Fowler doctrine (California) · Go Syfert
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Fowler doctrine in California

8 California opinions name it 1 courts 1978–2026 1 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 (9)

CaseFollowedCited
DaFonte v. Up-Right, Inc.green
cal · 1992 · cited in 1 California opinions naming this issue, 2026–2026
1 sentence

2026Supp. 25-29; Gutierrez v. Carmax Auto Superstores California (2018) 19 Cal.App.5th 1234, 1249 [first question for statutory interpretation is whether the language is susceptible to more than one reasonable interpretation]; DaFonte v. Up-Right, Inc. (1992) 2 Cal.4th 593, 601 (DaFonte) [“When ‘ “statutory language is . . . clear and unambiguous there is no need for construction, and courts should not indulge in it.” ’ ”].) But this record does not show that the parties presented competing statutory interpretations of sections 96 and 97 to the trial court, nor does it show that the trial court fo

11
Gutierrez v. Carmax Auto Superstores Cal.green
calctapp5d · 2018 · cited in 1 California opinions naming this issue, 2026–2026
1 sentence

2026Supp. 25-29; Gutierrez v. Carmax Auto Superstores California (2018) 19 Cal.App.5th 1234, 1249 [first question for statutory interpretation is whether the language is susceptible to more than one reasonable interpretation]; DaFonte v. Up-Right, Inc. (1992) 2 Cal.4th 593, 601 (DaFonte) [“When ‘ “statutory language is . . . clear and unambiguous there is no need for construction, and courts should not indulge in it.” ’ ”].) But this record does not show that the parties presented competing statutory interpretations of sections 96 and 97 to the trial court, nor does it show that the trial court fo

11
Berman v. Bromberggreen
calctapp · 1997 · cited in 1 California opinions naming this issue, 2014–2014
2 sentences

2014(See Bedolla v. Logan & Frazer (1975) 52 Cal.App.3d 118, 135-136 [ 125 Cal.Rptr. 59 ] [noting that “[w]hile under section 473 of the Code of Civil Procedure and the case authorities pertaining thereto the trial court has wide discretion in allowing the amendment of any pleading [citations], as a matter of policy the ruling of the trial court in such matters will be upheld unless a manifest or gross abuse of discretion is shown . . .”]; see also Berman v. Bromberg (1997) 56 Cal.App.4th 936 , 945 *271 [ 65 Cal.Rptr.2d 777 ] [noting a court should grant a motion to amend a pleading to state a leg

2014(See Bedolla v. Logan & Frazer (1975) 52 Cal.App.3d 118, 135-136 [ 125 Cal.Rptr. 59 ] [noting that “[w]hile under section 473 of the Code of Civil Procedure and the case authorities pertaining thereto the trial court has wide discretion in allowing the amendment of any pleading [citations], as a matter of policy the ruling of the trial court in such matters will be upheld unless a manifest or gross abuse of discretion is shown . . .”]; see also Berman v. Bromberg (1997) 56 Cal.App.4th 936 , 945 *271 [ 65 Cal.Rptr.2d 777 ] [noting a court should grant a motion to amend a pleading to state a leg

11
Janken v. GM Hughes Electronicsgreen
calctapp · 1996 · cited in 1 California opinions naming this issue, 2014–2014
2 sentences

2014Intentional infliction of emotional distress To successfully resist a motion for summary judgment on a claim for intentional infliction of emotional distress, a plaintiff must provide evidence of “conduct beyond the bounds of human decency.” (Janken v. GM Hughes Electronics (1996) 46 Cal.App.4th 55, 80 (Janken).) Summary adjudication of Fowler’s claim for intentional infliction of emotional distress was proper because Fowler failed to introduce any evidence of 13 “extreme and outrageous” conduct by Cedars.

2014A simple pleading of personnel management activity is insufficient to support a claim of intentional infliction of emotional distress.” (Janken, supra, 46 Cal.App.4th at p. 80 .) The trial court did not err by summarily adjudicating Fowler’s claim for intentional infliction of emotional distress in favor of Cedars.

11
Bedolla v. Logan & Frazergreen
calctapp · 1975 · cited in 1 California opinions naming this issue, 2014–2014
2 sentences

2014(See Bedolla v. Logan & Frazer (1975) 52 Cal.App.3d 118, 135-136 [ 125 Cal.Rptr. 59 ] [noting that “[w]hile under section 473 of the Code of Civil Procedure and the case authorities pertaining thereto the trial court has wide discretion in allowing the amendment of any pleading [citations], as a matter of policy the ruling of the trial court in such matters will be upheld unless a manifest or gross abuse of discretion is shown . . .”]; see also Berman v. Bromberg (1997) 56 Cal.App.4th 936 , 945 *271 [ 65 Cal.Rptr.2d 777 ] [noting a court should grant a motion to amend a pleading to state a leg

2014(See Bedolla v. Logan & Frazer (1975) 52 Cal.App.3d 118, 135-136 [ 125 Cal.Rptr. 59 ] [noting that “[w]hile under section 473 of the Code of Civil Procedure and the case authorities pertaining thereto the trial court has wide discretion in allowing the amendment of any pleading [citations], as a matter of policy the ruling of the trial court in such matters will be upheld unless a manifest or gross abuse of discretion is shown . . .”]; see also Berman v. Bromberg (1997) 56 Cal.App.4th 936 , 945 *271 [ 65 Cal.Rptr.2d 777 ] [noting a court should grant a motion to amend a pleading to state a leg

11
People v. Coffmangreen
cal · 2004 · cited in 1 California opinions naming this issue, 2014–2014
2 sentences

2014In Fowler, unlike the present case, the court instructed the jury, “ ‘The testimony of an accomplice which tends to incriminate the other in the offense for which they are on trial should be viewed with distrust.’ ” (Fowler, at p. 85, italics added.) Coffman characterized the Fowler instruction as one “to distrust everything an accomplice-defendant testified to.” (Coffman, supra, 34 Cal.4th at p. 105, fn. 37 , italics added.) The CALCRIM No. 334 instruction used in the present case did not refer to “distrust” and the instruction contained two additional explanatory sentences not found in the F

2014In Fowler, unlike the present case, the court instructed the jury, “ ‘The testimony of an accomplice which tends to incriminate the other in the offense for which they are on trial should be viewed with distrust.’ ” (Fowler, at p. 85, italics added.) Coffman characterized the Fowler instruction as one “to distrust everything an accomplice-defendant testified to.” (Coffman, supra, 34 Cal.4th at p. 105, fn. 37 , italics added.) The CALCRIM No. 334 instruction used in the present case did not refer to “distrust” and the instruction contained two additional explanatory sentences not found in the F

11
People v. Lawsongreen
calctapp · 1980 · cited in 1 California opinions naming this issue, 1995–1995
2 sentences

1995Former rule 425(a)(4) provided, as a criterion affecting concurrent or consecutive sentences, the fact that “Any of the crimes involved multiple victims.” Although People v. Lawson (1980) 107 Cal.App.3d 748, 758 [ 165 Cal.Rptr. 764 ], is cited in some opinions as rejecting the “transactionally related” analysis, it actually supported it in that it held, “The [trial] court may not find that the crime at issue . . . involved multiple victims ... by adding victim(s) from independent crimes.” (Italics added.) In People v. Leung (1992) 5 Cal.App.4th 482, 503 [ 7 Cal.Rptr.2d 290 ], the Sixth Distric

1995Former rule 425(a)(4) provided, as a criterion affecting concurrent or consecutive sentences, the fact that “Any of the crimes involved multiple victims.” Although People v. Lawson (1980) 107 Cal.App.3d 748, 758 [ 165 Cal.Rptr. 764 ], is cited in some opinions as rejecting the “transactionally related” analysis, it actually supported it in that it held, “The [trial] court may not find that the crime at issue . . . involved multiple victims ... by adding victim(s) from independent crimes.” (Italics added.) In People v. Leung (1992) 5 Cal.App.4th 482, 503 [ 7 Cal.Rptr.2d 290 ], the Sixth Distric

11
People v. Leunggreen
calctapp · 1992 · cited in 1 California opinions naming this issue, 1995–1995
2 sentences

1995Former rule 425(a)(4) provided, as a criterion affecting concurrent or consecutive sentences, the fact that “Any of the crimes involved multiple victims.” Although People v. Lawson (1980) 107 Cal.App.3d 748, 758 [ 165 Cal.Rptr. 764 ], is cited in some opinions as rejecting the “transactionally related” analysis, it actually supported it in that it held, “The [trial] court may not find that the crime at issue . . . involved multiple victims ... by adding victim(s) from independent crimes.” (Italics added.) In People v. Leung (1992) 5 Cal.App.4th 482, 503 [ 7 Cal.Rptr.2d 290 ], the Sixth Distric

1995Former rule 425(a)(4) provided, as a criterion affecting concurrent or consecutive sentences, the fact that “Any of the crimes involved multiple victims.” Although People v. Lawson (1980) 107 Cal.App.3d 748, 758 [ 165 Cal.Rptr. 764 ], is cited in some opinions as rejecting the “transactionally related” analysis, it actually supported it in that it held, “The [trial] court may not find that the crime at issue . . . involved multiple victims ... by adding victim(s) from independent crimes.” (Italics added.) In People v. Leung (1992) 5 Cal.App.4th 482, 503 [ 7 Cal.Rptr.2d 290 ], the Sixth Distric

11
People v. Terrygreen
cal · 1970 · cited in 1 California opinions naming this issue, 1987–1987
1 sentence

1987To instruct a jury to regard a defendant’s testimony with distrust is prohibited by the rule announced in People v. Terry, supra, 2 Cal.3d 362, 399; People v. Gurule, supra, 236 Cal.App.2d 847, 855 ; and People v. Arends, supra, 155 Cal.App.2d 496, 513 .

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 (9)

CaseCitedYears
Sierra Managed Asset Plan, LLC v. Hale green
calappdeptsuper · 2015
1 sentence

2026We conclude that Sierra Managed Asset Plan, LLC v. Hale (2015) 240 Cal.App.4th Supp. 1 (Sierra) and Midland Funding LLC v. Romero (2016) 5 Cal.App.5th Supp. 1 (Midland) are better reasoned than Unifund CCR, LLC v. Dear (2015) 243 Cal.App.4th Supp. 1 (Unifund).

12026–2026
Unifund CCR, LLC v. Dear green
calappdeptsuper · 2015
1 sentence

2026We conclude that Sierra Managed Asset Plan, LLC v. Hale (2015) 240 Cal.App.4th Supp. 1 (Sierra) and Midland Funding LLC v. Romero (2016) 5 Cal.App.5th Supp. 1 (Midland) are better reasoned than Unifund CCR, LLC v. Dear (2015) 243 Cal.App.4th Supp. 1 (Unifund).

12026–2026
Midland Funding LLC v. Romero green
calappdeptsuper · 2016
1 sentence

2026We conclude that Sierra Managed Asset Plan, LLC v. Hale (2015) 240 Cal.App.4th Supp. 1 (Sierra) and Midland Funding LLC v. Romero (2016) 5 Cal.App.5th Supp. 1 (Midland) are better reasoned than Unifund CCR, LLC v. Dear (2015) 243 Cal.App.4th Supp. 1 (Unifund).

12026–2026
Rancho Viejo v. TRES AMIGOS VIEJOS green
calctapp · 2002
2 sentences

2014(See Bedolla v. Logan & Frazer (1975) 52 Cal.App.3d 118, 135-136 [ 125 Cal.Rptr. 59 ] [noting that “[w]hile under section 473 of the Code of Civil Procedure and the case authorities pertaining thereto the trial court has wide discretion in allowing the amendment of any pleading [citations], as a matter of policy the ruling of the trial court in such matters will be upheld unless a manifest or gross abuse of discretion is shown . . .”]; see also Berman v. Bromberg (1997) 56 Cal.App.4th 936 , 945 *271 [ 65 Cal.Rptr.2d 777 ] [noting a court should grant a motion to amend a pleading to state a leg

2014(See Bedolla v. Logan & Frazer (1975) 52 Cal.App.3d 118, 135-136 [ 125 Cal.Rptr. 59 ] [noting that “[w]hile under section 473 of the Code of Civil Procedure and the case authorities pertaining thereto the trial court has wide discretion in allowing the amendment of any pleading [citations], as a matter of policy the ruling of the trial court in such matters will be upheld unless a manifest or gross abuse of discretion is shown . . .”]; see also Berman v. Bromberg (1997) 56 Cal.App.4th 936 , 945 *271 [ 65 Cal.Rptr.2d 777 ] [noting a court should grant a motion to amend a pleading to state a leg

12014–2014
Hughes v. Pair green
cal · 2009
1 sentence

2014(Hughes v. Pair (2009) 46 Cal.4th 1035, 1050 .) Cedars’s decision to place Fowler on unpaid leave in November of 2009 and informing the Employment Development Department that she was on a leave of absence in response to a claim for unemployment benefits in the summer of 2001 were personnel management actions that do not support a claim for intentional infliction of emotional distress.

12014–2014
People v. Gurule green
calctapp · 1965
1 sentence

1987To instruct a jury to regard a defendant’s testimony with distrust is prohibited by the rule announced in People v. Terry, supra, 2 Cal.3d 362, 399; People v. Gurule, supra, 236 Cal.App.2d 847, 855 ; and People v. Arends, supra, 155 Cal.App.2d 496, 513 .

11987–1987
People v. Arends green
calctapp · 1957
1 sentence

1987To instruct a jury to regard a defendant’s testimony with distrust is prohibited by the rule announced in People v. Terry, supra, 2 Cal.3d 362, 399; People v. Gurule, supra, 236 Cal.App.2d 847, 855 ; and People v. Arends, supra, 155 Cal.App.2d 496, 513 .

11987–1987
Terry v. Ohio green
scotus · 1968
2 sentences

1984It argues the arresting officer could have stopped him at gunpoint in his own front yard anyway, simply based on his observation of Fowler walking from his house to the motorhome, and could have done so legally under Terry v. Ohio (1968) 392 U.S. 1 [ 20 L.Ed.2d 889 , 88 S.Ct. 1868 ], We find the notion so obviously spurious as to be unworthy of discussion.

1984It argues the arresting officer could have stopped him at gunpoint in his own front yard anyway, simply based on his observation of Fowler walking from his house to the motorhome, and could have done so legally under Terry v. Ohio (1968) 392 U.S. 1 [ 20 L.Ed.2d 889 , 88 S.Ct. 1868 ], We find the notion so obviously spurious as to be unworthy of discussion.

11984–1984
People v. Longwill green
cal · 1975
2 sentences

1978We are left, nevertheless, with the question whether appellant should not be accorded the benefit of the Fowler doctrine by virtue of the requirements of article I, section 15 of our state Constitution. 6 In this respect we are mindful of the observation: “As we noted in People v. Longwill (1975) 14 Cal.3d 943, 951 , footnote 4 [ 123 Cal.Rptr. 297 , 538 P.2d 753 ]: ‘[I]n the area of fundamental civil liberties—which includes not only freedom from unlawful search and seizure but all protections of the California Declaration of Rights—we sit as a court of last resort, subject only to the qualifi

1978We are left, nevertheless, with the question whether appellant should not be accorded the benefit of the Fowler doctrine by virtue of the requirements of article I, section 15 of our state Constitution. 6 In this respect we are mindful of the observation: “As we noted in People v. Longwill (1975) 14 Cal.3d 943, 951 , footnote 4 [ 123 Cal.Rptr. 297 , 538 P.2d 753 ]: ‘[I]n the area of fundamental civil liberties—which includes not only freedom from unlawful search and seizure but all protections of the California Declaration of Rights—we sit as a court of last resort, subject only to the qualifi

11978–1978

Where else courts name it

CA 8 (1978–2026) GA 5 (2004–2025) FL 3 (1983–2011) LA 3 (2007–2016) OH 3 (2014–2025) WA 2 (2005–2023) SC 2 (1996–2009) IN 2 (2016–2026) TX 2 (2018–2024) MS 2 (1990–2020) PA 2 (2001–2025)

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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