A.M. and R.Y. [Full Text] [CFLR]: In reversal, Fourth District holds trial court erred in finding mother’s evidence was legally insufficient to establish abuse under the DVPA; however, even when a DVRO petitioner has made a facially adequate showing of past abuse on the papers, trial court has discretion to conclude that the circumstances do not pose enough of an immediate threat to warrant ex parte relief pending a noticed hearing. In re Marriage of A.M. and R.Y. (4/30/25) 4 Civ D084344, Div 1 (Buchanan) 2025 WL 1243815, 2025 DJDAR 3536, 110 Cal.App.5th 1115, 332 Cal.Rptr.3d 341, CFLP §C.12.2, 2025 CFLR 16041, 2025 FA 2181 (rehg den 5/21/25)

A.M. [Full Text]: In reversal, Second District held juvenile court erred by removing child from her incarcerated father on the basis of his incarceration, where father arranged for paternal aunt to care for child, provided educational and medical documents to aunt, and provided a notarized letter establishing temporary custody. In re A.M. (9/18/25) 114 Cal.App.5th 627

Adeyeye & Faramaye [Full Text] [CFLR]: In reversal, Fourth District held the income of a sponsored immigrant should be considered in calculating the sponsor’s support obligation under I-864 [affidavit of support establishing an agreement to maintain an immigrant at an income level of no less than 125 percent of the federal poverty level]. In re Marriage of Adeyeye & Faramaye (6/20/25) 4 Civ G064553, Div 3 (Sanchez) 2025 WL 1720669, 2025 DJDAR 5472, 112 Cal.App.5th 119, 333 Cal.Rptr.3d 719, CFLP §F.110, 2025 CFLR 16001, 2025 FA 2187 (no pet f)

Agnone [Full Text] [CFLR]: Second District holds Cal Rules of Court, rule 3.1010(b) [authorizing attorney of record to appear and participate in deposition by telephone, videoconference, or other remote electronic means] does not authorize an attorney to participate in a deposition by audio-only when that attorney is physically present with client in the same location during a deposition. Agnone v. Agnone (5/30/25) 2 Civ B321252, Div 3 (Egerton) 2025 WL 1540539, 2025 DJDAR 4422, 111 Cal.App.5th 758, 333 Cal.Rptr.3d 119, CFLP §D.122, 2025 CFLR 16045, 2025 FA 2184 (no pet f)

Alvarez [Full Text]: Fourth District issued a $1,500 sanction against an attorney who filed opposition to a motion to dismiss on behalf of defendant in a criminal action, where attorney included a quotation attributed to a case in which purported quote did not exist, citation to a case that did not exist, and citations to two cases that did not address issues for which they were cited. People v. Alvarez (10/2/25) 114 Cal.App.5th 1115

Atlas [Full Text]: In affirmance, the Second District held trial court did not err by issuing a terminating sanction against defendant resulting in a default judgment in favor of plaintiff in the amount of $1.1 million, where the terminating sanction occurred only after issuing incremental discovery sanctions based on eight previous motions for discovery noncompliance. Atlas v. Davidyan (8/29/25) 113 Cal.App.5th 1086

Baer [Full Text] [CFLR]: In affirmance, Fourth District holds CCP §§2023.030(a) and 2031.320(b) authorize an award of appellate attorney’s fees that were incurred in connection with successfully defending an appeal from an order imposing monetary sanctions. Baer v. Tedder (11/10/25) 4 Civ G063642, G063784, Div 3 (Sanchez) 2025 WL 3140496, 2025 DJDAR 10488, 115 Cal.App.5th 1139, 338 Cal.Rptr.3d 754, CFLP §§D.119 et seq., 2025 CFLR ___, 2025 FA 2207 (no pet f)

Balandran [Full Text] [CFLR]: In reversal, Third District holds Grandparents’ visitation order after death of grandparents’ child under Fam C §3102 violated mother’s fundamental parenting rights, as she was a fit parent who allowed grandparent visitation. Balandran v. Balandran (7/22/25, ord pub 8/21/25) 2 Civ B335531, Div 3 (Gaab) 2025 WL 2416708, 2025 DJDAR 8034, 113 Cal.App.5th 858, 336 Cal.Rptr.3d 1, CFLP §G.146.1.1.15, 2025 CFLR 16065, 2025 FA 2196 (no pet f)

Birdsall [Full Text]: In reversal, the First District held, among other things, trial court erred by precluding evidence of, and jury instruction regarding, plaintiff’s failure to wear a seat belt; seat belt evidence was relevant to defendant’s affirmative defense that plaintiff was comparatively at fault in car accident and, thus, admissible. Birdsall v. Helfet (8/11/25) 113 Cal.App.5th 558

Bronshteyn [Full Text]: In affirmance, the Second District held trial court did not abuse its discretion by awarding employee approximately $5 million in attorney fees after she prevailed at trial against former employer, where, among other things, former employer complained that too many hours were billed but did not disclose how many hours its lawyers worked on the case. Bronshteyn v. Department of Consumer Affairs (9/17/25) 114 Cal.App.5th 537

C.T. [Full Text] [CFLR]: In writ proceeding, First District holds that trial court was not divested of UCCJEA jurisdiction under Fam C §3422(a)(2) [divesting UCCJEA jurisdiction when parties and child no longer presently reside in California], where jurisdiction properly attached upon father’s request for custody and visitation, thereafter the parties and child all relocated out of state while custody and visitation proceeding was pending, and the first proceeding had yet to be fully adjudicated. C.T. v. Superior Court (K.W.) (3/20/25) 1 Civ A171160, Div 4 (Brown) 2025 WL 877512, 2025 DJDAR 2495, 109 Cal.App.5th 1075, 331 Cal.Rptr.3d 104, CFLP §H.51, 2025 CFLR 15965, 2025 FA 2174 (no pet f)

Cradduck [Full Text]: In affirmance, the Fourth District held plaintiff waived his argument that trial court abused its discretion by denying his motion for reconsideration; in any event, plaintiff failed to make the requisite showing necessary for a motion for reconsideration under CCP §1008 since he did not offer any argument why the evidence of his attorney’s medical condition could not have been presented prior to trial court’s dismissal of plaintiff’s negligence action. Cradduck v. Hilton Domestic Operating Co., Inc. (6/24/25) 112 Cal.App.5th 284

DeBenedetti [Full Text] [CFLR]: In affirmance, the Fourth District held the trial court did not err by assigning four of husband’s retirement accounts to wife in order to enforce damages of $1.8 million arising from husband’s breach of fiduciary duty. In re Marriage of DeBenedetti & Ensberg (4/24/25) 4 Civ D082801, Div 1 (Rubin) 2025 WL 1189730, 110 Cal.App.5th 1035, 332 Cal.Rptr.3d 316, CFLP §§L.10.0 et seq., 2025 CFLR 15986, 2025 FA 2179 (rev den 4/23/25)

Egelston [Full Text]: In affirmance, the Second District held youth correctional officer who was fired after he assaulted and harassed his wife forfeited his argument that claims of assault and harassment in the administrative proceeding was barred by doctrines of res judicata and collateral estoppel; in any event, the dismissal without prejudice of a DVRO request did not have preclusive effect on later administrative proceedings, since the proceedings did not involve the same parties and the dismissal without prejudice was not a final decision on the merits. Egelston v. State Personnel Bd. (7/15/25) 112 Cal.App.5th 1050

Freeman [Full Text] [CFLR]: In affirmance, the Fourth District held trial court did not err by concluding the proper date for valuation of community property interest in spouse’s separate real property was the date that was closer to time of trial rather than time of the parties’ separation. In re Marriage of Freeman (4/4/25) 4 Civ G064552, Div 3 (Moore) 2025 WL 1009056, 2025 DJDAR 2978, 110 Cal.App.5th 406, 331 Cal.Rptr.3d 633, CFLP §§J.99.1 et seq., 2025 CFLR 15961, 2025 FA 2177 (no pet f)

Gamo [Full Text]: In partial affirmance, the Fourth District held the unilateral fee provision in W&I C §15657.5(a) does not bar a prevailing defendant from obtaining cost-of-proof fees under CCP §2033.420, since the cost-of-proof fees do not reward a party for prevailing on a claim but instead are intended to encourage efficient trials. Gamo v. Merrell (8/14/25) 113 Cal.App.5th 656

Hart [Full Text] [CFLR]: In reversal, Second District holds trial court may not renew a DVRO for a duration of less than five years pursuant to Fam C §6345(a). Trial court erred by granting wife’s request to renew a DVRO against husband for a duration of nine months. Hart v. Hart (10/27/25) (10/27/25) 2 Civ B338817, Div 2 (Lui) 2025 WL 3001823, 2025 DJDAR 10093, 115 Cal.App.5th 571, 338 Cal.Rptr.3d 231, §C.13.5, 2025 CFLR ___, 2025 FA 2205 (no pet f)

Herren [Full Text]: In affirmance, the First District held daughter was not required to rebut a presumption of father’s capacity in order to have standing to request a restraining order against attorney pursuant to the Elder Abuse and Dependent Adult Civil Protection Act. Herren v. George S. (3/3/25) 109 Cal.App.5th 410

Houser [Full Text] [CFLR]: In writ petition, the Fourth District held trial court erred by imposing sanctions against custodial parent for contempt of joint legal custody order and scheduling order, where the relevant orders did not specifically prohibit the unilateral actions the custodial parent took. Houser v. Superior Court of Orange County (Larsen) (11/19/25, ord pub 12/12/25) 4 Civ G065315, Div 3 (Sanchez) 2025 WL 3567875, 2025 DJDAR 11,375, 116 Cal.App.5th 1182, 340 Cal.Rptr.3d 31, CFLP §S.141, 2025 CFLR __, 2025 FA 2213 (no pet f)

J.G. and K.G. [Full Text] [CFLR]: In reversal, Third District holds that when Fam C §3044 [rebuttable presumption against custody award to perpetrator of domestic violence] is triggered, the court may not rely on the parties’ stipulation to award joint custody unless and until the perpetrator successfully rebuts the presumption. Marriage of J.G. and K.G. (5/2/25) 3 Civ C100075 (Earl) 2025 WL 1275765, 2025 DJDAR 3677, 110 Cal.App.5th 1214, 332 Cal.Rptr.3d 407, CFLP §G.26.5, 2025 CFLR 15985, 2025 FA 2180 (no pet f)

K.T. and E.S. [Full Text] [CFLR]: In partial reversal, Second District holds trial court erred by declining to include parties’ children as other protected parties in mother’s DVRO against father, where undisputed evidence demonstrated father committed multiple instances of physical and sexual abuse against mother in the presence of the children. K.T. v. E.S. (3/21/25) 2 Civ B333127, Div 8 (Stratton) 2025 WL 879852, 2025 DJDAR 2543, 109 Cal.App.5th 1114, 331 Cal.Rptr.3d 140, CFLP §C.10.10, 2025 CFLR 15966, 2025 FA 2175 (no pet f)

Kouvabina and Veltman [Full Text] [CFLR]: First District declares mother a vexatious litigant pursuant to CCP 391, where in the last five years she has commenced, prosecuted, or maintained nine appeals that have been finally determined adversely to her. In re Marriage of Kouvabina and Veltman (10/16/25) A171807, A172215, Div 3 (Rodriguez) 2025 WL 2938005, 2025 DJDAR 9815, 115 Cal.App.5th 293, 337 Cal.Rptr.3d 864, CFLP §C.42.2.20, 2026 CFLR 16136, 2025 FA 2203  (rev den 12/30/25)

Lugo [Full Text]: In reversal, the Second District held that amended version of Fam C §7575(c)(1) does not apply to a voluntary declaration of paternity (VDOP) that was filed before January 1, 2020; if a VDOP was filed before January 1, 2020, a request to set aside the VDOP may be timely filed within the time permitted by former Fam C §7575(c)(1). County of Los Angeles v. Lugo (11/21/25) 116 Cal.App.5th 206

M.P. and M.C. [Full Text] [CFLR]: In partial affirmance, the Fourth District held the court-created child dependency hearsay exception approved by the California Supreme Court in In re Cindy L. applies in DVPA proceedings involving the sexual abuse of a minor; thus, T/CT did not abuse its discretion by permitting wife to testify as to child’s statements discussing sexual abuse committed by husband. In re Marriage of M.P. and M.C. (12/9/25) 4 Civ G064023, Div 3 (Bancroft) 2025 WL 3523076, 2025 DJDAR 11227, 116 Cal.App.5th 1096, 339 Cal.Rptr.3d 798, CFLP §P.89, 2026 CFLR ___, 2026 FA 2215

M.V. [Full Text] [CFLR]: Second District affirms parental termination concluding that the juvenile court’s rejection of the supplemental bonding study was not an abuse of discretion since the study may reasonably be perceived as a psychological checklist rather than reach an individualized conclusion taking into account the “full range of evidence relevant to whether [minor child] had substantial, positive emotional attachments to her parents.” In re M.V. (3/725) 2 Civ B321252, Div 8 (Stratton) 2025 WL 732016, 2025 DJDAR 1983, 109 Cal.App.5th 486, 330 Cal.Rptr.3d 539, 2025 CFLR 16025 (no pet f)

Mamer [Full Text] [CFLR]: In reversal, Fourth District holds trial court erred by denying father’s request for reimbursement of IVF costs pursuant to Fam C §7637 [judgment or order may direct parent to pay reasonable expenses of pregnancy] on the grounds that these costs were incurred before mother filed a parentage action. Fourth District finds that no such exception exists and would frustrate the policy of the Uniform Parentage Act, which requires both parents to support their child. Mamer v. Weingarten (1/17/25) 4 Civ D084258, Div 1 (Irion) 2025 WL 225487, 2025 DJDAR 446, 108 Cal.App.5th 169, 328 Cal.Rptr.3d 922, CFLP §E.0.0.14.10, 2025 CFLR 15907, 2025 FA 2165 (no pet f)

 

 

 

 

Marino [Full Text] [CFLR]: In affirmance, the Second District held the trial court did not err by denying movant’s request to seal court records in civil harassment restraining order proceedings, where the restraining order was terminated but movant nevertheless claimed the proceedings had negatively impacted background checks as he applied for jobs and subjected him to increased scrutiny by airport authorities. Marino v. Rayant (3/24/25, ord pub 4/18/25) 2 Civ B337874, Div 1 (Bendix) 2025 WL 1148311, 2025 DJDAR 3250, 110 Cal.App.5th 846, 332 Cal.Rptr.3d 1, CFLP §C.97.3, 2025 CFLR 15987, 2025 FA 2178 (rehg den 4/10/25)

McDonald [Full Text]: The Second District held trial court abused its discretion by allowing plaintiff’s medical expert, who was disclosed one week before trial, to testify on a new medical theory that plaintiff needed spinal surgery as a result of a motorcycle accident, where there was no emergency or serious, unexpected development in the case and plaintiff provided no reasonable justification for the delayed disclosure. McDonald v. Zargaryan (12/22/25) 117 Cal.App.5th 344

Michael K. v. Cho [Full Text] [CFLR]: In reversal, the First District held the trial court erred by concluding husband’s defamation claims against wife’s attorney did not arise out of litigation activity protected by the anti-SLAPP statute, where husband initiated a chargeback dispute with the parties’ bank requiring wife’s attorney to justify wife’s payments for her legal fees and, in so doing, attorney restated wife’s claims of abuse in her statement to the bank. Michael K. v. Cho (7/10/25, ord part pub 7/28/25) 1 Civ A169917, Div 5 (Burns) 2025 WL 2102864, 2025 DJDAR 7019, 113 Cal.App.5th 1, 335 Cal.Rptr.3d 102, CFLP §A.103.2.95, 2025 CFLR 16068, 2025 FA 2194 (full pub den 7/29/25)

Miles [Full Text] [CFLR]: In affirmance, the Second District held the trial court did not err by denying movant’s request to seal court records in civil harassment restraining order proceedings, where the restraining order was terminated but movant nevertheless claimed the proceedings had negatively impacted background checks as he applied for jobs and subjected him to increased scrutiny by airport authorities. Miles v. Gerstein (3/28/25) 3 Civ C099438 (Hull) 2025 WL 942514, 2025 DJDAR 2688, 110 Cal.App.5th 88, 110 Cal.App.5th 88, CFLP §G.166.5, 2025 CFLR 15945, 2025 FA 2176 (rehg den 4/11/25) (rev den 6/25/25)

Morales [Full Text] [CFLR]: In affirmance, the First District held that plaintiff’s appeal of three orders, including two imposing discovery sanctions against his counsel, are objectively and subjectively frivolous where two of the orders were plainly nonappealable and with regard to the sole appealable order, plaintiff’s counsel raised arguments that had been forfeited for failure to raise them in the trial court and that directly contradicted the position taken at trial. Morales v. City and County of San Francisco (9/4/25) 1 Civ A170154 (Div 3, Rodriguez) 2025 WL 2539115, 114 Cal.App.5th 43, 336 Cal.Rptr.3d 627, CFLP §R.54.3, 2025 CFLR 16112, 2025 FA 2199 (depub den 11/2/25)

Navarro [Full Text] [CFLR]: In reversal, the First District held trial court abused its discretion by denying plaintiff’s request to renew a DVRO, where the incident giving rise to the issuance of the original order involved defendant attempting to kill plaintiff with a knife and where defendant violated DVRO by continuing to send correspondence to plaintiff. Navarro v. Cervera (1/22/25) 1 Civ A169830, Div 3 (Petrou) 2025 WL 262412, 2025 DJDAR 574, 108 Cal.App.5th 229, 329 Cal.Rptr.3d 191, CFLP §C.13.5, 2025 CFLR 15931, 2025 FA 2166 (no pet f)

Nelson [Full Text] [CFLR]: In affirmance, the Fourth District held there is no conflict between Fam C §4337 [except as otherwise agreed in writing, spousal support obligation terminates on death of either party or recipient’s remarriage] and Fam C §4360 [authorizing court to direct security of spousal support by ordering supporting spouse to establish a trust for the benefit of supported spouse]; also, substantial evidence supports trial court’s imposition of a trust under Fam C §4360. In re Marriage of Russell and Nelson (10/30/25) 4 Civ G064256, Div 3 (Moore) 2025 WL 3034122, 2025 DJDAR 10241, 115 Cal.App.5th 904, 338 Cal.Rptr.3d 561, CFLP §F.56.5.1, 2025 CFLR ___, 2025 FA 2206 (no pet f)

Noland [Full Text] [CFLR]: In affirmance, Second District holds P’s counsel’s use of AI-generated fabricated quotations in appellate briefs rendered the appeal frivolous, wherein P’s opening brief, 21 of the 23 quotations were fabricated, many of the cases P relied on did not support the propositions for which they were cited, and a few cases cited did not exist at all. Noland v. Land of the Free, L.P. (9/12/25) 2 Civ B331918, Div 3 (Edmon) 2025 WL 2629868, 2025 DJDAR 8961, 114 Cal.App.5th 426, 336 Cal.Rptr.3d 897, CFLP §R.54.3, 2025 CFLR 16115, 2025 FA 2199 (no pet f)

Patel [Full Text] [CFLR]: In affirmance, the Fourth District held trial court did not err by dismissing wife’s petition for legal separation, where husband filed a motion to dismiss the petition per Fam C §2345 [court may not render judgment of legal separation without the consent of both parties].In re Marriage of Patel (11/20/25, ord pub 12/19/25) 4 Civ G064218, Div 3 (Sanchez) 2025 WL 3687995, 2025 DJDAR 11,612, 117 Cal.App.5th 262, 340 Cal.Rptr.3d 35, CFLP §H.1.15, 2025 CFLR ___, 2025 FA 2212

Pham [Full Text] [CFLR]: In a matter of first impression, Fourth District holds that where parties have entered into a valid contract specifying how frozen embryos shall be treated in the event of a divorce or legal separation, the contractual approach for determining disposition of frozen embryos upon divorce governs; as such, trial court did not err by awarding wife frozen embryos in a dissolution action where husband and wife entered into a valid in vitro fertilization agreement specifying that upon divorce the embryos would be made available to the other partner. Pham v. Superior Court of Orange County (Kon) (12/16/25, part pub) 4 Civ G065471, Div 3 (Gooding) 2025 WL 3638359, 117 Cal.App.5th 115, 340 Cal.Rptr.3d 204, CFLP §§G.166.5 et seq., 2025 CFLR ___, 2025 FA 2211

Planchard [Full Text]: In affirmance, the Third District held PC §646.9(b) [stalking] does not require the perpetrator to direct a course of conduct at the victim; instead, it is sufficient that the nature of the conduct makes it reasonably foreseeable that the victim would become aware of the conduct. People v. Planchard (2/27/25) 109 Cal.App.5th 157

Pollock [Full Text] [CFLR]: In affirmance, the Second District held that even assuming trial court erred by awarding attorney fees to plaintiff as the prevailing party prior to trial, such error was harmless since the parties subsequently settled their case in a manner that made plaintiff the prevailing party. Pollock v. Kelso(1/8/25) 2 Civ B320574, Div 8 (Wiley) 2025 WL 47533, 2025 DJDAR 163, 107 Cal.App.5th 1190, 328 Cal.Rptr.3d 846, CFLP §§A.0 et seq., 2025 CFLR 15952, 2025 FA 2170 (no pet f)

Porter [Full Text]: In a matter of first impression, the Sixth District held that Veh C §23123.5(a) [prohibiting driving while holding and operating wireless phone] does not prohibit a driver from holding a phone that is turned off or is turned “on” with screen locked People v. Porter (7/3/25) 111 Cal.App.5th 927

Prato [Full Text]: In reversal, the Fourth District held trial court abused its discretion by awarding attorney fees to defendants where plaintiff’s lawsuit was dismissed after plaintiff failed to appear for trial and defendants were aware that the State Bar placed plaintiff’s attorney on inactive status but attorneys failed to provide timely notice to plaintiff pursuant to CCP §286
Prato v. Gioia (6/27/25) 112 Cal.App.5th 651, 334 Cal.Rptr.3d 463, 2025 DJDAR 6084

R.K. and G.K. [Full Text] [CFLR]: In affirmance, the Second District held that father forfeited his argument that he was denied due process by the trial court awarding mother more than she had requested and granting her sole physical custody of child, since father failed to object to the trial court’s tentative decision; even if father had not forfeited this argument, father was not denied due process since he participated in a three-day evidentiary hearing where a change of custody was at issue. In re Marriage of R.K. and G.K. (7/28/25, mod 8/18/25) 2 Civ B334571, Div 6 (Yegan) 2025 WL 2104367, 2025 DJDAR 7033, 113 Cal.App.5th 14, 335 Cal.Rptr.3d 143, CFLP §§G.125.8 et seq., 2025 CFLR 16026, 2025 FA 2192 (rehg den 8/18/25) (rev den 11/12/25)

R.R. [Full Text]: In reversal, the Second District held trial court abused its discretion by denying father’s request for a DVRO, where trial court found mother committed stalking but noted it could not determine whether mother’s actions were an intentional attempt to threaten or intimidate father. R.R. v. C.R. (12/2/25 opn, ord pub 12/26/25, vacated 1/20/26)

Roe [Full Text]: In reversal, the Second District held the trial court erred in granting plaintiffs’ request to proceed under pseudonyms in a defamation case, where plaintiffs were minors for a portion of the underlying events but not at the time they filed their lawsuit. Roe v. Smith (11/21/25) 116 Cal.App.5th 227

Shayan [Full Text]: The Second District imposed a monetary sanction against appellant’s attorney after he filed a brief containing numerous fabricated quotations that, whether the result of AI hallucinations or human failure to verify, violated the Rules of Professional Conduct. Shayan v. Shakib (12/1/25) 116 Cal.App.5th 619

Sheehy [Full Text]: The Fourth District dismissed plaintiff’s appeal from trial court’s order granting defendant’s motion in limine excluding plaintiff’s expert witness, an attorney who previously represented defendant, since such an order on a motion in limine is not appealable; in so holding, the Fourth District disagreed with the Second District’s holding on appealability in Brand v. 20th Century Ins. Co./21st Century Ins. Co. (2004) 124 Cal.App.4th 594, 21 Cal.Rptr.3d 380. Sheehy v. Chicago Title Ins. Co. (1/21/25) 108 Cal.App.5th 178

Stop C-29, LLC [Full Text]: The Second District held a trial court granting a motion to set aside and vacate a judgment pursuant to CCP §663 must necessarily also enter a new or amended judgment within the 75-day period specified in CCP §663a(b); otherwise, the order vacating the original judgment is void. Stop C-19, LLC v. Tooling Express, Inc. (5/30/25) 111 Cal.App.5th 803

Strong [Full Text] [CFLR]: In affirmance, Second District holds CCP §708.510(a)(5) [court may order a debtor to assign to creditor all or part of a right to payments from a patent or copyright] authorizes the assignment of a copyright itself (not only the payments from a copyright) to a receiver to be monetized to pay delinquent payments for support. In re Marriage of Strong (10/29/25, ord pub 11/24/25) 2 Civ B345843, Div 1 (Rothschild) 2025 WL 3268649, 116 Cal.App.5th 304, 339 Cal.Rptr.3d 203, CFLP §S.127, 2025 CFLR ___, 2025 FA 2209

Vergara [Full Text]: In affirmance, the Sixth District held quasi-judicial immunity barred father’s lawsuit against licensed therapist who was appointed to supervise father’s visits with child but who terminated such visits after father refused to acknowledge his conduct toward child. Vergara v. Ouse (12/12/25) 116 Cal.App.5th 1238

Winter [Full Text]: In affirmance, the Second District held trial court did not err by granting trustee’s motion to disqualify co-trustee’s attorney on the grounds that trustee previously had sought to retain attorney to represent him in his case against co-trustee and, in so doing, disclosed confidential information about the litigation to attorney. Winter v. Menlo (4/2/25) 110 Cal.App.5th 299

X.D. [Full Text] [CFLR]: In reversal, Second District holds trial court erred by excluding authenticated, relevant text messages evidencing threats to mother. After such evidence is considered, the record did not show father promptly demonstrated a full commitment to parental responsibilities as required to constitute a Kelsey S. father [natural father who makes full and timely commitment to assume parental responsibilities has right to withhold consent to adoption]. Adoption of X.D. (9/29/25) 2 Civ B343632, B343634, Div 8 (Rubin) 2025 WL 2753550, 2025 DJDAR 9322, 114 Cal.App.5th 812, 337 Cal.Rptr.3d 348, CFLP §G.168.0, 2025 CFLR 16105, 2025 FA 2201 (rehg den 12/10/25, rev den 12/10/25)

X.K. [Full Text] [CFLR]: In reversal, the First District held the trial court erred by denying mother’s DVRO request simply because the request occurred in the context of a dispute involving custody and visitation. Also, the trial court was required to consider father’s conduct while the parties resided in China as part of the totality of the circumstances analysis under DVPA. X.K. v. M.C. (6/25/25, ord pub 7/23/25) 1 Civ A170020, Div 4 (Brown) 2025 WL 2079528, 2025 DJDAR 6968, 112 Cal.App.5th 1287, 335 Cal.Rptr.3d 277, CFLP §C.9.5, 2025 CFLR 16027, 2025 FA 2193 (no pet f)

Yu [Full Text] [CFLR]: In reversal, the Second District held that a petitioner seeking an alternative to personal service under CCP §527.6(m)(2) must make a diligent effort to accomplish personal service before the court may authorize service by another method; process server’s declaration lacked the detail to establish a diligent effort to accomplish personal service where such declaration consisted only of conclusory statements. Yu v. Pozniak-Rice (7/21/25) 2 Civ B337415, Div 7 (Segal) 2025 WL 2027905, 2025 DJDAR 6678, 112 Cal.App.5th 1135, 334 Cal.Rptr.3d 886, CFLP §C.16.5, 2025 CFLR 16021, 2025 FA 2191 (rehg den 8/4/25) (rev & depub den 10/15/25)

Note: Legislation listed below indicates principle statutes affected only.

Selected 2025 California Assembly Bills

AB 515 [Full Text]: This bill amends, repeals, and re-adds CCP §§632 and 664, relating to statements of decision. Among other things, AB 515 requires courts to issue a statement of decision explaining the factual and legal basis for its decision as to each of the principal controverted issues at trial upon the request of any party appearing at the trial. The request must be made in writing or orally if there is an official record of the proceeding being transcribed, prior to the submission of the matter for decision. The statement of decision must be in writing, unless the parties appearing at trial agree otherwise. The court may, in its sole discretion, issue a statement of decision even though one has not been requested. Effective 1/1/2027, CFLP §R.40.

AB 1297 [Full Text]:This bill amends, repeals, and re-adds Fam C §2040, relating to automatic temporary restraining orders that issue in actions for dissolution of marriage, nullity, legal separation, and under the Uniform Parentage Act. Existing law requires the summons in such proceedings to include specified automatic temporary restraining orders restraining both parties, pending further or-der of the court, from, among other things, cashing, borrowing against, canceling, transferring, disposing of, or changing the beneficiaries of any insurance or other coverage, including life, health, automobile, and disability policies, held for the benefit of the parties and any minor children for whom support may be ordered. Beginning January 1, 2027, AB 1297 prohibits either party from allowing any such insurance or coverage to lapse for nonpayment of premiums or by failing to renew the coverage. AB 1297 (Ch. 48, Stefani): Effective 1/1/2027, CFLP §C.1.0.1, Automatic temporary restraining orders.