honest error (California) · Go Syfert
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honest error in California

12 California opinions name it 2 courts 1903–2002 0 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Davis v. Damrellgreen
calctapp · 1981 · cited in 2 California opinions naming this issue, 2002–2002
2 sentences

2002The doctrine immunizes attorneys from liability “resulting from an honest error in judgment concerning a doubtful or debatable point of law.” (Davis v. Damrell (1981) 119 Cal.App.3d 883, 887 [ 174 Cal.Rptr. 257 ].) “[T]he controlling test [for judgmental immunity] invokes a two-pronged inquiry: (1) whether the state of the law was unsettled at the time the professional advice was rendered; (2) and whether that advice was based upon the exercise of an informed judgment.” (Ibid.) Village Nurseries directs its challenge to the first prong of the test, arguing the state of the law was not unsettle

2002The doctrine immunizes attorneys from liability “resulting from an honest error in judgment concerning a doubtful or debatable point of law.” (Davis v. Damrell (1981) 119 Cal.App.3d 883, 887 [ 174 Cal.Rptr. 257 ].) “[T]he controlling test [for judgmental immunity] invokes a two-pronged inquiry: (1) whether the state of the law was unsettled at the time the professional advice was rendered; (2) and whether that advice was based upon the exercise of an informed judgment.” (Ibid.) Village Nurseries directs its challenge to the first prong of the test, arguing the state of the law was not unsettle

12
Royer v. Steinberggreen
calctapp · 1979 · cited in 1 California opinions naming this issue, 1986–1986
2 sentences

1986(Royer v. Steinberg (1979) 90 Cal.App.3d 490, 498 [ 153 Cal.Rptr. 499 ].) Section 583 of the Restatement Second of Torts states as a general principle: “Except as stated in § 584, the consent of another to the publication of defamatory matter concerning him is a complete defense to his action for defamation.” Section 584 allows an honest inquiry by the defamed person to inquire into *1633 the defamatory publication.

1986(Royer v. Steinberg (1979) 90 Cal.App.3d 490, 498 [ 153 Cal.Rptr. 499 ].) Section 583 of the Restatement Second of Torts states as a general principle: “Except as stated in § 584, the consent of another to the publication of defamatory matter concerning him is a complete defense to his action for defamation.” Section 584 allows an honest inquiry by the defamed person to inquire into *1633 the defamatory publication.

11
MJS Enterprises, Inc. v. Superior Courtgreen
calctapp · 1984 · cited in 1 California opinions naming this issue, 1984–1984
2 sentences

1984The section allows "a party to amend any pleading...." Presumably the court is not authorized to do so on its own motion. [5] Section 473 allows amendments to "any pleading or proceeding." There is considerable doubt that a summons is a "proceeding," being defined as "the process by which a court acquires personal jurisdiction over a defendant in a civil action." ( MJS Enterprises, Inc. v. Superior Court (1984) 153 Cal. App.3d 555, 557 [ 200 Cal. Rptr. 286 ].) In light of our resolution of the case on other grounds, this question need not be decided. [1] All statutory citations are to the Code

1984The section allows "a party to amend any pleading...." Presumably the court is not authorized to do so on its own motion. [5] Section 473 allows amendments to "any pleading or proceeding." There is considerable doubt that a summons is a "proceeding," being defined as "the process by which a court acquires personal jurisdiction over a defendant in a civil action." ( MJS Enterprises, Inc. v. Superior Court (1984) 153 Cal. App.3d 555, 557 [ 200 Cal. Rptr. 286 ].) In light of our resolution of the case on other grounds, this question need not be decided. [1] All statutory citations are to the Code

11
Smith v. Lewisgreen
cal · 1975 · cited in 1 California opinions naming this issue, 1981–1981
2 sentences

1981(Lysick v. Walcom (1968) 258 Cal.App.2d 136, 156 [ 65 Cal.Rptr. 406 , 28 A.L.R.3d 368 ]; 1 Witkin, Cal. Procedure (2d ed. 1970) Attorneys, § 143, p. 154.) But it is equally settled that no liability will attach “‘for lack of knowledge as to the true state of the law where a doubtful or debatable point is involved.’” (Sprague v. Morgan (1960) 185 Cal.App.2d 519, 523 [ 8 Cal.Rptr. 347 ]; accord Smith v. Lewis, supra, 13 Cal.3d 349, 358-359 ; see generally 1 Witkin, op. cit., §§ 150-152, pp. 161-164; Annot. (1977) 78 A.L.R.3d 255 .) In reaffirming the long-established principle immunizing the leg

1981(Lysick v. Walcom (1968) 258 Cal.App.2d 136, 156 [ 65 Cal.Rptr. 406 , 28 A.L.R.3d 368 ]; 1 Witkin, Cal. Procedure (2d ed. 1970) Attorneys, § 143, p. 154.) But it is equally settled that no liability will attach “‘for lack of knowledge as to the true state of the law where a doubtful or debatable point is involved.’” (Sprague v. Morgan (1960) 185 Cal.App.2d 519, 523 [ 8 Cal.Rptr. 347 ]; accord Smith v. Lewis, supra, 13 Cal.3d 349, 358-359 ; see generally 1 Witkin, op. cit., §§ 150-152, pp. 161-164; Annot. (1977) 78 A.L.R.3d 255 .) In reaffirming the long-established principle immunizing the leg

11
Lysick v. Walcomgreen
calctapp · 1968 · cited in 1 California opinions naming this issue, 1981–1981
2 sentences

1981(Lysick v. Walcom (1968) 258 Cal.App.2d 136, 156 [ 65 Cal.Rptr. 406 , 28 A.L.R.3d 368 ]; 1 Witkin, Cal. Procedure (2d ed. 1970) Attorneys, § 143, p. 154.) But it is equally settled that no liability will attach “‘for lack of knowledge as to the true state of the law where a doubtful or debatable point is involved.’” (Sprague v. Morgan (1960) 185 Cal.App.2d 519, 523 [ 8 Cal.Rptr. 347 ]; accord Smith v. Lewis, supra, 13 Cal.3d 349, 358-359 ; see generally 1 Witkin, op. cit., §§ 150-152, pp. 161-164; Annot. (1977) 78 A.L.R.3d 255 .) In reaffirming the long-established principle immunizing the leg

1981(Lysick v. Walcom (1968) 258 Cal.App.2d 136, 156 [ 65 Cal.Rptr. 406 , 28 A.L.R.3d 368 ]; 1 Witkin, Cal. Procedure (2d ed. 1970) Attorneys, § 143, p. 154.) But it is equally settled that no liability will attach “‘for lack of knowledge as to the true state of the law where a doubtful or debatable point is involved.’” (Sprague v. Morgan (1960) 185 Cal.App.2d 519, 523 [ 8 Cal.Rptr. 347 ]; accord Smith v. Lewis, supra, 13 Cal.3d 349, 358-359 ; see generally 1 Witkin, op. cit., §§ 150-152, pp. 161-164; Annot. (1977) 78 A.L.R.3d 255 .) In reaffirming the long-established principle immunizing the leg

11
Sprague v. Morgangreen
calctapp · 1960 · cited in 1 California opinions naming this issue, 1981–1981
2 sentences

1981(Lysick v. Walcom (1968) 258 Cal.App.2d 136, 156 [ 65 Cal.Rptr. 406 , 28 A.L.R.3d 368 ]; 1 Witkin, Cal. Procedure (2d ed. 1970) Attorneys, § 143, p. 154.) But it is equally settled that no liability will attach “‘for lack of knowledge as to the true state of the law where a doubtful or debatable point is involved.’” (Sprague v. Morgan (1960) 185 Cal.App.2d 519, 523 [ 8 Cal.Rptr. 347 ]; accord Smith v. Lewis, supra, 13 Cal.3d 349, 358-359 ; see generally 1 Witkin, op. cit., §§ 150-152, pp. 161-164; Annot. (1977) 78 A.L.R.3d 255 .) In reaffirming the long-established principle immunizing the leg

1981(Lysick v. Walcom (1968) 258 Cal.App.2d 136, 156 [ 65 Cal.Rptr. 406 , 28 A.L.R.3d 368 ]; 1 Witkin, Cal. Procedure (2d ed. 1970) Attorneys, § 143, p. 154.) But it is equally settled that no liability will attach “‘for lack of knowledge as to the true state of the law where a doubtful or debatable point is involved.’” (Sprague v. Morgan (1960) 185 Cal.App.2d 519, 523 [ 8 Cal.Rptr. 347 ]; accord Smith v. Lewis, supra, 13 Cal.3d 349, 358-359 ; see generally 1 Witkin, op. cit., §§ 150-152, pp. 161-164; Annot. (1977) 78 A.L.R.3d 255 .) In reaffirming the long-established principle immunizing the leg

11
In Re Imblergreen
cal · 1963 · cited in 1 California opinions naming this issue, 1975–1975
2 sentences

1975In making such an attack, however, [the] petitioner must establish by a preponderance of the evidence that perjured testimony was adduced at his trial. .-. .” (In re Imbler, 60 Cal.2d 554, 560 [ 35 Cal.Rptr. 293 , 387 P.2d 6 ], cert. den., 379 U.S. 908 [ 13 L.Ed.2d 181 , 85 S.Ct. 196 ].) “An honest error in expert opinion is not perjury even though further diligence and study might have revealed the error.” (In re Imbler, supra, 60 Cal.2d at p. 567 .) Here Kirschke failed to establish by a preponderance of the evidence that Wolfer’s error in preparation of the enlarged photographs was anything

1975In making such an attack, however, [the] petitioner must establish by a preponderance of the evidence that perjured testimony was adduced at his trial. .-. .” (In re Imbler, 60 Cal.2d 554, 560 [ 35 Cal.Rptr. 293 , 387 P.2d 6 ], cert. den., 379 U.S. 908 [ 13 L.Ed.2d 181 , 85 S.Ct. 196 ].) “An honest error in expert opinion is not perjury even though further diligence and study might have revealed the error.” (In re Imbler, supra, 60 Cal.2d at p. 567 .) Here Kirschke failed to establish by a preponderance of the evidence that Wolfer’s error in preparation of the enlarged photographs was anything

11
In Re Manchestergreen
cal · 1949 · cited in 1 California opinions naming this issue, 1975–1975
1 sentence

1975“Unless [the] negligence has obstructed the defendant in challenging the case against him, it is not a ground for collateral attack.” (In re Imbler, supra, 60 Cal.2d at p. 567 ; see also In re Manchester, supra, 33 Cal.2d 740, 742 ; In re Waltreus, supra, 62 Cal.2d 218, 221 .) Here the negligence of Wolfer in the preparation of the demonstrative evidence did not obstruct Kirschke’s ability to challenge the case against him.

11
In Re Lindleygreen
cal · 1947 · cited in 1 California opinions naming this issue, 1963–1963
2 sentences

1963(See In re Howell, 114 Cal. 250, 254 [ 46 P. 159 ]; People v. Von Tiedeman, 120 Cal. 128, 136-137 [ 52 P. 155 ]; In re Lindley, 29 Cal.2d 709, 723 [ 177 P.2d 918 ].) Petitioner contends, however, that the fingerprint expert was negligent in analyzing the fingerprints and in testifying that they were too fragmentary to identify.

1963(See In re Howell, 114 Cal. 250, 254 [ 46 P. 159 ]; People v. Von Tiedeman, 120 Cal. 128, 136-137 [ 52 P. 155 ]; In re Lindley, 29 Cal.2d 709, 723 [ 177 P.2d 918 ].) Petitioner contends, however, that the fingerprint expert was negligent in analyzing the fingerprints and in testifying that they were too fragmentary to identify.

11
In re Howellgreen
cal · 1896 · cited in 1 California opinions naming this issue, 1963–1963
1 sentence

1963(See In re Howell, 114 Cal. 250, 254 [ 46 P. 159 ]; People v. Von Tiedeman, 120 Cal. 128, 136-137 [ 52 P. 155 ]; In re Lindley, 29 Cal.2d 709, 723 [ 177 P.2d 918 ].) Petitioner contends, however, that the fingerprint expert was negligent in analyzing the fingerprints and in testifying that they were too fragmentary to identify.

11
People v. Von Tiedemangreen
cal · 1898 · cited in 1 California opinions naming this issue, 1963–1963
2 sentences

1963(See In re Howell, 114 Cal. 250, 254 [ 46 P. 159 ]; People v. Von Tiedeman, 120 Cal. 128, 136-137 [ 52 P. 155 ]; In re Lindley, 29 Cal.2d 709, 723 [ 177 P.2d 918 ].) Petitioner contends, however, that the fingerprint expert was negligent in analyzing the fingerprints and in testifying that they were too fragmentary to identify.

1963(See In re Howell, 114 Cal. 250, 254 [ 46 P. 159 ]; People v. Von Tiedeman, 120 Cal. 128, 136-137 [ 52 P. 155 ]; In re Lindley, 29 Cal.2d 709, 723 [ 177 P.2d 918 ].) Petitioner contends, however, that the fingerprint expert was negligent in analyzing the fingerprints and in testifying that they were too fragmentary to identify.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
Cooley v. County of Calaveras green
cal · 1898
2 sentences

1958(Cooley v. County of Calaveras, 121 Cal. 482 [ 53 P. 1075 ].) They cite a Washington decision, Southern Pac.

1958(Cooley v. County of Calaveras, 121 Cal. 482 [ 53 P. 1075 ].) They cite a Washington decision, Southern Pac.

21958–1958
Milam v. Dickman Construction Co. green
calctapp · 1964
2 sentences

1984(Stephens v. Berry, supra, 249 Cal.App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal.App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal.App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal.App.2d 340.) The dissent fails to make this distinction.

1984As has been pointed out, it is important to maintain the distinction between correcting an honest error in the name of a correctly named party and joining a new party in the litigation for the first time under the guise of a claim of misnomer. ( Stephens v. Berry, supra, 249 Cal. App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal. App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal. App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal. App.2d 340 .) The dissent fails to make this distinction. [4] If the trial court had been asked to do so, it probably would have been improper for

11984–1984
Thompson v. Palmer Corporation green
calctapp · 1956
2 sentences

1984(Stephens v. Berry, supra, 249 Cal.App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal.App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal.App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal.App.2d 340.) The dissent fails to make this distinction.

1984As has been pointed out, it is important to maintain the distinction between correcting an honest error in the name of a correctly named party and joining a new party in the litigation for the first time under the guise of a claim of misnomer. ( Stephens v. Berry, supra, 249 Cal. App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal. App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal. App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal. App.2d 340 .) The dissent fails to make this distinction. [4] If the trial court had been asked to do so, it probably would have been improper for

11984–1984
Stephens v. Berry green
calctapp · 1967
2 sentences

1984(Stephens v. Berry, supra, 249 Cal.App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal.App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal.App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal.App.2d 340.) The dissent fails to make this distinction.

1984As has been pointed out, it is important to maintain the distinction between correcting an honest error in the name of a correctly named party and joining a new party in the litigation for the first time under the guise of a claim of misnomer. ( Stephens v. Berry, supra, 249 Cal. App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal. App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal. App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal. App.2d 340 .) The dissent fails to make this distinction. [4] If the trial court had been asked to do so, it probably would have been improper for

11984–1984
Kline v. Beauchamp green
calctapp · 1938
2 sentences

1984(Stephens v. Berry, supra, 249 Cal.App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal.App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal.App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal.App.2d 340.) The dissent fails to make this distinction.

1984As has been pointed out, it is important to maintain the distinction between correcting an honest error in the name of a correctly named party and joining a new party in the litigation for the first time under the guise of a claim of misnomer. ( Stephens v. Berry, supra, 249 Cal. App.2d 474 ; Milam v. Dickman Construction Co., supra, 229 Cal. App.2d 208 ; Thompson v. Palmer Corporation, supra, 138 Cal. App.2d 387 ; Kline v. Beauchamp, supra, 29 Cal. App.2d 340 .) The dissent fails to make this distinction. [4] If the trial court had been asked to do so, it probably would have been improper for

11984–1984
In Re Waltreus green
cal · 1965
1 sentence

1975“Unless [the] negligence has obstructed the defendant in challenging the case against him, it is not a ground for collateral attack.” (In re Imbler, supra, 60 Cal.2d at p. 567 ; see also In re Manchester, supra, 33 Cal.2d 740, 742 ; In re Waltreus, supra, 62 Cal.2d 218, 221 .) Here the negligence of Wolfer in the preparation of the demonstrative evidence did not obstruct Kirschke’s ability to challenge the case against him.

11975–1975
Bynum v. United States green
scotus · 1964
1 sentence

1975In making such an attack, however, [the] petitioner must establish by a preponderance of the evidence that perjured testimony was adduced at his trial. .-. .” (In re Imbler, 60 Cal.2d 554, 560 [ 35 Cal.Rptr. 293 , 387 P.2d 6 ], cert. den., 379 U.S. 908 [ 13 L.Ed.2d 181 , 85 S.Ct. 196 ].) “An honest error in expert opinion is not perjury even though further diligence and study might have revealed the error.” (In re Imbler, supra, 60 Cal.2d at p. 567 .) Here Kirschke failed to establish by a preponderance of the evidence that Wolfer’s error in preparation of the enlarged photographs was anything

11975–1975
Marshall, Springs & Co. v. Smith green
sc · 1900
1 sentence

1975In making such an attack, however, [the] petitioner must establish by a preponderance of the evidence that perjured testimony was adduced at his trial. .-. .” (In re Imbler, 60 Cal.2d 554, 560 [ 35 Cal.Rptr. 293 , 387 P.2d 6 ], cert. den., 379 U.S. 908 [ 13 L.Ed.2d 181 , 85 S.Ct. 196 ].) “An honest error in expert opinion is not perjury even though further diligence and study might have revealed the error.” (In re Imbler, supra, 60 Cal.2d at p. 567 .) Here Kirschke failed to establish by a preponderance of the evidence that Wolfer’s error in preparation of the enlarged photographs was anything

11975–1975
Collazo de Texidor v. People neutral
prsupreme · 1934
1 sentence

1963(See In re Howell, 114 Cal. 250, 254 [ 46 P. 159 ]; People v. Von Tiedeman, 120 Cal. 128, 136-137 [ 52 P. 155 ]; In re Lindley, 29 Cal.2d 709, 723 [ 177 P.2d 918 ].) Petitioner contends, however, that the fingerprint expert was negligent in analyzing the fingerprints and in testifying that they were too fragmentary to identify.

11963–1963
Reynolds v. Struble green
calctapp · 1933
1 sentence

1935(Reynolds v. Struble, supra.) "It has been broadly held that a physician or surgeon is not liable for an honest error or mistake in judgment. *37 However, a limitation of this broad rule is recognized in cases that exempt from liability for errors of judgment only where there is a reasonable doubt ... as to the proper course to be followed, or where good judgments may differ.

11935–1935
Webb v. . Fulchire neutral
nc · 1843
1 sentence

1910The ground of recovery in that and the like cases of Webb v. Fulchire, 25 N. C. (3 Ired.) 485 , [ 40 Am.

11910–1910
Barnes v. Jones neutral
cal · 1876
2 sentences

1903In construing the section immediately following the one involved in this case,—section 733 of the Code of Civil Procedure,—this court, in Stewart v. Sefton, 108 Cal. 197 , has said: “ To entitle the plaintiff to treble damages under section 733 of the Code of Civil Procedure, she must have proved her allegation that plaintiff willfully or maliciously removed the trees, knowing them to be the property of plaintiff.” The court then goes on to cite Barnes v. Jones, 51 Cal. 303 , in which it was held that a complaint under this statute which did not state that the trespass was committed willfully,

1903In construing the section immediately following the one involved in this case,—section 733 of the Code of Civil Procedure,—this court, in Stewart v. Sefton, 108 Cal. 197 , has said: “ To entitle the plaintiff to treble damages under section 733 of the Code of Civil Procedure, she must have proved her allegation that plaintiff willfully or maliciously removed the trees, knowing them to be the property of plaintiff.” The court then goes on to cite Barnes v. Jones, 51 Cal. 303 , in which it was held that a complaint under this statute which did not state that the trespass was committed willfully,

11903–1903
Stewart v. Sefton green
cal · 1895
1 sentence

1903In construing the section immediately following the one involved in this case,—section 733 of the Code of Civil Procedure,—this court, in Stewart v. Sefton, 108 Cal. 197 , has said: “ To entitle the plaintiff to treble damages under section 733 of the Code of Civil Procedure, she must have proved her allegation that plaintiff willfully or maliciously removed the trees, knowing them to be the property of plaintiff.” The court then goes on to cite Barnes v. Jones, 51 Cal. 303 , in which it was held that a complaint under this statute which did not state that the trespass was committed willfully,

11903–1903

Where else courts name it

NY 18 (1889–2007) MI 12 (1886–2019) CA 12 (1903–2002) OR 12 (1902–2025) MO 12 (1913–2020) MA 12 (1931–2025) IN 11 (1889–2019) AL 9 (1878–2009) WA 8 (1921–2026) IL 6 (1872–1968) GA 5 (1988–2024) DE 5 (1943–1973) UT 4 (1998–2025) PA 4 (1932–1976) MS 4 (1925–2009) VA 4 (1883–1904) NC 4 (1889–1974) MN 3 (1986–1987) FL 3 (1982–2014) NJ 3 (1980–2015) OK 3 (1998–2011) AR 2 (1973–1982) MD 2 (1932–1980) DC 2 (2008–2015) TX 2 (1913–1918) SD 2 (1911–2007) KS 2 (1911–2010) CO 2 (2009–2011) IA 2 (1884–1931) WV 2 (1930–1985) WY 2 (1947–1989) WI 2 (1980–1996) OH 2 (1997–2002)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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