App.5th 619, 625–626.)Even if Rios has not forfeited his arguments on appeal, hedoes not demonstrate that the trial court erred in granting themotion to enforce the settlement.Section 664.6, subdivision (a), provides: “If parties to pendinglitigation stipulate, in a writing signed by the parties outside[of] the presence of the court or orally before the court,for settlement of the case, ... the court, upon motion, mayenter judgment pursuant to the terms of the settlement.”“The trial court's factual findings on a motion to enforcea settlement under section 664.6 ‘are subject to limitedappellate review and will not be disturbed if supported bysubstantial evidence.’ [Citation.]” (Critzer v. Enos (2010) 187Cal.App.4th 1242, 1253.) Substantial evidence is “evidenceof ponderable legal significance, evidence that is reasonable,credible and of solid value.” (Minnegren v. Nozar (2016) 4Cal.App.5th 500, 507.) We consider the evidence in the lightmost favorable to the prevailing party and resolve conflicts insupport of the trial court's findings. (Estate of Young (2008)160 Cal.App.4th 62, 76.) We independently review issues oflaw. (Critzer, at p. 1253.)
ALEJANDRO RIOS, Plaintiff and Appellant, v. PUENTE..., Not Reported in... © 2026 Thomson Reuters. No claim to original U.S. Government Works.3Substantial evidence supports the trial court's ruling. PuenteHills Ford submitted a settlement agreement, signed by Rios,in which Rios agreed to release all claims concerning theoil change and all claims that could have been asserted inhis lawsuit. Rios further agreed to dismiss the lawsuit withprejudice. Puente Hills Ford also submitted declarations fromits general manager and service director attesting that theysaw Rios sign the agreement and that Rios received thesettlement payment. Although we generally “look only at theevidence and reasonable inferences supporting the successfulparty, and disregard the contrary showing” (Howard v. OwensCorning (1999) 72 Cal.App.4th 621, 631), we note that Riosdid not submit a declaration and did not refute that thesettlement agreement was genuine, that he signed it, or thathe received payment.The trial court did not err in concluding that the settlementagreement was properly authenticated. A “proponent's burdenof producing evidence to show authenticity ([Evid. Code,] §1400) is met ‘when sufficient evidence has been producedto sustain a finding that the document is what it purportsto be. [Citation.]’ [Citation.]” (People v. Valdez (2011) 201Cal.App.4th 1429, 1435.) In his declaration, Puente HillsFord's general manager stated under penalty of perjury thatthe agreement submitted to the court was a true and correctcopy of the settlement agreement that he and Rios reviewedtogether and signed. This was sufficient to establish that theagreement was what it purports to be.Rios contends the settlement agreement is unenforceablebecause it is not notarized, was not signed by a witness and“[w]as not filed or exchanged through any court-authorizedsettlement process.” However, “section 664.6 requires onlythat a settlement agreement be reduced to writing and signedby the parties, or orally stated in court.” (In re Marriageof Woolsey (2013) 220 Cal.App.4th 881, 898.) Thoserequirements were satisfied. In Woolsey, the appellate courtrejected the argument that a marital settlement agreementwas unenforceable because it did not comply with a localcourt rule requiring that a property settlement agreementbe notarized if the parties were unrepresented. (Id. at p.899.) The court concluded that nothing in the Code ofCivil Procedure or any other California code required theagreement to be notarized. Further, adding a notarizationrequirement would be “inconsistent with the Legislature'sspecifications of the requirements for enforceability.” (Ibid.)Similarly, section 664.6 does not require that a settlementagreement be signed by a witness or exchanged through acourt-authorized settlement process.*4 Rios also contends that the agreement was notenforceable because it did not identify specific causes ofaction to be released, specifically state it was intended toresolve a lawsuit, reference a Superior Court case number,or contain a Civil Code section 1542 release. The settlementagreement contradicts most of these claims. It defines the term“lawsuit” by reference to the Superior Court case number,states that the agreement is intended to resolve all claims thatwere or could have been raised in the lawsuit, and providesthat Rios will dismiss the lawsuit with prejudice. It alsocontains an express waiver of Civil Code section 1542. Thatthe settlement agreement does not list the causes of actionRios asserted does not render it unenforceable.Rios argues that because he denied the existence of asettlement, the trial court was required to hold an evidentiaryhearing. However, the cases he cites demonstrate that thisis incorrect. Osumi v. Sutton (2007) 151 Cal.App.4th 1355and Fiore v. Alvord (1985) 182 Cal.App.3d 561, providethat a trial judge ruling on a motion to enforce a settlementagreement may decide disputed facts and may consider oraltestimony or may determine the motion upon declarationsalone.4 (Osumi, at p. 1360; Fiore, at p. 565.) The trial courtacted within its discretion when it decided the motion basedon the declarations Puente Hills Ford submitted.Rios further claims the settlement agreement wasunenforceable because it stated his name as “Alejandro Rios,”rather than his full legal name, “Alejandro Rey Rios.” Weaccept Rios's assertion that a contract must clearly identifythe parties. However, as the trial court observed, Rios used“Alejandro Rios” in the caption of his complaint and otherdocuments he filed with the trial court. Rios also signedboth his complaint and his opening brief in this appeal as“Alejandro Rios.” Rios evidently believed the abbreviatedversion of his name was sufficient to identify him for litigationpurposes. There is no reason why it would not be sufficientto identify him as a party to the contract. There is also nolegal authority to support Rios's claim that the contract isunenforceable because it did not use his full legal name.The trial court did not err in rejecting Rios's claim thatthe settlement agreement was unenforceable because hedid not intend to release all of his claims against PuenteHills Ford and the payment of $3,500 was “partial.” Asthe court observed, the plain language of the settlementagreement contradicts this claim. The agreement providedfor a “complete resolution” of Rios's claims against Puente
ALEJANDRO RIOS, Plaintiff and Appellant, v. PUENTE..., Not Reported in... © 2026 Thomson Reuters. No claim to original U.S. Government Works.4Hills Ford. “ ‘ “The general rule is that when a personwith the capacity of reading and understanding an instrumentsigns it, he is, in the absence of fraud and imposition,bound by its contents, and is estopped from saying that itsprovisions are contrary to his intentions or understanding.”’ [Citations.]” (Jefferson v. Department of Youth Authority(2002) 28 Cal.4th 299, 303.) Rios did not argue below or onappeal that Puente Hills Ford fraudulently induced him to signthe agreement. Thus, he is bound by its terms.Finally, Rios contends the court abused its discretion invacating the default because Puente Hills Ford did not makea motion under section 473, subdivision (b). We disagree.Although Puente Hills Ford did not expressly move to vacatethe default, the trial court vacated default in response tothe motion to enforce the settlement. The trial court did noterr in deeming Puente Hills Ford to have also moved tovacate the default. (See Dill v. Berquist Construction Co.(1994) 24 Cal.App.4th 1426, 1440, 1443–1445 (Dill) [finding“defendants’ motions [to dismiss] implicitly included arequest for relief from the default judgments entered againstthem” and affirming order dismissing the action].) In itsmotion to enforce the settlement, Puente Hills Ford pointedout that Rios had agreed to immediately dismiss his complaintwith prejudice upon receiving payment pursuant to thesettlement agreement but instead he attempted to obtaindefault and default judgment against Puente Hills Ford. Itfurther asserted that it had never been served with copies ofthe requests for entry of default and submitted a declarationattesting to this fact.*5 Thus, Puente Hills Ford's motion to enforce thesettlement included evidence establishing that the defaultagainst it had been taken by “surprise” for purposes of section473, subdivision (b). As in Dill, a motion to vacate the defaultwould have been timely if brought with Puente Hills Ford'smotion to enforce the settlement. (Dill, supra, 24 Cal.App.4that p. 1444; § 473, subd. (b) [application for relief “shallbe made within a reasonable time, in no case exceedingsix months” after order or judgment].) Moreover, since thetrial court correctly concluded that Rios released all claimsasserted in this action, “nothing would be gained by insistingupon an express motion having been made.” (Dill, at p. 1444.)DISPOSITIONThe judgment is affirmed. Puente Hills Ford, LLC shallrecover its costs on appeal.NOT TO BE PUBLISHED IN THE OFFICIALREPORTSWe concur:EDMON, P. J.HANASONO, J.All CitationsNot Reported in Cal.Rptr., 2026 WL 445097Footnotes1All further undesignated statutory references are to the Code of Civil Procedure.2We take our facts from the complaint.3Rios cites “Stanley v. Univ. of Southern California (2022) 98 Cal.App.5th 151” for the proposition that a defendant'sunilateral misunderstanding as to a plaintiff's intent is unenforceable against the plaintiff. He cites “Eustace v. Lynch(2012) 209 Cal.App.4th 1457” for the proposition that general releases must be accompanied by a Civil Code section1542 waiver. These reporter citations lead to decisions with entirely different names, and which do not support Rios'sclaims. Although we located decisions with the case names Rios provided, the existing Stanley decision is from a differentjurisdiction and the existing Eustace case was decided 71 years before the nonexistent case Rios cites. (Stanley v.University of Southern California (9th Cir. 1994) 13 F.3d 1313; Eustace v. Lynch (1941) 43 Cal.App.2d 486.) The actualcases with these names do not support Rios's claims.4Rios purports to quote from Osumi and Fiore in his brief on appeal, but the quotations do not exist in those cases.
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