reliance requirement (California) · Go Syfert
← California issues

reliance requirement in California

75 California opinions name it 2 courts 1964–2026 31 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 (35)

CaseFollowedCited
In Re Tobacco II Casesgreen
cal · 2009 · cited in 10 California opinions naming this issue, 2009–2016
2 sentences

2016The appellate court held, “[a] consumer’s burden of pleading causation in a UCL action should hinge on the nature of the alleged wrongdoing rather than the specific prong of the UCL the consumer invokes.” (Durell v. Sharp Healthcare, supra, 183 Cal.App.4th at p. 1363.) It cited the California Supreme Court’s decision in In re Tobacco II Cases (2009) 46 Cal.4th 298 [ 93 Cal.Rptr.3d 559 , 207 P.3d 20 ], which held Business and Professions Code section 17204’s “ ‘as a result of’ ” requirement ‘“imposes an actual reliance requirement on plaintiffs prosecuting a private enforcement action under the

2016The appellate court held, “[a] consumer’s burden of pleading causation in a UCL action should hinge on the nature of the alleged wrongdoing rather than the specific prong of the UCL the consumer invokes.” (Durell v. Sharp Healthcare, supra, 183 Cal.App.4th at p. 1363.) It cited the California Supreme Court’s decision in In re Tobacco II Cases (2009) 46 Cal.4th 298 [ 93 Cal.Rptr.3d 559 , 207 P.3d 20 ], which held Business and Professions Code section 17204’s “ ‘as a result of’ ” requirement ‘“imposes an actual reliance requirement on plaintiffs prosecuting a private enforcement action under the

410
People v. Watsongreen
cal · 1956 · cited in 23 California opinions naming this issue, 2017–2025
2 sentences

2023If the answer to this question is ‘yes,’ then the defendant has not suffered prejudice from the court’s reliance on factors not 8 found true by a jury in selecting the upper term.” (Lopez, supra, 78 Cal.App.5th at p. 467, fn. 11.) If, however, the answer to the question is “no,” then we apply the harmlessness standard in People v. Watson (1956) 46 Cal.2d 818, 836 (Watson), to the trial court’s reliance on impermissible factors.

2023If the answer to this question is ‘yes,’ then the defendant has not suffered prejudice from the court’s reliance on factors not found true by a jury in selecting the upper term.” (Lopez, supra, 78 Cal.App.5th at p. 467, fn. 11.) The Lopez court further stated that if the answer to the first question is “no,” this court must “then consider the second question, which is whether a reviewing court can be certain, to the degree required by People v. Watson (1956) 46 Cal.2d 818, 836 , that the trial court would nevertheless have exercised its discretion to select the upper term if it had recognized

223
Burchard v. Garaygreen
cal · 1986 · cited in 2 California opinions naming this issue, 2023–2023
2 sentences

2023(See Jane J. v. Superior Court (2015) 237 Cal.App.4th 894, 907 [“It is certainly true that one of the key factors the court should address as grounds for modifying custody is the custodial parent’s deliberate efforts to impair the children’s frequent and continuing contacts with the noncustodial 16 parent”]; Burchard v. Garay, supra, 42 Cal.3d at p. 540 [“A custody determination must be based upon a true assessment of the emotional bonds between parent and child”].) Mother does not dispute that the trial court properly relied on several factors in determining that it was not in the children’s

2023(See Jane J. v. Superior Court (2015) 237 Cal.App.4th 894, 907 [“It is certainly true that one of the key factors the court should address as grounds for modifying custody is the custodial parent’s deliberate efforts to impair the children’s frequent and continuing contacts with the noncustodial 16 parent”]; Burchard v. Garay, supra, 42 Cal.3d at p. 540 [“A custody determination must be based upon a true assessment of the emotional bonds between parent and child”].) Mother does not dispute that the trial court properly relied on several factors in determining that it was not in the children’s

22
Jane J. v. Superior Courtgreen
calctapp · 2015 · cited in 2 California opinions naming this issue, 2023–2023
2 sentences

2023(See Jane J. v. Superior Court (2015) 237 Cal.App.4th 894, 907 [“It is certainly true that one of the key factors the court should address as grounds for modifying custody is the custodial parent’s deliberate efforts to impair the children’s frequent and continuing contacts with the noncustodial 16 parent”]; Burchard v. Garay, supra, 42 Cal.3d at p. 540 [“A custody determination must be based upon a true assessment of the emotional bonds between parent and child”].) Mother does not dispute that the trial court properly relied on several factors in determining that it was not in the children’s

2023(See Jane J. v. Superior Court (2015) 237 Cal.App.4th 894, 907 [“It is certainly true that one of the key factors the court should address as grounds for modifying custody is the custodial parent’s deliberate efforts to impair the children’s frequent and continuing contacts with the noncustodial 16 parent”]; Burchard v. Garay, supra, 42 Cal.3d at p. 540 [“A custody determination must be based upon a true assessment of the emotional bonds between parent and child”].) Mother does not dispute that the trial court properly relied on several factors in determining that it was not in the children’s

22
Kwikset Corp. v. Superior Courtgreen
cal · 2011 · cited in 2 California opinions naming this issue, 2014–2016
2 sentences

2016(See Kwikset, supra, 51 Cal.4th at p. 325 [“If a party has alleged or proven a personal, individualized loss of money or property in any nontrivial amount, he or she has also alleged or proven injury in fact.”].) Medrazo has been criticized by some federal district courts because we stated that “an actual reliance requirement does not apply to UCL actions 14 that are not based upon a fraud theory. [Citation.]” (Medrazo, supra, 205 Cal.App.4th at p. 12 .) (See, e.g., Kane v. Chobani, Inc. (N.D.

2016(See Kwikset, supra, 51 Cal.4th at p. 325 [‘“If a party has alleged or proven a personal, individualized loss of money or property in any nontrivial amount, he or she has also alleged or proven injury in fact.”].) Medrazo has been criticized by some federal district courts because we stated that ‘“an actual reliance requirement does not apply to UCL actions that are not based upon a fraud theory. [Citation.]” ( Medrazo, supra, 205 Cal.App.4th at p. 12.) (See, e.g., Kane v. Chobani, Inc. (N.D.Cal. 2014) 973 F.Supp.2d 1120, 1131 , vacated on other grounds in Kane v. Chobani, LLC (9th Cir. 2016)

22
Cunningham v. Californiagreen
scotus · 2007 · cited in 3 California opinions naming this issue, 2007–2024
2 sentences

2024(Black II, at pp. 814–815; see Sandoval, at pp. 850–851.) This court decided Black II and Sandoval in the wake of Cunningham, supra, 549 U.S. 270 , in which the high court held that California’s original DSL violated the Sixth Amendment.

2007On January 22, 2007, after the filing of the reply brief in this case, Cunningham v. California (2007) 549 U.S. ___ [ 166 L.Ed.2d 856 , 127 S.Ct. 856 ] ( Cunningham ), held that imposing an upper term pursuant to California's former determinate sentencing law (DSL) 6 violated the Sixth Amendment right to a jury trial, unless the sentencing court relied on (1) a fact found by a jury beyond a reasonable doubt, (2) a fact admitted by the defendant, or (3) a prior conviction. ( Cunningham , at p. ___ [ 127 S.Ct. at p. 860 ]; cf. Black II, supra , 41 Cal.4th 799 , 816 .) In so doing, the court over

13
Medrazo v. Honda of North Hollywoodgreen
calctapp · 2012 · cited in 3 California opinions naming this issue, 2015–2016
2 sentences

2016(See Kwikset, supra, 51 Cal.4th at p. 325 [“If a party has alleged or proven a personal, individualized loss of money or property in any nontrivial amount, he or she has also alleged or proven injury in fact.”].) Medrazo has been criticized by some federal district courts because we stated that “an actual reliance requirement does not apply to UCL actions 14 that are not based upon a fraud theory. [Citation.]” (Medrazo, supra, 205 Cal.App.4th at p. 12 .) (See, e.g., Kane v. Chobani, Inc. (N.D.

2016(See Kwikset, supra, 51 Cal.4th at p. 325 [‘“If a party has alleged or proven a personal, individualized loss of money or property in any nontrivial amount, he or she has also alleged or proven injury in fact.”].) Medrazo has been criticized by some federal district courts because we stated that ‘“an actual reliance requirement does not apply to UCL actions that are not based upon a fraud theory. [Citation.]” ( Medrazo, supra, 205 Cal.App.4th at p. 12.) (See, e.g., Kane v. Chobani, Inc. (N.D.Cal. 2014) 973 F.Supp.2d 1120, 1131 , vacated on other grounds in Kane v. Chobani, LLC (9th Cir. 2016)

13
Durell v. Sharp Healthcaregreen
calctapp · 2010 · cited in 2 California opinions naming this issue, 2016–2024
2 sentences

2016(See Durell v. Sharp Healthcare (2010) 183 Cal.App.4th 1350, 1363 [the reliance requirement “applies equally to the ‘unlawful’ prong of the UCL when . . . the predicate unlawfulness is misrepresentation and deception.”].) However, in the instant case, the evidence raises a triable issue whether plaintiffs’ reliance on the allegedly deceptive advertising resulted in their economic loss.

2016(See Durell v. Sharp Healthcare (2010) 183 Cal.App.4th 1350, 1363 [ 108 Cal.Rptr.3d 682 ] [the reliance requirement “applies equally to the ‘unlawful’ prong of the UCL when ... the predicate unlawfulness is misrepresentation and deception.”].) However, in the instant case, the evidence raises a triable issue whether plaintiffs’ reliance on the allegedly deceptive advertising resulted in their economic loss.

12
People v. W.B.green
cal · 2012 · cited in 1 California opinions naming this issue, 2024–2024
2 sentences

2024(Id. at pp. 91-96.) And In re W.B. (2012) 55 Cal.4th 30 invalidated a rule that required juvenile courts to apply ICWA to all delinquency proceedings; the rule conflicted with legislative intent because by statute ICWA applied to delinquency proceedings “if the child is at risk of entering foster care or is in foster care.” (Id. at p. 53 (italics omitted); see id. at pp. 53-58 & fn. 17.) The statute did not say “only if.” 16 For all of these reasons, we are not persuaded by the claim that because section 224.2(b) begins with the word “if” instead of the words “only if,” section 224.2(b) impose

2024(Id. at pp. 91-96.) And In re W.B. (2012) 55 Cal.4th 30 invalidated a rule that required juvenile courts to apply ICWA to all delinquency proceedings; the rule conflicted with legislative intent because by statute ICWA applied to delinquency proceedings “if the child is at risk of entering foster care or is in foster care.” (Id. at p. 53 (italics omitted); see id. at pp. 53-58 & fn. 17.) The statute did not say “only if.” 16 For all of these reasons, we are not persuaded by the claim that because section 224.2(b) begins with the word “if” instead of the words “only if,” section 224.2(b) impose

11
In Re Estradagreen
cal · 1965 · cited in 1 California opinions naming this issue, 2022–2022
1 sentence

2022(See In re Estrada (1965) 63 Cal.2d 740, 744-745 [absent evidence of contrary legislative intent, ameliorative criminal statutes apply to all cases not final when the statute takes effect]; see also People v. Woods (2018) 19 Cal.App.5th 1080, 1090-1091 .) In light of the trial court’s reliance on factors in aggravation that were neither admitted by defendant nor found true beyond a reasonable doubt, we must vacate the sentence and remand the matter for resentencing.

11
People v. Woodsgreen
calctapp5d · 2018 · cited in 1 California opinions naming this issue, 2022–2022
1 sentence

2022(See In re Estrada (1965) 63 Cal.2d 740, 744-745 [absent evidence of contrary legislative intent, ameliorative criminal statutes apply to all cases not final when the statute takes effect]; see also People v. Woods (2018) 19 Cal.App.5th 1080, 1090-1091 .) In light of the trial court’s reliance on factors in aggravation that were neither admitted by defendant nor found true beyond a reasonable doubt, we must vacate the sentence and remand the matter for resentencing.

11
People v. Hernandezgreen
cal · 2011 · cited in 1 California opinions naming this issue, 2017–2017
2 sentences

2017However, its remarks were, at most, post hoc justifications for adhering to a generic policy. ( Ibid . ) This reliance on a standard policy was an abuse of discretion but reversal was not required because the error was harmless under People v. Watson (1956) 46 Cal.2d 818 , 299 P.2d 243 . ( Hernandez , at pp. 744, 746, 121 Cal.Rptr.3d 103 , 247 P.3d 167 .) Here, the court devoted considerable time and attention to the issue.

2017However, its remarks were, at most, post hoc justifications for adhering to a generic policy. ( Ibid . ) This reliance on a standard policy was an abuse of discretion but reversal was not required because the error was harmless under People v. Watson (1956) 46 Cal.2d 818 , 299 P.2d 243 . ( Hernandez , at pp. 744, 746, 121 Cal.Rptr.3d 103 , 247 P.3d 167 .) Here, the court devoted considerable time and attention to the issue.

11
Buller v. Sutter Healthgreen
calctapp · 2008 · cited in 1 California opinions naming this issue, 2014–2014
2 sentences

2014(Wilson v. Hynek, supra, 207 Cal.App.4th at p. 1008 .) D The fraud prong of the UCL may be shown if members of the public are “ ‘ “likely to be deceived.” ’ ” (Buller v. Sutter Health (2008) 160 Cal.App.4th 981, 986 [ 74 Cal.Rptr.3d 47 ].) However, “ ‘[a]bsent a duty to disclose, the failure to do so does not support a claim under the fraudulent *614 prong of the UCL.’ ” (Id. at p. 987.) Additionally, the UCL “imposes an actual reliance requirement on plaintiffs prosecuting a private enforcement action under the UCL’s fraud prong.” (In re Tobacco II Cases (2009) 46 Cal.4th 298, 326 [ 93 Cal.Rp

2014(Wilson v. Hynek, supra, 207 Cal.App.4th at p. 1008 .) D The fraud prong of the UCL may be shown if members of the public are “ ‘ “likely to be deceived.” ’ ” (Buller v. Sutter Health (2008) 160 Cal.App.4th 981, 986 [ 74 Cal.Rptr.3d 47 ].) However, “ ‘[a]bsent a duty to disclose, the failure to do so does not support a claim under the fraudulent *614 prong of the UCL.’ ” (Id. at p. 987.) Additionally, the UCL “imposes an actual reliance requirement on plaintiffs prosecuting a private enforcement action under the UCL’s fraud prong.” (In re Tobacco II Cases (2009) 46 Cal.4th 298, 326 [ 93 Cal.Rp

11
San Diego County Health & Human Services Agency v. Mary M.green
calctapp · 2011 · cited in 1 California opinions naming this issue, 2014–2014
11
In re Shaputisgreen
cal · 2008 · cited in 1 California opinions naming this issue, 2010–2010
11
Milton v. H. C. Stone Lumber Co.green
ilsd · 1928 · cited in 1 California opinions naming this issue, 2010–2010
11
Durkee v. Chino Land and Water Co.green
cal · 1907 · cited in 1 California opinions naming this issue, 2010–2010
11
Panopulos v. Maderisgreen
cal · 1956 · cited in 1 California opinions naming this issue, 2010–2010
11
People v. Coopergreen
cal · 2002 · cited in 1 California opinions naming this issue, 2009–2009
11
Outboard Marine Corp. v. Superior Courtgreen
calctapp · 1975 · cited in 1 California opinions naming this issue, 2007–2007
11
Nagel v. Twin Laboratories, Inc.green
calctapp · 2003 · cited in 1 California opinions naming this issue, 2007–2007
11
PEOPLR v. Albrittongreen
calctapp · 1998 · cited in 1 California opinions naming this issue, 2002–2002
11
Ginns v. Savagegreen
cal · 1964 · cited in 1 California opinions naming this issue, 2002–2002
11
Quinn v. State of Californiagreen
cal · 1975 · cited in 1 California opinions naming this issue, 1990–1990
11
United States v. Pricegreen
scotus · 1960 · cited in 1 California opinions naming this issue, 1990–1990
11
Lesny Development Co. v. Kendallgreen
calctapp · 1985 · cited in 1 California opinions naming this issue, 1989–1989
11
Puritan Leasing Co. v. Superior Courtgreen
calctapp · 1977 · cited in 1 California opinions naming this issue, 1989–1989
11
People v. McDonaldgreen
cal · 1984 · cited in 1 California opinions naming this issue, 1988–1988
11
People v. Warnergreen
cal · 1978 · cited in 1 California opinions naming this issue, 1987–1987
11
People v. Caudillored
cal · 1978 · cited in 1 California opinions naming this issue, 1982–1982
11
Billings v. Edwardsgreen
calctapp · 1979 · cited in 1 California opinions naming this issue, 1981–1981
11
Hocharian v. Superior Courtgreen
cal · 1981 · cited in 1 California opinions naming this issue, 1981–1981
11
Winters v. New Yorkgreen
scotus · 1948 · cited in 1 California opinions naming this issue, 1977–1977
11
People v. Perezgreen
cal · 1965 · cited in 1 California opinions naming this issue, 1966–1966
11
People v. Snydergreen
cal · 1958 · cited in 1 California opinions naming this issue, 1964–1964
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 (34)

CaseCitedYears
Rand v. American National Insurance green
cand · 2010
2 sentences

2015As plaintiffs have argued, inserting a reliance requirement in this setting would have subverted the purpose of the law and encourage rather than “‘suppress the mischief at which [the statute] is directed.’” (Rand, supra, 717 F.Supp.2d at p. 957 .) The same situation does not exist here, however.

2015As plaintiffs have argued, inserting a reliance requirement in this setting would have subverted the purpose of the law and encourage rather than “‘suppress the mischief at which [the statute] is directed.’” (Rand, supra, 717 F.Supp.2d at p. 957 .) The same situation does not exist here, however.

22015–2015
Cattie v. Wal-Mart Stores, Inc. green
casd · 2007
2 sentences

2010This is a case in which the “concept of reliance” unequivocally applies (Tobacco II, supra, 46 Cal.4th at p. 325, fn. 17 ), and omitting an actual reliance requirement when the defendant’s alleged misrepresentation has not deceived the plaintiff “would blunt Proposition 64’s intended reforms” (Cattie v. Wal-Mart Stores, Inc. (S.D.Cal. 2007) 504 F.Supp.2d 939, 948 ).

2008Plaintiffs lack standing to bring their UCL and [false advertising law] claims.” (Ibid.) In Cattie v. Wal-Mart Stores, Inc. (S.D.Cal. 2007) 504 F.Supp.2d 939, 948 , the district court concluded that omitting a reliance requirement for standing to bring a UCL claim would “undermine Proposition 64’s reform purposes.” The plaintiff’s UCL claim alleged the thread count of the bed linens she purchased from the defendants’ Web site was lower than advertised. ( 504 F.Supp.2d at p. 941 .) The plaintiff purchased one set of bedsheets 11 days before filing the lawsuit and did not allege she relied on an

22008–2010
Johnson v. United States green
scotus · 1943
2 sentences

1965In Johnson v. United States, 318 U.S. 189 [ 63 S.Ct. 549 , 87 L.Ed. 704 ], the court held that comment on the defendant's reliance on his privilege against self- incrimination was error, but failed to reverse because the error had been waived.

1965In Johnson v. United States, supra, 318 U.S. 189 , the court held that comment on the defendant’s reliance on his privilege against self-incrimination was error, but failed to reverse because the error had been waived.

21965–1965
Adams v. Commission on Judicial Performance green
cal · 1995
1 sentence

2026(See Adams v. Commission on Judicial Performance (1995) 10 Cal.4th 866 , 907–908 [it is a violation of the canons of judicial ethics for a judge to help litigants prepare their cases].) This is so even though Mother was not represented by counsel at the hearing.

12026–2026
San Francisco Apartment Ass'n v. City & County of San Francisco green
calctapp · 2016
1 sentence

2025(See ibid. [discussing San Francisco Apartment, supra, 3 Cal.App.5th at p. 472 ].) Although the appellate court disposed of the challenge by concluding the organization did not fail the associational interest test, City of Pomona does not stand for the affirmative proposition that to merit public interest standing an organization must show its members satisfy the requirements for associational standing.

12025–2025
Citizens for Amending Proposition v. City of Pomona green
calctapp5d · 2018
1 sentence

2025(See ibid. [discussing San Francisco Apartment, supra, 3 Cal.App.5th at p. 472 ].) Although the appellate court disposed of the challenge by concluding the organization did not fail the associational interest test, City of Pomona does not stand for the affirmative proposition that to merit public interest standing an organization must show its members satisfy the requirements for associational standing.

12025–2025
Alvarez v. Seaside Transp. Servs. LLC green
calctapp5d · 2017
1 sentence

2023(Alvarez, supra, 13 Cal.App.5th at p. 644 .) This rationale applies regardless of whether the complaint pleads the existence of an exception to Privette or the plaintiff’s reliance on an exception is revealed in subsequent discovery responses.

12023–2023
Chapman v. California red
scotus · 1967
1 sentence

2022If the answer to both of these questions is ‘no,’ then it is clear that remand to the trial court for resentencing is necessary.” (Ibid.) 15 In Dunn, the court agreed “with Lopez on the majority of the standard it articulated,” but concluded only “one aggravating circumstance must be reviewed pursuant to [Chapman v. California (1967) 386 U.S. 18 ].” (Dunn, supra, 81 Cal.App.5th at pp. 408, 409.) It held, “the remaining aggravating circumstances involve only a state-created right to a jury trial that must be reviewed pursuant to Watson.” (Ibid.) Likewise, in Zabelle, the court agreed with Lopez

12022–2022
People v. Peoples green
cal · 2016
1 sentence

2020In arguing in favor of a transfer to Sonoma County, the Attorney General relies on the Supreme Court’s decision in People v. Peoples (2016) 62 Cal.4th 718 .

12020–2020
Yu v. Signet Bank/Virginia green
calctapp · 2002
1 sentence

2017It declared the trial court's decision "untenable," and held that law of the case barred the defendants from contending Barquis was wrongly decided. ( Id . at p. 310, 126 Cal.Rptr.2d 516 .) The court reasoned that its first opinion had "necessarily determined that the Yus had stated a cause of action for abuse of process, and that Barquis remained good law." ( Ibid . ) The Yu court rejected the defendants' reliance on the rule that law of the case does not extend to issues that might have been but were not raised on a prior appeal.

12017–2017
Kane v. Chobani, Inc. green
cand · 2014
2 sentences

2016Cal. 2014) 973 F.Supp.2d 1120, 1131 , vacated on other grounds by Kane v. Chobani, LLC (9th Cir. 2016) 645 Fed.Appx. 593 [“Medrazo contains no discussion of Kwikset’s statement that the actual reliance requirement applies to claims under the unlawful prong of the UCL where the alleged unlawful conduct is based on a statute that prohibits specific types of misrepresentations.”]; De Keczer v. Tetley USA, Inc. (N.D.Cal.

2016(See Kwikset, supra, 51 Cal.4th at p. 325 [‘“If a party has alleged or proven a personal, individualized loss of money or property in any nontrivial amount, he or she has also alleged or proven injury in fact.”].) Medrazo has been criticized by some federal district courts because we stated that ‘“an actual reliance requirement does not apply to UCL actions that are not based upon a fraud theory. [Citation.]” ( Medrazo, supra, 205 Cal.App.4th at p. 12.) (See, e.g., Kane v. Chobani, Inc. (N.D.Cal. 2014) 973 F.Supp.2d 1120, 1131 , vacated on other grounds in Kane v. Chobani, LLC (9th Cir. 2016)

12016–2016
Katie Kane v. Chobani, LLC green
ca9 · 2016
2 sentences

2016Cal. 2014) 973 F.Supp.2d 1120, 1131 , vacated on other grounds by Kane v. Chobani, LLC (9th Cir. 2016) 645 Fed.Appx. 593 [“Medrazo contains no discussion of Kwikset’s statement that the actual reliance requirement applies to claims under the unlawful prong of the UCL where the alleged unlawful conduct is based on a statute that prohibits specific types of misrepresentations.”]; De Keczer v. Tetley USA, Inc. (N.D.Cal.

2016(See Kwikset, supra, 51 Cal.4th at p. 325 [‘“If a party has alleged or proven a personal, individualized loss of money or property in any nontrivial amount, he or she has also alleged or proven injury in fact.”].) Medrazo has been criticized by some federal district courts because we stated that ‘“an actual reliance requirement does not apply to UCL actions that are not based upon a fraud theory. [Citation.]” ( Medrazo, supra, 205 Cal.App.4th at p. 12.) (See, e.g., Kane v. Chobani, Inc. (N.D.Cal. 2014) 973 F.Supp.2d 1120, 1131 , vacated on other grounds in Kane v. Chobani, LLC (9th Cir. 2016)

12016–2016
Lueras v. BAC Home Loans Servicing, LP green
calctapp · 2013
1 sentence

2016Also, as discussed above, the UCL’s fraud prong generally “‘require[s] . . . a showing that members of the public are likely to be deceived.’” (Lueras v. BAC Home Loans Servicing, LP (2013) 221 Cal.App.4th 49, 81 .) To establish a private party’s 18 standing to maintain a UCL cause of action under the fraud prong In re Tobacco II Cases, supra, 46 Cal.4th 298 , held the phrase “as a result of” appearing in Business and Professions Code section 17204 “imposes an actual reliance requirement on plaintiffs prosecuting a private enforcement action under the UCL’s fraud prong.” (In re Tobacco II Case

12016–2016
Cadlo v. Owens-Illinois, Inc. green
calctapp · 2004
2 sentences

2015(Belasco, supra, 234 Cal.App.4th at p. 424 ; Cadlo, supra, 125 Cal.App.4th at p. 519 .) “ ‘Several courts have held that class certification is inappropriate where a putative class representative is subject to unique defenses which threaten to become the focus of the litigation.’ ” (Seastrom v. Neways, Inc. (2007) 149 Cal.App.4th 1496, 1502 .) Because plaintiff knew he had been the victim of identity theft and knew he did not owe a fine, it appears plaintiff may be subject to a reliance defense that is “unavailable or less available against other class members.” (Id. at p. 1503.) We need not a

2015(Belasco, supra, 234 Cal.App.4th at p. 424 ; Cadlo, supra, 125 Cal.App.4th at p. 519 .) “ ‘Several courts have held that class certification is inappropriate where a putative class representative is subject to unique defenses which threaten to become the focus of the litigation.’ ” (Seastrom v. Neways, Inc. (2007) 149 Cal.App.4th 1496, 1502 .) Because plaintiff knew he had been the victim of identity theft and knew he did not owe a fine, it appears plaintiff may be subject to a reliance defense that is “unavailable or less available against other class members.” (Id. at p. 1503.) We need not a

12015–2015
SEASTROM v. Neways, Inc. green
calctapp · 2007
1 sentence

2015(Belasco, supra, 234 Cal.App.4th at p. 424 ; Cadlo, supra, 125 Cal.App.4th at p. 519 .) “ ‘Several courts have held that class certification is inappropriate where a putative class representative is subject to unique defenses which threaten to become the focus of the litigation.’ ” (Seastrom v. Neways, Inc. (2007) 149 Cal.App.4th 1496, 1502 .) Because plaintiff knew he had been the victim of identity theft and knew he did not owe a fine, it appears plaintiff may be subject to a reliance defense that is “unavailable or less available against other class members.” (Id. at p. 1503.) We need not a

12015–2015
Belasco v. Wells green
calctapp · 2015
1 sentence

2015(Belasco, supra, 234 Cal.App.4th at p. 424 ; Cadlo, supra, 125 Cal.App.4th at p. 519 .) “ ‘Several courts have held that class certification is inappropriate where a putative class representative is subject to unique defenses which threaten to become the focus of the litigation.’ ” (Seastrom v. Neways, Inc. (2007) 149 Cal.App.4th 1496, 1502 .) Because plaintiff knew he had been the victim of identity theft and knew he did not owe a fine, it appears plaintiff may be subject to a reliance defense that is “unavailable or less available against other class members.” (Id. at p. 1503.) We need not a

12015–2015
Wilson v. Hynek green
calctapp · 2012
1 sentence

2014(Wilson v. Hynek, supra, 207 Cal.App.4th at p. 1008 .) D The fraud prong of the UCL may be shown if members of the public are “ ‘ “likely to be deceived.” ’ ” (Buller v. Sutter Health (2008) 160 Cal.App.4th 981, 986 [ 74 Cal.Rptr.3d 47 ].) However, “ ‘[a]bsent a duty to disclose, the failure to do so does not support a claim under the fraudulent *614 prong of the UCL.’ ” (Id. at p. 987.) Additionally, the UCL “imposes an actual reliance requirement on plaintiffs prosecuting a private enforcement action under the UCL’s fraud prong.” (In re Tobacco II Cases (2009) 46 Cal.4th 298, 326 [ 93 Cal.Rp

12014–2014
Kowis v. Howard green
cal · 1992
12013–2013
Pacific Coast Engineering Company, a Corporation v. Merritt-Chapman & Scott Corporation, a Corporation green
ca9 · 1969
12010–2010
Milton v. H. C. Stone Lumber Co. neutral
ca7 · 1929
12010–2010
People v. Black red
cal · 2005
12007–2007
Vasquez v. Superior Court red
cal · 1971
12007–2007
Anunziato v. eMachines, Inc. green
cacd · 2005
12007–2007
People v. Black green
cal · 2007
12007–2007
Nagel v. Twin Laboratories, Inc. green
calctapp · 2003
12007–2007
People v. Ramos green
cal · 1997
12006–2006
People v. Smith green
cal · 2005
12006–2006
Abdul-Majeed v. Emory University Hospital green
gactapp · 1994
12002–2002
People v. Wandick green
calctapp · 1991
12001–2001
Sonbergh v. MacQuarrie green
calctapp · 1952
11991–1991
Pugh v. See's Candies, Inc. green
calctapp · 1981
11989–1989
People v. Cole green
cal · 1956
11988–1988
People v. Bolton green
cal · 1979
11987–1987
People v. Johnson green
calctapp · 1980
11982–1982

Statutes the citing opinions construe

CA § Cal. Civil Code § 1750 (10) CA § Cal. Evidence Code § 352 (7) CA § Cal. Civil Code § 1770 (6) CA § Cal. Civil Code § 1780 (6) CA § Cal. Evidence Code § 1101 (6) CA § Cal. Civil Code § 1641 (5) CA § Cal. Civil Code § 1644 (5) CA § Cal. Business and Professions Code § 17200 (4) CA § Cal. Civil Code § 1670.5 (4) CA § Cal. Vehicle Code § 23152 (4) CA § Cal. Evidence Code § 210 (3) CA § Cal. Vehicle Code § 2800.2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 75 (1964–2026) NY 30 (1906–2025) IL 26 (1977–2024) PA 23 (1980–2025) TX 18 (1978–2022) WA 18 (1986–2026) AL 16 (1991–2025) CT 15 (1995–2024) MA 14 (1960–2025) MD 14 (1969–2024) FL 14 (1973–2020) NJ 12 (1981–2022) WI 11 (1985–2025) MI 9 (1978–2024) UT 8 (1995–2026) GA 8 (1978–2026) OH 8 (1966–2018) AZ 7 (1973–2020) DC 7 (1979–2022) LA 7 (1985–2017) VT 6 (1967–2018) NM 6 (2000–2021) NC 6 (1986–2020) ID 6 (1979–2021) NE 5 (1988–2024) AK 5 (1976–1989) OR 5 (2001–2012) MN 5 (1971–2017) CO 5 (1994–2026) TN 4 (1995–2014) NV 4 (1957–2014) IA 4 (2006–2018) WV 4 (1980–2017) RI 4 (2002–2023) IN 4 (1978–2023) VA 4 (2008–2018) MO 3 (1966–2017) KS 3 (1972–2008) MS 2 (2007–2007) HI 2 (1996–2017) KY 2 (2011–2026) SC 2 (2000–2011) SD 2 (2004–2009) VI 2 (2009–2011) ME 2 (2007–2012) ND 2 (1976–2018) NH 2 (1997–2005)

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.

← Caselaw search · G Cite Topics · Brief Check