rationale for the general rule (California) · Go Syfert
← California issues

rationale for the general rule in California

5 California opinions name it 1 courts 1974–2013 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 (7)

CaseFollowedCited
In Re Marriage of Stevensongreen
calctapp · 1993 · cited in 2 California opinions naming this issue, 2006–2013
2 sentences

2013Because earnings and accumulations following separation are the spouse’s separate property, it follows the community interest should be valued as of the date of separation—the cutoff date for the acquisition of community assets.’” (Id. at pp. 625-626, quoting In re Marriage of Stevenson (1993) 20 Cal.App.4th 250, 253-254 .) 6 The rationale for the general exception to trial date valuation applies equally to any small business that relies on the skill and reputation of the spouse who operates it.

2006Because earnings and accumulations following separation are the spouse’s separate property, it follows the community interest should be valued as of the date of separation—the cutoff date for the acquisition of community assets.’ (In re Marriage of Stevenson[, supra,] 20 Cal.App.4th 250, 253-254 [ 24 Cal.Rptr.2d 411 ].) H] Moreover, ‘the rationale for the general exception to trial date valuation is not limited to small law practices.

22
In Re Marriage of Duncangreen
calctapp · 2001 · cited in 1 California opinions naming this issue, 2013–2013
2 sentences

2013(Duncan, supra, 90 Cal.App.4th at p. 626 [small investment adviser business]; In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business.) “Thus, an alternative valuation date may apply to a business when its value ‘devolves largely from the personal skill, industry and guidance of the operating spouse,’ rather than the business’s capital assets.” ( Duncan, supra, at p. 626 .) The trial court’s determination of the date of valuation is reviewed under the abuse of discretion standard.

2013(Duncan, supra, 90 Cal.App.4th at p. 626 [small investment adviser business]; In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business.) “Thus, an alternative valuation date may apply to a business when its value ‘devolves largely from the personal skill, industry and guidance of the operating spouse,’ rather than the business’s capital assets.” ( Duncan, supra, at p. 626 .) The trial court’s determination of the date of valuation is reviewed under the abuse of discretion standard.

11
In Re Marriage of Gowdygreen
calctapp · 1986 · cited in 1 California opinions naming this issue, 2006–2006
2 sentences

2006It applies with equal logic to other small businesses which rely on the skill and reputation of the spouse who operates them.’ (In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business falls within general exception to trial date valuation].)” (In re Marriage of Duncan, supra, 90 Cal.App.4th at pp. 625-626.) 5 In re Marriage of Moore (1980) 28 Cal.3d 366 [ 168 Cal.Rptr. 662 , 618 P.2d 208 ] (Moore); In re Marriage of Marsden (1982) 130 Cal.App.3d 426 [ 181 Cal.Rptr. 910 ] (Marsden). 6 One commentator “suggested that the Camire court’s disposition may be

2006It applies with equal logic to other small businesses which rely on the skill and reputation of the spouse who operates them.’ (In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business falls within general exception to trial date valuation].)” (In re Marriage of Duncan, supra, 90 Cal.App.4th at pp. 625-626.) 5 In re Marriage of Moore (1980) 28 Cal.3d 366 [ 168 Cal.Rptr. 662 , 618 P.2d 208 ] (Moore); In re Marriage of Marsden (1982) 130 Cal.App.3d 426 [ 181 Cal.Rptr. 910 ] (Marsden). 6 One commentator “suggested that the Camire court’s disposition may be

11
In Re the Marriage of Greengreen
calctapp · 1989 · cited in 1 California opinions naming this issue, 1993–1993
2 sentences

1993(In re Marriage of Green (1989) 213 Cal.App.3d 14, 20-21 [ 261 Cal.Rptr. 294 ]; Hogoboom & King, Cal. Practice Guide: Family Law 1 (The Rutter Group 1993) ]| 8:300.5, pp. 8-351-8-352.) The rationale for the general exception to trial date valuation is not limited to small law practices.

1993(In re Marriage of Green (1989) 213 Cal.App.3d 14, 20-21 [ 261 Cal.Rptr. 294 ]; Hogoboom & King, Cal. Practice Guide: Family Law 1 (The Rutter Group 1993) ]| 8:300.5, pp. 8-351-8-352.) The rationale for the general exception to trial date valuation is not limited to small law practices.

11
Toole v. Richardson-Merrell Inc.green
calctapp · 1967 · cited in 1 California opinions naming this issue, 1974–1974
2 sentences

1974Workers, 16 Cal.App.3d 686, 697 [ 94 Cal.Rptr. 562 ]; 4 Witkin, Summary of Cal. Law (1974) Torts, § 856, pp. 3147-3148) or (2) where the tort was committed by an employee or agent acting in a managerial capacity (Lowe v. Yolo County etc. Water Co., 157 Cal. 503, 511-513 [ 108 P. 297 ]; Toole v. Richardson-Merrell Inc., 251 Cal.App.2d 689, 711-712 [ 60 Cal.Rptr. 398 , 29 A.L.R.3d 988 ]).

1974Workers, 16 Cal.App.3d 686, 697 [ 94 Cal.Rptr. 562 ]; 4 Witkin, Summary of Cal. Law (1974) Torts, § 856, pp. 3147-3148) or (2) where the tort was committed by an employee or agent acting in a managerial capacity (Lowe v. Yolo County etc. Water Co., 157 Cal. 503, 511-513 [ 108 P. 297 ]; Toole v. Richardson-Merrell Inc., 251 Cal.App.2d 689, 711-712 [ 60 Cal.Rptr. 398 , 29 A.L.R.3d 988 ]).

11
Davis v. LOCAL UNION NO. 11, INTERNAT.green
calctapp · 1971 · cited in 1 California opinions naming this issue, 1974–1974
2 sentences

1974Workers, 16 Cal.App.3d 686, 697 [ 94 Cal.Rptr. 562 ]; 4 Witkin, Summary of Cal. Law (1974) Torts, § 856, pp. 3147-3148) or (2) where the tort was committed by an employee or agent acting in a managerial capacity (Lowe v. Yolo County etc. Water Co., 157 Cal. 503, 511-513 [ 108 P. 297 ]; Toole v. Richardson-Merrell Inc., 251 Cal.App.2d 689, 711-712 [ 60 Cal.Rptr. 398 , 29 A.L.R.3d 988 ]).

1974Workers, 16 Cal.App.3d 686, 697 [ 94 Cal.Rptr. 562 ]; 4 Witkin, Summary of Cal. Law (1974) Torts, § 856, pp. 3147-3148) or (2) where the tort was committed by an employee or agent acting in a managerial capacity (Lowe v. Yolo County etc. Water Co., 157 Cal. 503, 511-513 [ 108 P. 297 ]; Toole v. Richardson-Merrell Inc., 251 Cal.App.2d 689, 711-712 [ 60 Cal.Rptr. 398 , 29 A.L.R.3d 988 ]).

11
Lowe v. Yolo Cty. Consol. Water Co.green
cal · 1910 · cited in 1 California opinions naming this issue, 1974–1974
2 sentences

1974Workers, 16 Cal.App.3d 686, 697 [ 94 Cal.Rptr. 562 ]; 4 Witkin, Summary of Cal. Law (1974) Torts, § 856, pp. 3147-3148) or (2) where the tort was committed by an employee or agent acting in a managerial capacity (Lowe v. Yolo County etc. Water Co., 157 Cal. 503, 511-513 [ 108 P. 297 ]; Toole v. Richardson-Merrell Inc., 251 Cal.App.2d 689, 711-712 [ 60 Cal.Rptr. 398 , 29 A.L.R.3d 988 ]).

1974Workers, 16 Cal.App.3d 686, 697 [ 94 Cal.Rptr. 562 ]; 4 Witkin, Summary of Cal. Law (1974) Torts, § 856, pp. 3147-3148) or (2) where the tort was committed by an employee or agent acting in a managerial capacity (Lowe v. Yolo County etc. Water Co., 157 Cal. 503, 511-513 [ 108 P. 297 ]; Toole v. Richardson-Merrell Inc., 251 Cal.App.2d 689, 711-712 [ 60 Cal.Rptr. 398 , 29 A.L.R.3d 988 ]).

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 (4)

CaseCitedYears
Production Resources Group, L.L.C. v. NCT Group, Inc. green
delch · 2004
1 sentence

2009Lexis 1635, pp. *24-*25; Production Resources v. NCT Group (Del.Ch. 2004) 863 A.2d 772, 787-803 , overruled in part in NACEPF v. Gheewalla (Del. 2007) 930 A.2d 92, 103 .) *1039 As generally discussed by the court in Ben Franklin, the rationale for the general rule of no duty owed to creditors is that it is the shareholders who own a corporation, which is managed by the directors.

12009–2009
North American Catholic Educational Programming Foundation, Inc. v. Gheewalla green
del · 2007
1 sentence

2009Lexis 1635, pp. *24-*25; Production Resources v. NCT Group (Del.Ch. 2004) 863 A.2d 772, 787-803 , overruled in part in NACEPF v. Gheewalla (Del. 2007) 930 A.2d 92, 103 .) *1039 As generally discussed by the court in Ben Franklin, the rationale for the general rule of no duty owed to creditors is that it is the shareholders who own a corporation, which is managed by the directors.

12009–2009
In Re Marriage of Marsden green
calctapp · 1982
2 sentences

2006It applies with equal logic to other small businesses which rely on the skill and reputation of the spouse who operates them.’ (In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business falls within general exception to trial date valuation].)” (In re Marriage of Duncan, supra, 90 Cal.App.4th at pp. 625-626.) 5 In re Marriage of Moore (1980) 28 Cal.3d 366 [ 168 Cal.Rptr. 662 , 618 P.2d 208 ] (Moore); In re Marriage of Marsden (1982) 130 Cal.App.3d 426 [ 181 Cal.Rptr. 910 ] (Marsden). 6 One commentator “suggested that the Camire court’s disposition may be

2006It applies with equal logic to other small businesses which rely on the skill and reputation of the spouse who operates them.’ (In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business falls within general exception to trial date valuation].)” (In re Marriage of Duncan, supra, 90 Cal.App.4th at pp. 625-626.) 5 In re Marriage of Moore (1980) 28 Cal.3d 366 [ 168 Cal.Rptr. 662 , 618 P.2d 208 ] (Moore); In re Marriage of Marsden (1982) 130 Cal.App.3d 426 [ 181 Cal.Rptr. 910 ] (Marsden). 6 One commentator “suggested that the Camire court’s disposition may be

12006–2006
In Re Marriage of Moore green
cal · 1980
2 sentences

2006It applies with equal logic to other small businesses which rely on the skill and reputation of the spouse who operates them.’ (In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business falls within general exception to trial date valuation].)” (In re Marriage of Duncan, supra, 90 Cal.App.4th at pp. 625-626.) 5 In re Marriage of Moore (1980) 28 Cal.3d 366 [ 168 Cal.Rptr. 662 , 618 P.2d 208 ] (Moore); In re Marriage of Marsden (1982) 130 Cal.App.3d 426 [ 181 Cal.Rptr. 910 ] (Marsden). 6 One commentator “suggested that the Camire court’s disposition may be

2006It applies with equal logic to other small businesses which rely on the skill and reputation of the spouse who operates them.’ (In re Marriage of Stevenson, supra, 20 Cal.App.4th at p. 254 [small general contracting business falls within general exception to trial date valuation].)” (In re Marriage of Duncan, supra, 90 Cal.App.4th at pp. 625-626.) 5 In re Marriage of Moore (1980) 28 Cal.3d 366 [ 168 Cal.Rptr. 662 , 618 P.2d 208 ] (Moore); In re Marriage of Marsden (1982) 130 Cal.App.3d 426 [ 181 Cal.Rptr. 910 ] (Marsden). 6 One commentator “suggested that the Camire court’s disposition may be

12006–2006

Where else courts name it

IL 8 (1988–2022) MO 6 (1993–2011) CA 5 (1974–2013) TX 3 (2011–2011) NC 3 (1980–1989) HI 2 (2006–2008) IN 2 (1994–1999) MD 2 (1998–2006) GA 2 (2013–2013) AZ 2 (1981–2014)

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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