Chen v. L.A. Truck Cntrs., S240245 (Cal. Jul. 22, 2019)
This PI case involving a bus accident. Plaintiff sued, among others, the Indiana-based Manufacturer of the bus and a California-based Dealer. His theory was the bus was defective because it was manufactured and distrusted without seat belts. The trial court first held that Indiana law—which was substantially less consumer friendly—applied. But then the manufacturer settled out. The trial court (now a different judge) refused Plaintiff’s motion in limine requesting a new ruling applying California law. Distributor won a split defense verdict.
The Court of Appeal reversed. The Court of Appeal held that the trial court was required to reconsider the choice of law ruling after Plaintiff settled with the Indianan Manufacturer. The original choice-of-law ruling was effectively a motion in limine, which is always provisional up to trial. So nothing stopped the Court from reevaluating the choice of law question, which would have had a different result without the presence of an Indiana defendant.
The Supreme Court granted review. In a short and unanimous opinion written by Justice Chin, the Court holds only that the Court of Appeal erred when it decided the trial court was required to reevaluate the choice of law question after Manufacturer settled. Given the importance of early resolution of choice of law issues in many cases, courts should not be required to reevaluate those decisions based on late developments in the procedural posture of a case.
Moreover, neither party challenged the original choice of law determination on appeal. But both Defendants were in the case at the time of the original choice of law ruling. So if Plaintiff wanted to argue that California law applied to Dealer, even if Indiana law applied to manufacturer, it could have done so at that time.
The Court “underscore[s]” the narrowness of its ruling: “[W]e do not reach the question whether trial courts may revisit a prior choice of law ruling. Nor do we opine that there are no circumstances under which the trial court would be obligated to reconsider the choice of law. We hold only that, in this case, plaintiffs fail to demonstrate that their decision to accept a settlement offer from one defendant constitutes such an exceptional circumstance.”
Court of Appeal reversed.
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