abuse of discretion standard in California

2026(People v. Waidla (2000) 22 Cal.4th 690, 717 ; Litinsky v. Kaplan (2019) 40 Cal.App.5th 970 , 988; Amtower v. Photon Dynamics, Inc. (2008) 158 Cal.App.4th 1582, 1599 .) Under the abuse of discretion standard, we review the trial court’s factual findings for substantial evidence and legal conclusions de novo, but we will not reverse the trial court’s application of the law to the facts unless arbitrary and capricious.

2026(People v. Waidla (2000) 22 Cal.4th 690, 717 ; Litinsky v. Kaplan (2019) 40 Cal.App.5th 970 , 988; Amtower v. Photon Dynamics, Inc. (2008) 158 Cal.App.4th 1582, 1599 .) Under the abuse of discretion standard, we review the trial court’s factual findings for substantial evidence and legal conclusions de novo, but we will not reverse the trial court’s application of the law to the facts unless arbitrary and capricious.

2026This court’s decisions acknowledge the general principle that rulings on an application for a preliminary injunction are reviewed for an abuse of discretion. ( T.C.E.F., supra, 246 Cal.App.4th at pp. 315–316; see Tulare Lake Canal Co. v. Stratford Public Utility Dist. (2023) 92 Cal.App.5th 380 , 402 (Tulare Lake).) We also stated that description of the standard of review was incomplete “because the abuse of discretion standard is not unified and a more specific rule might apply once the appellate court has identified the particular aspect of the trial court’s determination being challenged.”

2026(Sargon Enterprises, Inc. v. University of Southern California (2012) 55 Cal.4th 747, 773 [evidentiary rulings]; Williams v. Superior Court (2017) 3 Cal.5th 531, 540 [discovery]; City of Los Angeles v. Public Utilities Commission (1972) 7 Cal.3d 331, 352 [order quashing trial subpoena under former Code of Civil Procedure section 1987].) “The abuse of discretion standard is not a unified standard; the deference it calls for varies according to the aspect of a trial court’s ruling under review.” (Haraguchi v. Superior Court (2008) 43 Cal.4th 706, 711 .) “The question of whether a trial court app

2026(People v. Carmony (2004) 33 Cal.4th 367, 371 ; People v. Mendoza (2023) 88 Cal.App.5th 287 , 298 (Mendoza).) The abuse of discretion standard is highly deferential.

2026(People v. Carmony (2004) 33 Cal.4th 367, 371 ; People v. Mendoza (2023) 88 Cal.App.5th 287 , 298 (Mendoza).) The abuse of discretion standard is highly deferential.

2021“The appellant 15 has the burden of showing there is no evidence of a sufficiently substantial nature to support the finding or order.” (In re Dakota H. (2005) 132 Cal.App.4th 212, 228 .) “Because a section 366.26 hearing occurs only after the court has repeatedly found the parent unable to meet the child’s needs, it is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.” (In re Jasmine D. (2000) 78 Cal.App.4th 1339, 1350 .) Courts have applied both the substantial evidence standard and the abuse of discr

2020Where a biological parent ... is incapable of functioning in that role, the child should be given every opportunity to bond with an individual who will assume the role of a parent.” [Citation.]’ [Citation.]” (Ibid.) Appellate courts are divided over the appropriate standard of review to apply to an order determining the applicability of the beneficial parent-child relationship exception.3 Some courts have applied the substantial evidence test (e.g., In re G.B., supra, 227 Cal.App.4th at p. 1166 ), while others have applied the abuse of discretion standard (e.g., In re Jasmine D., supra, 78 Cal

2016(In re Cliffton B. (2000) 81 Cal.App.4th 415, 424-425 [Fourth Dist., Div. Three applied the substantial evidence standard]; In re Autumn H. (1994) 27 Cal.App.4th 567 , 576 14 [Fourth Dist., Div. One applied the substantial evidence standard]; In re Jasmine D. (2000) 78 Cal.App.4th 1339, 1351 [First Dist., Div. Three applying the abuse of discretion standard]; In re Aaliyah R. (2006) 136 Cal.App.4th 437, 449 [Second Dist., Div. Eight applying the abuse of discretion standard]; In re K.P. (2012) 203 Cal.App.4th 614, 621-622 [Second Dist., Div. Seven applying the hybrid standard]; In re Bailey J.

2016(Bailey J., supra, at p. 1314 .) The second requirement for the exception is that the beneficial parental relationship constitute a “compelling reason for determining that termination would be detrimental .…” (§ 366.26, subd. (c)(1)(B); K.P., supra, 203 Cal.App.4th at p. 622 .) Although grounded in the facts, the court’s determination of this issue is a “‘quintessentially’ discretionary decision, which calls for the juvenile court to determine the importance of the relationship in terms of the detrimental impact that its severance can be expected to have on the child and to weigh that against

2024(Caden C., supra, 11 Cal.5th at p. 636; cf. Autumn H., supra, 27 Cal.App.4th at p. 575 .) Contrary to Mother’s 12 conclusory and unsupported assertion, there is nothing in the record showing that the court “failed to properly apply the Caden C. factors.” To the extent Mother cites evidence or inferences that would have supported a contrary finding by the court on the third prong, she misapplies the abuse of discretion standard of review.

2023(Ibid.) ‘On review of the sufficiency of the evidence, we presume in favor of the order, considering the evidence in the light most favorable to the prevailing party, giving the prevailing party the benefit of every reasonable inference and resolving all conflicts in support of the order.’ (In re Autumn H., supra, 27 Cal.App.4th at p. 576 .) Under the abuse of discretion standard of review, we determine whether the juvenile court’s decision exceeded the bounds of reason and, in 16 so doing, we cannot substitute our view for that of the juvenile court.

2026(Ibid.) An appellate court “generally review[s] a trial court’s ruling on matters regarding discovery under an abuse of discretion standard.” (People v. Ayala (2000) 23 Cal.4th 225, 299 ; Kennedy v. Superior Court (2006) 145 Cal.App.4th 359, 366 [applying abuse of discretion standard to trial court’s denial of § 1054.9 discovery motion].) “ ‘ “The burden is on the party complaining to establish an abuse of discretion, and unless a clear case of abuse is shown and unless there has been a miscarriage of justice a reviewing court will not substitute its opinion and thereby divest the trial court

2025Instead defendant claims the issue is whether the denial of a continuance to present “critical defense evidence violated [his] due process rights.” Defendant cites no authority to support this assertion but instead refers to his opening brief at pages 26–28, 14 where defendant discussed the standard of review for the denial of due process not the denial of a continuance.6 “‘The burden is on the party complaining to establish an abuse of discretion, and unless a clear case of abuse is shown and unless there has been a miscarriage of justice a reviewing court will not substitute its opinion and

2021(Ibid.) “We review a section 128.7 sanctions award under the abuse of discretion standard. [Citation.] We presume the trial court’s order is correct and do not substitute our judgment for that of the trial court. [Citation.]” (Bucur v. Ahmad, supra, 244 Cal.App.4th at p. 190 .) “The scope of discretion,” however, “always resides in the particular law being applied, i.e., in the ‘legal principles governing the subject of [the] action . . . .’ ” (City of Sacramento v. Drew (1989) 207 Cal.App.3d 1287, 1297 .) “Action that transgresses the confines of the applicable principles of law is outside th

2018We began as follows: "Various definitions and principles describing the abuse of discretion standard of review have been stated and repeated in numerous *623 cases, such as in Blank v. Kirwan (1985) 39 Cal.3d 311 , 331 [ 216 Cal.Rptr. 718 , 703 P.2d 58 ], that we will set aside a trial court ruling only upon a showing of ' " 'a clear case of abuse' " ' and ' " 'a miscarriage of justice.' " ' As to what is required to show such abuse, it has been said that a trial court abuses its discretion only when its ruling ' " 'fall[s] "outside the bounds of reason." ' " [Citation.]' ( People v. Benavides

2026(Sargon Enterprises, Inc. v. University of Southern California (2012) 55 Cal.4th 747, 773 [evidentiary rulings]; Williams v. Superior Court (2017) 3 Cal.5th 531, 540 [discovery]; City of Los Angeles v. Public Utilities Commission (1972) 7 Cal.3d 331, 352 [order quashing trial subpoena under former Code of Civil Procedure section 1987].) “The abuse of discretion standard is not a unified standard; the deference it calls for varies according to the aspect of a trial court’s ruling under review.” (Haraguchi v. Superior Court (2008) 43 Cal.4th 706, 711 .) “The question of whether a trial court app

2025(City of Oakland v. Oakland Police & Fire Retirement System (2014) 224 Cal.App.4th 210, 228 .) Finally, under the abuse of discretion standard, we determine whether the trial court’s application of law to the facts “ ‘falls within the permissible range of options set by the legal criteria.’ ” (Husain, supra, 61 Cal.App.5th at p. 727.) In other words, to demonstrate an abuse of discretion, the City must show that Judge Wise’s decision “ ‘is so irrational or arbitrary that no reasonable person could agree with it.’ ” (Sargon Enterprises, Inc. v. University of Southern California (2012) 55 Cal.4t

2024(Vosburg, supra, 54 Cal.App.5th at p. 460.) The third category of trial court determinations, which Haraguchi described as the “application of the law to the facts” (Haraguchi, supra, 43 Cal.4th at p. 712 ), can be 7 The clarification provided in Haraguchi addressed without referencing Justice Wiener’s criticism of the abuse of discretion standard as “so amorphous as to mean everything and nothing at the same time and [as] virtually useless as an analytic tool.” (Hurtado v. Statewide Home Loan Co. (1985) 167 Cal.App.3d 1019, 1022 , disapproved on another ground in Shamblin v. Brattain (1988) 4

2023(Shamblin v. Brattain (1988) 44 Cal.3d 474, 478 (Shamblin).) The abuse of discretion standard of review “requires we defer to factual determinations made by the trial court when the evidence is in conflict, whether the evidence consists of oral 2 Tara Smith is not included on the notice of appeal and has not made an appearance in this appeal. 7 testimony or declarations.” (Ramos v. Homeward Residential, Inc. (2014) 223 Cal.App.4th 1434 , 1440–1441, citing Shamblin, supra, 44 Cal.3d at p. 479 .) “Because the law favors disposing of cases on their merits, ‘any doubts in applying section 473 must

2025(In re Robert H. (2002) 96 Cal.App.4th 1317, 1330 (Robert H.).) The reviewing court will “‘“indulge all reasonable inferences to support the decision of the juvenile court and will not disturb its findings when there is substantial evidence to support them.”’” (Ibid.) The abuse of discretion standard of review “asks in substance whether the ruling in question ‘falls outside the bounds of reason’ under the applicable law and the relevant facts [citations].” (People v. Williams (1998) 17 Cal.4th 148, 162 ; accord, In re Oscar A. (2013) 217 Cal.App.4th 750, 755 [“‘“[D]iscretion is abused whenever

2025(In re Robert H. (2002) 96 Cal.App.4th 1317, 1330 (Robert H.).) The reviewing court will “‘“indulge all reasonable inferences to support the decision of the juvenile court and will not disturb its findings when there is substantial evidence to support them.”’” (Ibid.; see In re Carlos J. (2018) 22 Cal.App.5th 1, 5 (Carlos J.) [we review the court’s findings for substantial evidence].) The abuse of discretion standard of review “asks in substance whether the ruling in question ‘falls outside the bounds of reason’ under the applicable law and the relevant facts [citations].” (People v. Williams

2023“The abuse of discretion standard of review applies to any ruling by a trial court on the admissibility of evidence. [Citation.] This standard is particularly appropriate when, as here, the trial court’s determination of admissibility involved questions of relevance, the state-of-mind exception to the hearsay rule, and undue prejudice. [Citation.] Under this standard, a trial court’s ruling will not be disturbed, and reversal of the judgment is not required, unless the trial court exercised its discretion in an arbitrary, capricious, or patently absurd manner that resulted in a manifest miscar

2022(People v. Breslin, supra, 205 Cal.App.4th at p. 1416 .)4 We will not disturb a ruling “unless the trial court exercised its discretion in an arbitrary, capricious, or patently absurd manner that resulted in a manifest miscarriage of justice.” (People v. Guerra (2007) 37 Cal.4th 1067, 1113 .) Under an abuse of discretion standard of review, “ ‘we ask whether the trial court’s findings of fact are supported by substantial evidence, 4 In one part of her briefs, Tolbert argues that the conditions of her confinement were “unconstitutionally” coercive.

2025That need will often dictate the conclusion that maintenance of the current arrangement would be in the best interests of that child.’ ” (In re Stephanie M., supra, 7 Cal.4th at p. 317 .) Under the abuse of discretion standard, the reviewing court cannot interfere unless “ ‘we find that under all the evidence, viewed most favorably in support of the trial court’s action, no judge could reasonably have made the order.’ ” (In re Robert L. (1993) 21 Cal.App.4th 1057, 1067 .) Mother shows no such error.

2023Under the abuse of discretion standard, ‘“[w]hen two or more inferences can reasonably be deduced from the facts, the reviewing court has no authority to substitute its decision for that of the trial court.”’ (Stephanie M., supra, 7 Cal.4th at p. 319 .) Mother did not 15 meet her burden to show a change in circumstances sufficient to safely return R.G. to her custody.

2026(People v. Blackburn (1982) 139 Cal.App.3d 761, 765 .) “It is well settled that the trial court has broad discretion to order a case reopened and allow the introduction of additional evidence. [Citations.] Such a decision is proper in the absence of an abuse of discretion. [Citation.]” (People v. Goss (1992) 7 Cal.App.4th 702, 706 .) “Under the abuse of discretion standard, ‘a trial court’s ruling will not be disturbed, and reversal of the judgment is not required, unless the trial court exercised its discretion in an arbitrary, capricious, or patently absurd manner that resulted in a manifest

2026Other Evidentiary Issues A. Standard of review “[A]n appellate court applies the abuse of discretion standard of review to any ruling by a trial court on the admissibility of evidence.” (People v. Waidla (2000) 22 Cal.4th 690, 717 .) Under this standard, “ ‘a trial court’s ruling will not be disturbed, and reversal of the judgment is not required, unless the trial court exercised its discretion in an arbitrary, capricious, or patently absurd manner that resulted in a manifest miscarriage of justice.’ [Citation.]” (People v. Hovarter (2008) 44 Cal.4th 983, 1004 .) B.

2024(In re D.O., supra, 247 Cal.App.4th at p. 174 .) We apply “the abuse of discretion standard to the court’s weighing of competing interests.” (Ibid.; see also In re Bailey J. (2010) 189 Cal.App.4th 1308, 1315 .) III.

2016(In re L.Y.L. (2002) 101 Cal.App.4th 942 , 951.) Because this component of the juvenile court’s decision is discretionary, the abuse of discretion standard of review applies.” (In re Bailey J., supra, 189 Cal.App.4th at p. 1315 ; see In re C.B. (2010) 190 Cal.App.4th 102, 123 .) “ ‘ [“]The appropriate test for abuse of discretion is whether the trial court exceeded the bounds of reason.

2026(Caden C., supra, 11 Cal.5th at pp. 639–641; In re J.C., supra, 226 Cal.App.4th at pp. 530–531.) We apply the substantial evidence standard of review to the factual issues of maintenance of regular contact and visitation and the existence of a beneficial parent-child relationship, and the abuse of discretion standard to the determination of whether there is a compelling reason for finding that termination would be detrimental to the child.

2024(Caden C., supra, 11 Cal.5th at pp. 639–641; In re J.C., supra, 226 Cal.App.4th at pp. 530–531.) We apply the substantial evidence standard of review to the factual issues of maintenance of regular contact and visitation and the existence of a beneficial parent-child relationship, and the abuse of discretion standard to the determination of whether there is a compelling reason for finding that termination would be detrimental to the child.

2025(In re Alexander A. (2011) 192 Cal.App.4th 847, 852 ; People v. Giordano (2007) 42 Cal.4th 644, 663 (Giordano).) “The abuse of discretion standard is not a 3 In his opening brief, Belloli relies on the probation report in contending he received only $5,370 for the copper wire.

2023Once the victim makes a prima facie showing of economic losses incurred as a result of the defendant’s criminal acts, the burden shifts to the defendant to disprove [that showing].” (People v. Gemelli, supra, 161 Cal.App.4th 1539 , 1542–1543.) “ ‘ “[S]entencing judges are given virtually unlimited discretion as to the kind of information they can consider and the source from whence it comes.” ’ ” (People v. Foster (1993) 14 Cal.App.4th 939, 947 , superseded by statute on other grounds as stated in People v. Birkett (1999) 21 Cal.4th 226 , 238–245.) “[W]e review the trial court’s restitution or

2026(Burgess, supra, 13 Cal.4th at p. 32 [“[t]he standard of appellate review of custody . . . orders is the deferential abuse of discretion test,” “[t]he precise measure [of which] is whether the trial court could have reasonably concluded that the order in question advanced the ‘best interest’ of the child”], LaMusga, supra, 32 Cal.4th at p. 1086 [same].) “Under an abuse of discretion standard, we review the trial court’s legal conclusions de novo and its factual findings for substantial evidence, and we reverse its application of 12 the law to the facts only if it was arbitrary and capricious.”

2025That need will often dictate the conclusion that maintenance of the current arrangement would be in the best interests of that child.’ ” (In re Stephanie M., supra, 7 Cal.4th at p. 317 .) Under the abuse of discretion standard, the reviewing court cannot interfere unless “ ‘we find that under all the evidence, viewed most favorably in support of the trial court’s action, no judge could reasonably have made the order.’ ” (In re Robert L. (1993) 21 Cal.App.4th 1057, 1067 .) Mother shows no such error.

2026(Ibid.) An appellate court “generally review[s] a trial court’s ruling on matters regarding discovery under an abuse of discretion standard.” (People v. Ayala (2000) 23 Cal.4th 225, 299 ; Kennedy v. Superior Court (2006) 145 Cal.App.4th 359, 366 [applying abuse of discretion standard to trial court’s denial of § 1054.9 discovery motion].) “ ‘ “The burden is on the party complaining to establish an abuse of discretion, and unless a clear case of abuse is shown and unless there has been a miscarriage of justice a reviewing court will not substitute its opinion and thereby divest the trial court

2026(People v. Jordan (2003) 108 Cal.App.4th 349, 358 ; People v. Gonzales (1994) 22 Cal.App.4th 1744, 1758 .) “ ‘[A] trial court may, in the exercise of its discretion, “consider a wide range of sanctions” in response to [a] violation of a discovery order.’ ” (People v. Ayala (2000) 23 Cal.4th 225, 299 .) “ ‘We generally review a trial court’s ruling on matters regarding discovery under an abuse of discretion standard.’ ” (People v. Lamb (2006) 136 Cal.App.4th 575, 581 .) C.

2022(In re Microsoft I-V Cases (2006) 135 Cal.App.4th 706, 723 [review of approval of class action settlement]; PLCM Group, Inc. v. Drexler (2000) 22 Cal.4th 1084, 1095 [review of amount awarded for attorney fees].) “Thus, in reviewing approvals of class action settlements, ‘[w]e do not substitute our notions of fairness for those of the trial court or the parties to the agreement. [Citation.] “To merit reversal, both an abuse of discretion by the trial court must be ‘clear’ and the demonstration of it on appeal ‘strong.’”’ [Citation.] ‘“[G]reat weight is accorded the trial judge’s views . . . .”’

2021(PLCM Group, Inc. v. Drexler (2000) 22 Cal.4th 1084, 1095 .) We review a court’s determination under the abuse of discretion standard.

2025VI, § 13; Carnes v. Superior Court (2005) 126 Cal.App.4th 688, 694 [an appellate court reviews a trial court’s rulings on evidentiary objections under the abuse of discretion standard].) “ ‘[A]n erroneous evidentiary ruling requires reversal only “if there is a reasonable 11. probability that a result more favorable to the appealing party would have been reached in the absence of the error.” ’ ” ( Serri, supra, 226 Cal.App.4th at pp. 857‒858, quoting Twenty–Nine Palms, supra, 210 Cal.App.4th at p. 1449 .) Thus, in Serri, the appellate court concluded the trial court’s error in issuing a blanke

2025DISCUSSION I Plaintiffs Have Not Shown Error in Evidentiary Rulings A. Standards of Review for Evidentiary Rulings Although review of summary judgment itself is de novo, “an appellate court reviews a court’s final rulings on evidentiary objections by applying an abuse of discretion standard.” (Carnes v. Superior Court (2005) 126 Cal.App.4th 688, 694 ; see Ortiz v. Dameron Hospital Assn. (2019) 37 Cal.App.5th 568, 584 ; Michaels v. Greenberg Traurig, LLP (2021) 62 Cal.App.5th 512 , 521.) B.

2025(See People v. Sandoval (2007) 41 Cal.4th 825, 847 [“The trial court’s sentencing discretion must be exercised in a manner that is not arbitrary and capricious, that is consistent with the letter and spirit of the law, and that is based upon an ‘individualized consideration of the offense, the offender, and the public interest.’”]; accord People v. Carmony (2004) 33 Cal.4th 367, 371, 375 (Carmony); Mendoza, supra, 88 Cal.App.5th at p. 298; People v. Garcia (2024) 101 Cal.App.5th 848 , 856.) 11 “The abuse of discretion standard is highly deferential.” (Mendoza, supra, 88 Cal.App.5th at p. 298.)

2025(People v. Sandoval (2007) 41 Cal.4th 825, 847 ; accord People v. Carmony (2004) 33 Cal.4th 367, 375 .) The abuse of discretion standard is highly deferential and requires us to follow two fundamental precepts.

2026(See People v. Waidla (2000) 22 Cal.4th 690 , 745–746 [“An appellate court applies the abuse of discretion standard of review to any decision by a trial court to instruct, or not to instruct, in its exercise of its supervision over a deliberating jury”]; People v. Hodges (2013) 213 Cal.App.4th 531, 539 .) “Various definitions and principles describing the abuse of discretion standard of review have been stated and repeated in numerous cases, such as 18 in Blank v. Kirwan (1985) 39 Cal.3d 311, 331 , that we will set aside a trial court ruling only upon a showing of ‘ “ ‘a clear case of abuse’ ”

2024(Genis v. 1 While we would apply an abuse of discretion standard to review the trial court’s denial of leave to amend (Blank v. Kirwan, supra, 39 Cal.3d at p. 318 ), Mid-Sunset does not challenge this aspect of the trial court’s ruling in its briefing, arguing only that the causes of action were adequately alleged. 5 Schainbaum (2021) 66 Cal.App.5th 1007 , 1015.) We need not accept as true, however, contentions, deductions, or conclusions of fact or law.

2025(See Department of Parks & Recreation v. State Personnel Bd. (1991) 233 Cal.App.3d 813 , 830–831 [discussing “the distinction between the substantial evidence rule and the abuse of discretion standard”].) Below, Carol argued Wright was limited to working 66 hours in a workweek by statute (§ 12300.4, subd. (b)(2)), which conflicted with Wright’s testimony that he worked 12 hours a day, seven days a week.

2024(Gropen v. Superior Court (2023) 89 Cal.App.5th 1068 , 1075, 1082.) “Under an abuse of discretion standard of review, the ‘trial court’s findings of fact are reviewed for substantial evidence, its conclusions of law are reviewed de novo, and its application of the law to the facts is reversible only if arbitrary and capricious.’ [Citation.] A ‘court abuses its discretion “ ‘where no reasonable basis for the action is shown.’ ” ’ ” (In re Tobacco Cases II (2015) 240 Cal.App.4th 779, 790 .) On one level, “[a]ny exercise of discretion must rest on correct legal premises, . . . and in that respect

2026Plaintiffs argue that Vons therefore failed to meet its burden to show that it did not control the parking lot according to the lease, and the trial court erred in relying on the non-operative lease in granting the motion for summary judgment. 11 Plaintiffs note that they objected to the outdated lease in their evidentiary objections submitted with their opposition, but the court did not rule on their objections.5 We presume the objection was overruled (Reid v. Google, Inc. (2010) 50 Cal.4th 512, 534 ), and review that ruling under an abuse of discretion standard.

2026Plaintiffs argue that Vons therefore failed to meet its burden to show that it did not control the parking lot according to the lease, and the trial court erred in relying on the non-operative lease in granting the motion for summary judgment. 11 Plaintiffs note that they objected to the outdated lease in their evidentiary objections submitted with their opposition, but the court did not rule on their objections.5 We presume the objection was overruled (Reid v. Google, Inc. (2010) 50 Cal.4th 512, 534 ), and review that ruling under an abuse of discretion standard.