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Redefining the Rules: How Audish v. Macias Reshaped Future Medical Expense Claims in California Personal Injury Cases

In Audish v. Macias (2024) 102 Cal.App.5th 740, the California Court of Appeal decided a key issue concerning the admissibility of a plaintiff’s future Medicare eligibility in calculating damages for future medical expense...more

Section 998’s Cost-Shifting Provisions May Apply When Case Ends in Settlement

A divided court in Madrigal v. Hyundai Motor America (2023) 90 Cal.App.5th 385, as modified on denial of reh’g (May 9, 2023), review filed (June 20, 2023) recently held that the cost-shifting penalty provisions of California...more

Component-Part Manufacturers Are Not Required to Indemnify Retail Sellers Under California’s Song-Beverly Consumer Warranty Act...

The California Court of Appeal in Mega RV Corp. v. HWH Corp. (2014) 225 Cal.App.4th 1318 held that component-part manufacturers are not obligated to indemnify retail sellers under California Code of Civil Procedure section...more

Purchasers of Vehicles from Private Party Sellers Have No Standing Under the Song-Beverly Consumer Warranty Act

In Dagher v. Ford Motor Co. (2015) 238 Cal.App.4th 905, the plaintiff purchased a used vehicle in a private sale from the original purchaser. The vehicle had over 12,500 miles and two years left on its five-year express...more

California Supreme Court Clarifies Possible Lemon Law Damages

In Kirzhner v. Mercedes-Benz USA, LLC (2020) 9 Cal.5th 966, the California Supreme Court expanded the possible damages that are recoverable under the Song-Beverly Consumer Warranty Act (the “Act”) to include registration...more

California Supreme Court Limits Consumer Lemon Law Protection to Vehicles Purchased in California

In Cummins, Inc. v. Superior Court (2005) 36 Cal.4th 478, 483, the California Supreme Court addressed the issue of “whether a buyer who resides in California may bring suit against a manufacturer under the [Song-Beverly...more

Service Contracts Are Not Express Warranties Under the Song-Beverly Consumer Warranty Act

In Gavaldon v. DaimlerChrysler Corp. (2004) 32 Cal. 4th 1246, the California Supreme Court found that service contracts are not express warranties under the Song-Beverly Consumer Warranty Act and the Act did not otherwise...more

Collateral Source Rule Not Violated by References to Medical Insurance, Medicare and Social Security

Stokes v. Muschinske, No. B280116, 2019 WL 1513208 (Cal. Ct. App. Mar. 14, 2019) (awaiting official publication) begs the question, does reference to a plaintiff’s membership in a health care plan, like Kaiser Permanente, or...more

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