Plaintiffs brought an unfair competition action against defendants. The Los Angeles County Superior Court, California, entered judgment for defendants after it found that a pretrial settlement of plaintiffs' damage claims meant they no longer had standing to sue under the new standing requirements of Proposition 64. Plaintiffs appealed.
The court held that the changed standing rule was not intended to apply to cases pending when it took effect where a plaintiff had suffered actual injury as required by the new law, but settled that portion of its action before Proposition 64 took effect. The new standing requirement Orange California business lawyers did not apply to this unique factual situation. It was undisputed that, up to the time of the settlement, plaintiffs had a claim for actual injury that would have conferred standing under Proposition 64. Plaintiffs suffered actual injury, but settled that portion of their unfair competition claim before Proposition 64 was passed, partly in exchange for the right to pursue their injunctive relief claim in state court. Applying Proposition 64 to plaintiffs would have significantly impaired their settled rights and expectations.
The judgment was reversed, and the matter was remanded for further proceedings.
Pursuant to Cal. Civ. Proc. Code § 425.13(a), petitioner hospital sought review of a judgment by the Court of Appeal (California), which denied petitioner's writ of mandate to set aside a ruling that allowed plaintiffs, patient and her husband, to amend their complaint to state punitive damages against petitioner in their action for breach of therapeutic duty.
Plaintiffs, patient and her husband, sued petitioner hospital for breach of therapeutic duty claiming that plaintiff patient was traumatized by the termination of her extramarital affair with petitioner's employee, who was not involved in plaintiff patient's treatment. After the court of appeal denied petitioner's writ of mandate to set aside a ruling that allowed plaintiffs to amend their complaint to state punitive damages against petitioner, petitioner sought review of the denial. In reversing, the court held that the court of appeal erred in its denial because plaintiffs failed to satisfy the requirements of Cal. Civ. Proc. Code § 425.13(a). Specifically, plaintiffs failed to both state and substantiate a legitimate, triable punitive damages claim by failing to show they would have prevailed on their claim. Moreover, petitioner was not liable for punitive damages for any acts of fraud or malice by its employee in having the affair with plaintiff patient because such acts were wholly unrelated to petitioner's business or the employee's work duties.
The court reversed and remanded the court of appeal's judgment denying petitioner hospital's motion to set aside a ruling that allowed plaintiffs, patient and her husband, to amend their complaint to state punitive damages because plaintiffs failed to show a substantial probability of prevailing on the claim.