ironclad rule (California) · Go Syfert
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ironclad rule in California

9 California opinions name it 2 courts 1950–2013 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 (12)

CaseFollowedCited
Foster v. Fostergreen
cal · 1937 · cited in 3 California opinions naming this issue, 1950–1956
2 sentences

1955However, it has been said that the change of circumstances rule “is not an ironclad rule to which there can be no exceptions.’’ (Cowen v. Cowen, 100 Cal.App.2d 366, 370 [ 223 P.2d 666 ]; Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ].) The welfare and best interests of the children is the all-important consideration in custody cases.

1955However, it has been said that the change of circumstances rule “is not an ironclad rule to which there can be no exceptions.’’ (Cowen v. Cowen, 100 Cal.App.2d 366, 370 [ 223 P.2d 666 ]; Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ].) The welfare and best interests of the children is the all-important consideration in custody cases.

23
Bernstein v. Bernsteingreen
calctapp · 1947 · cited in 2 California opinions naming this issue, 1950–1956
2 sentences

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

22
Hollister Canning Co. v. Superior Courtgreen
calctapp · 1972 · cited in 1 California opinions naming this issue, 1996–1996
2 sentences

1996The addition of ‘s’ to ‘defendant’ in the charging allegations will suffice as long as the complaint does not limit the word ‘defendants’ to those sued by their correct names.” (Hogan, California’s Unique Doe Defendant Practice: A Fiction Stranger Than Truth (1977) 30 Stan.L.Rev. 51, 80, fns. omitted; see Hollister Canning Co. v. Superior Court (1972) 26 Cal.App.3d 186, 194-196 [ 102 Cal.Rptr. 713 ] [charging allegations referring to “defendants” embraced Doe defendants; amendment related back]; Milam v. Dickman Construction Co. (1964) 229 Cal.App.2d 208, 213-214 [ 40 Cal.Rptr. 130 ] [allegati

1996The addition of ‘s’ to ‘defendant’ in the charging allegations will suffice as long as the complaint does not limit the word ‘defendants’ to those sued by their correct names.” (Hogan, California’s Unique Doe Defendant Practice: A Fiction Stranger Than Truth (1977) 30 Stan.L.Rev. 51, 80, fns. omitted; see Hollister Canning Co. v. Superior Court (1972) 26 Cal.App.3d 186, 194-196 [ 102 Cal.Rptr. 713 ] [charging allegations referring to “defendants” embraced Doe defendants; amendment related back]; Milam v. Dickman Construction Co. (1964) 229 Cal.App.2d 208, 213-214 [ 40 Cal.Rptr. 130 ] [allegati

11
Milam v. Dickman Construction Co.green
calctapp · 1964 · cited in 1 California opinions naming this issue, 1996–1996
2 sentences

1996The addition of ‘s’ to ‘defendant’ in the charging allegations will suffice as long as the complaint does not limit the word ‘defendants’ to those sued by their correct names.” (Hogan, California’s Unique Doe Defendant Practice: A Fiction Stranger Than Truth (1977) 30 Stan.L.Rev. 51, 80, fns. omitted; see Hollister Canning Co. v. Superior Court (1972) 26 Cal.App.3d 186, 194-196 [ 102 Cal.Rptr. 713 ] [charging allegations referring to “defendants” embraced Doe defendants; amendment related back]; Milam v. Dickman Construction Co. (1964) 229 Cal.App.2d 208, 213-214 [ 40 Cal.Rptr. 130 ] [allegati

1996The addition of ‘s’ to ‘defendant’ in the charging allegations will suffice as long as the complaint does not limit the word ‘defendants’ to those sued by their correct names.” (Hogan, California’s Unique Doe Defendant Practice: A Fiction Stranger Than Truth (1977) 30 Stan.L.Rev. 51, 80, fns. omitted; see Hollister Canning Co. v. Superior Court (1972) 26 Cal.App.3d 186, 194-196 [ 102 Cal.Rptr. 713 ] [charging allegations referring to “defendants” embraced Doe defendants; amendment related back]; Milam v. Dickman Construction Co. (1964) 229 Cal.App.2d 208, 213-214 [ 40 Cal.Rptr. 130 ] [allegati

11
Marasco v. Wadsworthgreen
cal · 1978 · cited in 1 California opinions naming this issue, 1996–1996
1 sentence

1996The addition of ‘s’ to ‘defendant’ in the charging allegations will suffice as long as the complaint does not limit the word ‘defendants’ to those sued by their correct names.” (Hogan, California’s Unique Doe Defendant Practice: A Fiction Stranger Than Truth (1977) 30 Stan.L.Rev. 51, 80, fns. omitted; see Hollister Canning Co. v. Superior Court (1972) 26 Cal.App.3d 186, 194-196 [ 102 Cal.Rptr. 713 ] [charging allegations referring to “defendants” embraced Doe defendants; amendment related back]; Milam v. Dickman Construction Co. (1964) 229 Cal.App.2d 208, 213-214 [ 40 Cal.Rptr. 130 ] [allegati

11
Pac. Etc. Dev. Corp. v. Western Pac. RR Co.green
cal · 1956 · cited in 1 California opinions naming this issue, 1987–1987
1 sentence

1987Rather, it is reasonably clear from the court's extensive recitation of the facts in its discussion of estoppel, that the decision was based simply on the grounds that the facts did not establish an estoppel. (47 Cal.2d at pp. 70-71.) The equities in favor of the plaintiff brokerage firm were not compelling: it had entered the negotiations late and apparently had contributed little to what Nelson had already accomplished while employed by Fortune Realty; furthermore, as the court noted, "no option to purchase at $2,500 per acre was ever obtained," and finally, there was no unjust enrichment, s

11
Cabell v. John H.green
cal · 1978 · cited in 1 California opinions naming this issue, 1980–1980
2 sentences

1980(Pp. 564-565.) The argument that In re Aline D., supra, 14 Cal.3d 557 , sets forth an ironclad rule that a Youth Authority commitment must invariably be preceded by less restrictive placements, was recently rejected by the California Supreme Court in In re John H. (1978) 21 Cal.3d 18, 27 [ 145 Cal.Rptr. 357 , 557 P.2d 177 ].

1980(Pp. 564-565.) The argument that In re Aline D., supra, 14 Cal.3d 557 , sets forth an ironclad rule that a Youth Authority commitment must invariably be preceded by less restrictive placements, was recently rejected by the California Supreme Court in In re John H. (1978) 21 Cal.3d 18, 27 [ 145 Cal.Rptr. 357 , 557 P.2d 177 ].

11
Peterson v. Petersongreen
calctapp · 1944 · cited in 1 California opinions naming this issue, 1956–1956
2 sentences

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

11
Bemis v. Bemisgreen
calctapp · 1948 · cited in 1 California opinions naming this issue, 1956–1956
2 sentences

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

11
Disney v. Disneygreen
calctapp · 1953 · cited in 1 California opinions naming this issue, 1956–1956
2 sentences

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

1956(Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ] ; Peterson v. Peterson, 64 Cal.App.2d 631, 633 [ 149 P.2d 206 ]; Bemis v. Bemis, 89 Cal.App.2d 80, 91 [ 200 P.2d 84 ]; Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ]; Disney v. Disney, 121 Cal.App.2d 602, 607 [ 263 P.2d 865 ].) The father appeared in and contested the Idaho action.

11
Newman v. Newmangreen
calctapp · 1952 · cited in 1 California opinions naming this issue, 1955–1955
2 sentences

1955(Foster v. Foster, 8 Cal.2d 719 [ 68 P.2d 719 ]; Johnson v. Johnson, 72 Cal.App.2d 721 [ 165 P.2d 552 ]; Newman v. Newman, 109 Cal.App.2d 359 at 360 [ 240 P.2d 682 ].) It is true that Judge Cotton did not follow out the desire expressed in Judge Maushart’s opinion that the -children should be given an opportunity to express an intelligent opinion as to their preference.

1955(Foster v. Foster, 8 Cal.2d 719 [ 68 P.2d 719 ]; Johnson v. Johnson, 72 Cal.App.2d 721 [ 165 P.2d 552 ]; Newman v. Newman, 109 Cal.App.2d 359 at 360 [ 240 P.2d 682 ].) It is true that Judge Cotton did not follow out the desire expressed in Judge Maushart’s opinion that the -children should be given an opportunity to express an intelligent opinion as to their preference.

11
Cowen v. Cowengreen
calctapp · 1950 · cited in 1 California opinions naming this issue, 1955–1955
2 sentences

1955However, it has been said that the change of circumstances rule “is not an ironclad rule to which there can be no exceptions.’’ (Cowen v. Cowen, 100 Cal.App.2d 366, 370 [ 223 P.2d 666 ]; Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ].) The welfare and best interests of the children is the all-important consideration in custody cases.

1955However, it has been said that the change of circumstances rule “is not an ironclad rule to which there can be no exceptions.’’ (Cowen v. Cowen, 100 Cal.App.2d 366, 370 [ 223 P.2d 666 ]; Foster v. Foster, 8 Cal.2d 719, 728 [ 68 P.2d 719 ].) The welfare and best interests of the children is the all-important consideration in custody cases.

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 (10)

CaseCitedYears
Fraley v. Allstate Insurance Company green
calctapp · 2000
1 sentence

2013Co. (2000) 81 Cal.App.4th 1282 , cited by Rick Concrete, does not create such an ironclad rule.

12013–2013
Winding Creek v. McGlashan green
calctapp · 1996
2 sentences

2013The addition of “s” to “defendant” in the charging allegations will suffice as long as the complaint does not limit the word “defendants” to those sued by their correct names.’ [Citations.]” (Winding Creek v. McGlashan (1996) 44 Cal.App.4th 933, 941 , fn. omitted (Winding Creek).) 4 In Winding Creek, “every single cause of action stated in [the original complaint] incorporated by reference plaintiffs’ allegation that ‘. . . each of the fictitiously named Defendants is responsible in some manner for the occurances [sic] herein alleged, and that Plaintiffs’ damages as herein alleged were proxima

2013The addition of “s” to “defendant” in the charging allegations will suffice as long as the complaint does not limit the word “defendants” to those sued by their correct names.’ [Citations.]” (Winding Creek v. McGlashan (1996) 44 Cal.App.4th 933, 941 , fn. omitted (Winding Creek).) 4 In Winding Creek, “every single cause of action stated in [the original complaint] incorporated by reference plaintiffs’ allegation that ‘. . . each of the fictitiously named Defendants is responsible in some manner for the occurances [sic] herein alleged, and that Plaintiffs’ damages as herein alleged were proxima

12013–2013
Barnes v. Wilson green
calctapp · 1974
1 sentence

2013The addition of “s” to “defendant” in the charging allegations will suffice as long as the complaint does not limit the word “defendants” to those sued by their correct names.’ [Citations.]” (Winding Creek v. McGlashan (1996) 44 Cal.App.4th 933, 941 , fn. omitted (Winding Creek).) 4 In Winding Creek, “every single cause of action stated in [the original complaint] incorporated by reference plaintiffs’ allegation that ‘. . . each of the fictitiously named Defendants is responsible in some manner for the occurances [sic] herein alleged, and that Plaintiffs’ damages as herein alleged were proxima

12013–2013
Beazell v. Schrader green
cal · 1963
2 sentences

1987Rather, it is reasonably clear from the court's extensive recitation of the facts in its discussion of estoppel, that the decision was based simply on the grounds that the facts did not establish an estoppel. (47 Cal.2d at pp. 70-71.) The equities in favor of the plaintiff brokerage firm were not compelling: it had entered the negotiations late and apparently had contributed little to what Nelson had already accomplished while employed by Fortune Realty; furthermore, as the court noted, "no option to purchase at $2,500 per acre was ever obtained," and finally, there was no unjust enrichment, s

1987Rather, it is reasonably clear from the court's extensive recitation of the facts in its discussion of estoppel, that the decision was based simply on the grounds that the facts did not establish an estoppel. (47 Cal.2d at pp. 70-71.) The equities in favor of the plaintiff brokerage firm were not compelling: it had entered the negotiations late and apparently had contributed little to what Nelson had already accomplished while employed by Fortune Realty; furthermore, as the court noted, "no option to purchase at $2,500 per acre was ever obtained," and finally, there was no unjust enrichment, s

11987–1987
Franklin v. Hansen green
cal · 1963
2 sentences

1987Rather, it is reasonably clear from the court's extensive recitation of the facts in its discussion of estoppel, that the decision was based simply on the grounds that the facts did not establish an estoppel. (47 Cal.2d at pp. 70-71.) The equities in favor of the plaintiff brokerage firm were not compelling: it had entered the negotiations late and apparently had contributed little to what Nelson had already accomplished while employed by Fortune Realty; furthermore, as the court noted, "no option to purchase at $2,500 per acre was ever obtained," and finally, there was no unjust enrichment, s

1987Rather, it is reasonably clear from the court's extensive recitation of the facts in its discussion of estoppel, that the decision was based simply on the grounds that the facts did not establish an estoppel. (47 Cal.2d at pp. 70-71.) The equities in favor of the plaintiff brokerage firm were not compelling: it had entered the negotiations late and apparently had contributed little to what Nelson had already accomplished while employed by Fortune Realty; furthermore, as the court noted, "no option to purchase at $2,500 per acre was ever obtained," and finally, there was no unjust enrichment, s

11987–1987
Kaiser Foundation Hosp. v. WORKERS'COMP. APPEALS BD. green
cal · 1977
1 sentence

1985Such statutes are intended to afford “finality and predictability in legal affairs, and [to ensure] that claims will be resolved while the evidence bearing on the issues is reasonably available and fresh.” (Kaiser (Webb), supra, 19 Cal.3d at p. 336 .) The related notice statutes (§§ 138.3, 138.4, 5402) demonstrate a legislative decision that the policies underlying the statute of limitations are outweighed when an employer with knowledge of an injury breaches its duty to advise, and the employee is unaware of workers’ compensation.

11985–1985
Kirkpatrick v. Aline D. green
cal · 1975
1 sentence

1980(Pp. 564-565.) The argument that In re Aline D., supra, 14 Cal.3d 557 , sets forth an ironclad rule that a Youth Authority commitment must invariably be preceded by less restrictive placements, was recently rejected by the California Supreme Court in In re John H. (1978) 21 Cal.3d 18, 27 [ 145 Cal.Rptr. 357 , 557 P.2d 177 ].

11980–1980
Johnson v. Johnson green
calctapp · 1946
1 sentence

1955(Foster v. Foster, 8 Cal.2d 719 [ 68 P.2d 719 ]; Johnson v. Johnson, 72 Cal.App.2d 721 [ 165 P.2d 552 ]; Newman v. Newman, 109 Cal.App.2d 359 at 360 [ 240 P.2d 682 ].) It is true that Judge Cotton did not follow out the desire expressed in Judge Maushart’s opinion that the -children should be given an opportunity to express an intelligent opinion as to their preference.

11955–1955
Karahadian v. Lockett neutral
calctapp · 1917
1 sentence

1955(Foster v. Foster, 8 Cal.2d 719 [ 68 P.2d 719 ]; Johnson v. Johnson, 72 Cal.App.2d 721 [ 165 P.2d 552 ]; Newman v. Newman, 109 Cal.App.2d 359 at 360 [ 240 P.2d 682 ].) It is true that Judge Cotton did not follow out the desire expressed in Judge Maushart’s opinion that the -children should be given an opportunity to express an intelligent opinion as to their preference.

11955–1955
Moon v. Moon green
calctapp · 1944
2 sentences

1950(Foster v. Foster, supra, 728 .) In Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ], the court said: “In her brief appellant contended that eases such as Foster v. Foster, 8 Cal.2d 719 [ 68 P.2d 719 ], and Moon v. Moon, 62 Cal.App.2d 185 [ 144 P.2d 596 ], holding that to justify a modification there must be a change of circumstances arising after the original decree was entered, controlled here.

1950(Foster v. Foster, supra, 728 .) In Bernstein v. Bernstein, 80 Cal.App.2d 921, 924 [ 183 P.2d 43 ], the court said: “In her brief appellant contended that eases such as Foster v. Foster, 8 Cal.2d 719 [ 68 P.2d 719 ], and Moon v. Moon, 62 Cal.App.2d 185 [ 144 P.2d 596 ], holding that to justify a modification there must be a change of circumstances arising after the original decree was entered, controlled here.

11950–1950

Where else courts name it

IL 26 (1972–2024) WI 11 (1910–2026) TX 11 (1938–2012) PA 9 (1976–2024) CT 9 (1986–2020) CA 9 (1950–2013) FL 8 (1969–1995) MD 7 (1975–2020) AL 6 (1966–2018) MA 5 (1980–2024) LA 5 (1926–1994) AZ 4 (1993–2008) MO 4 (1908–2018) IA 3 (1978–2016) NJ 3 (1979–2008) AR 3 (2016–2025) MN 3 (1974–2013) NY 3 (1962–1999) WV 2 (2017–2023) IN 2 (1972–1987) ND 2 (2012–2012) MS 2 (1964–2024) OH 2 (1969–2017) WA 2 (1952–2014) UT 2 (2015–2015) TN 2 (2008–2008) GA 2 (2003–2021)

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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