late filing claim (California) · Go Syfert
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late filing claim in California

11 California opinions name it 2 courts 1944–2015 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 (2)

CaseFollowedCited
People v. Currygreen
cal · 1965 · cited in 2 California opinions naming this issue, 1969–1969
2 sentences

1969(E.g., People v. Curry, 62 Cal.2d 207, 212 [ 42 Cal. Rptr. 17 , 397 P.2d 1009 ]; People v. Davis, supra, at p. 809 .) [8] Having adopted the referee's finding in the present case that, because of somewhat unusual circumstances, petitioner was not aware of his appeal rights during the 10-day period following his sentencing, we hold that petitioner is entitled to relief under rule 31(a) because his failure to file a timely notice of appeal was due to ignorance of his appeal rights. [9] The referee correctly found that under the peculiar facts of this case petitioner is not estopped from obtainin

1969(E.g., People v. Curry, 62 Cal.2d 207, 212 [ 42 Cal. Rptr. 17 , 397 P.2d 1009 ]; People v. Davis, supra, at p. 809 .) [8] Having adopted the referee's finding in the present case that, because of somewhat unusual circumstances, petitioner was not aware of his appeal rights during the 10-day period following his sentencing, we hold that petitioner is entitled to relief under rule 31(a) because his failure to file a timely notice of appeal was due to ignorance of his appeal rights. [9] The referee correctly found that under the peculiar facts of this case petitioner is not estopped from obtainin

12
Viles v. State of Californiagreen
cal · 1967 · cited in 1 California opinions naming this issue, 1967–1967
2 sentences

1967(Viles v. State of California, 66 Cal.2d 24, 33 [ 56 Cal.Rptr. 666 , 423 P.2d 818 ].) In a proper case a public entity may be estopped to assert the failure of a claimant to present a claim, or to present it within time, to avoid liability upon a cause of action conditioned upon the prescribed presentation of a claim.

1967(Viles v. State of California, 66 Cal.2d 24, 33 [ 56 Cal.Rptr. 666 , 423 P.2d 818 ].) In a proper case a public entity may be estopped to assert the failure of a claimant to present a claim, or to present it within time, to avoid liability upon a cause of action conditioned upon the prescribed presentation of a claim.

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 (14)

CaseCitedYears
Flores v. Board of Supervisors of Los Angeles County green
calctapp · 1970
2 sentences

1983The statement by the court at page 485 of Flores v. Board of Supervisors, supra, 13 Cal. App.3d 480 , applies with equal vigor here: "In addition to the fact that the affidavits in support of appellants' petition amply support the conclusion that their failure to file a timely claim was due to the causes alleged, there is no showing that the public entity at bench was in any way prejudiced by a late filing of the claim.

1983The statement by the court at page 485 of Flores v. Board of Supervisors, supra, 13 Cal.App.3d 480 , applies with equal vigor here: “In addition to the fact that the affidavits in support of appellants’ petition amply support the conclusion that their failure to file a timely claim was due to the causes alleged, there is no showing that the public entity at bench was in any way prejudiced by a late filing of the claim.

21983–1983
Bettencourt v. Los Rios Community College District green
cal · 1986
2 sentences

2015(Id. at pp. 532-533.) The Court of Appeal reversed the trial court’s refusal to grant relief under Government Code section 946.6 from the effect of the late filing of the claim, because the evidence established that an “extensive investigation was conducted” 9 and the “investigator’s actions were not devoid of diligence.” (Kaslavage, at pp. 536- 537.) Bettencourt, supra, 42 Cal.3d 270 involved a wrongful death action arising from a fatal field trip sponsored by a city college.

2015(Id. at pp. 532-533.) The Court of Appeal reversed the trial court’s refusal to grant relief under Government Code section 946.6 from the effect of the late filing of the claim, because the evidence established that an “extensive investigation was conducted” 9 and the “investigator’s actions were not devoid of diligence.” (Kaslavage, at pp. 536- 537.) Bettencourt, supra, 42 Cal.3d 270 involved a wrongful death action arising from a fatal field trip sponsored by a city college.

12015–2015
Katz v. A. J. Ruhlman & Co. green
calctapp · 1945
2 sentences

1976Ruhlman & Co. (1945) 69 Cal.App.2d 541 [ 159 P.2d 426 ], the appeal involved the claimant’s attempt to offset his claim against the decedent in an action by the administrator to recover upon a note given by the claimant to the decedent.

1976Ruhlman & Co. (1945) 69 Cal.App.2d 541 [ 159 P.2d 426 ], the appeal involved the claimant’s attempt to offset his claim against the decedent in an action by the administrator to recover upon a note given by the claimant to the decedent.

11976–1976
Farrell v. County of Placer green
cal · 1944
2 sentences

1976They stem from Farrell v. County of Placer (1944) 23 Cal.2d 624 [ 145 P.2d 570 , 153 A.L.R. 323 ]; in which the court concluded: “In the instant case the facts clearly establish that defendants should be estopped to complain of the late filing of the claim” ( 23 Cal.2d at p. 628 ); and “... the filing of the claim within ninety days, while mandatory upon the claimant and a condition precedent to his cause of action,' is nothing more than a procedural requirement as to the agency, which, as to the claimant, may be excused by estoppel.” (Id., at pp. 630-631.) In Katz v. A. J.

1976They stem from Farrell v. County of Placer (1944) 23 Cal.2d 624 [ 145 P.2d 570 , 153 A.L.R. 323 ]; in which the court concluded: “In the instant case the facts clearly establish that defendants should be estopped to complain of the late filing of the claim” ( 23 Cal.2d at p. 628 ); and “... the filing of the claim within ninety days, while mandatory upon the claimant and a condition precedent to his cause of action,' is nothing more than a procedural requirement as to the agency, which, as to the claimant, may be excused by estoppel.” (Id., at pp. 630-631.) In Katz v. A. J.

11976–1976
People v. Garcia green
cal · 1965
2 sentences

1971Thus in People v. Garcia (1965) 63 Cal.2d 265 [ 46 Cal.Rptr. 324 , 405 P.2d 148 ], a delay of almost a year was justified where the petitioner could "barely write" and read "with difficulty" and where, after being advised that no proper notice of appeal had been filed and that his remedy was to seek appellate court relief, the circumstances of his imprisonment precluded any earlier action than that taken by him.

1971Thus in People v. Garcia (1965) 63 Cal.2d 265 [ 46 Cal.Rptr. 324 , 405 P.2d 148 ], a delay of almost a year was justified where the petitioner could "barely write" and read "with difficulty" and where, after being advised that no proper notice of appeal had been filed and that his remedy was to seek appellate court relief, the circumstances of his imprisonment precluded any earlier action than that taken by him.

11971–1971
People v. Acosta green
cal · 1969
2 sentences

1971We have held generally “that any significant delay between sentencing and the filing of a petition for relief from a late filing under rule 31(a) must be reasonably explained or the doctrines of waiver and estoppel will be invoked to deny relief.” (People v. Acosta, supra, 71 Cal.2d 683 , 690.) Although significant delays between sentencing and the filing of a petition for relief have been justified, in each of such cases the delay has been deemed to have been reasonably explained for one reason or another.

1971We have held generally "that any significant delay between sentencing and the filing of a petition for relief from a late filing under rule 31(a) must be reasonably explained or the doctrines of waiver and estoppel will be invoked to deny relief." ( People v. Acosta, supra, 71 Cal.2d 683 , 690.) Although significant delays between sentencing and the filing of a petition for relief have been justified, in each of such cases the delay has been deemed to have been reasonably explained for one reason or another.

11971–1971
Radar v. Rogers green
cal · 1957
1 sentence

1967We examined a line of decisions said to establish that compliance with such claim statutes "cannot be waived or excused by estoppel," and distinguished each on its facts. *645 Again, in Radar v. Rogers (1957) supra, 49 Cal.2d 243 , this court declined to require strict compliance with a statute very similar to Probate Code section 707.

11967–1967
Artukovich v. Astendorf green
cal · 1942
2 sentences

1966We are necessarily in accord with the viewpoint of the trial judge that the case of Artukovich v. Astendorf, 21 Cal.2d 329 [ 131 P.2d 831 ], requires a holding that after the expiration of one year from the date of the accident the Superior Court of Tuolumne County lacked jurisdiction to require the board of the Sonora Union High School District to permit a late filing of the claim.

1966We are necessarily in accord with the viewpoint of the trial judge that the case of Artukovich v. Astendorf, 21 Cal.2d 329 [ 131 P.2d 831 ], requires a holding that after the expiration of one year from the date of the accident the Superior Court of Tuolumne County lacked jurisdiction to require the board of the Sonora Union High School District to permit a late filing of the claim.

11966–1966
People v. Gustafson green
calctapp · 1942
2 sentences

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

11944–1944
Lucille v. Dodge green
arizctapp · 2000
1 sentence

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

11944–1944
McGee v. City of Los Angeles green
cal · 1936
1 sentence

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

11944–1944
La Societe Francaise De Bienfaisance Mutuelle v. California EmploymentCommission green
calctapp · 1943
2 sentences

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

11944–1944
Hewel v. Hogin green
calctapp · 1906
2 sentences

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

11944–1944
Ernst v. Tiel green
calctapp · 1921
2 sentences

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

1944Com., 56 Cal.App.2d 534 [ 133 P.2d 47 ]; McGee v. City of Los Angeles, 6 Cal.2d 390 [ 5 P.2d 925 ]; Ernst v. Tiel, 51 Cal.App. 747 [ 197 P. 809 ]; People v. Gustafson, 53 Cal.App.2d 230 [ 127 P.2d 627 ]; Hewel v. Hogin, 3 Cal.App. 248 [ 84 P. 1002 ].) It has been aptly said: “If we say with Mr. Justice Holmes, ‘Men must turn square corners when they deal with the Government’, It is hard to see why the government should not be held to a like standard of rectangular rectitude when dealing with its citizens.” (48 Harv.L.Rev. 1299.) In the instant case the facts clearly establish that defendants s

11944–1944

Where else courts name it

NY 26 (1942–2026) CA 11 (1944–2015) NJ 9 (1974–2022) TX 9 (1964–2020) MA 6 (1941–1963) AZ 5 (1976–2010) IL 4 (1996–2001) OR 4 (1958–2000) KY 2 (1974–1983) PA 2 (2018–2019)

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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