Wong v. Stoler – Delay Does Not Benefit Defendants

Here’s a thorny problem.  The trial court found that the seller of a house lied to the buyer.  The buyer sought the remedy of rescission.  The trial court denied relief, in part because of events that occurred with the passage of time. The court of appeal disagreed in Wong v. Stoler (June 23, 2015) __ …

A Deal is Deal, Except When You Pump Your Arms

When you read the cases, it’s hard not to reach the conclusion that the courts view a liability release agreement with distrust. A new high water mark in this analysis was reached in the recent decision in Etelvina Jimenez v. 24 Hour Fitness USA, Inc. (June 9, 2015) __ Cal.App.4th ___. In Jimenez, the court …

Estate of Britel – When is a Child Not a Child?

The law is filled with rules.  Rules give guidance to judges. Sometimes the legal result does not square with the facts.  In Estate of Britel (2015) 236 Cal.App.4th 127, “the court admitted into evidence a DNA test showing a 99.9996 percent probability that the decedent (Amine Britel) was A.S.’s (the child’s) father.”  Yet the court …

Huge Decline in California Bankruptcy Filings

The federal bankruptcy courts publish detailed statistics on bankruptcy filings.  California has four federal judicial districts, with Fresno located in the Eastern District. The 2011-2014 bankruptcy filings for the Eastern District of California show a substantial decline, as shown in this table:   E.D. Cal. total filings Chapter 7 cases Chapter 11 cases Chapter 12 …

U.S. v. Milovanovic – Ninth Circuit Adopts a Sloppy Fiduciary Standard

Case law reflects a tension in the interpretation of fiduciary duties. One camp favors a “I know it when I see it” approach, while the more rigorous jurists seek to discern the basis for imposition of such liability. This tension is on full display in the recent en banc decision in U.S. v. Milovanovic, ___ …

A. W. B. Simpson on English Wills in the 12th and 13th Centuries

A study of the ancient English common law begins, for many points, with the law that developed after 1066.  The history of inheritances of land is certainly curious, as we inevitably find it tied to the duties owed in a feudal, agricultural society. Here is an excellent analysis from Oxford Prof. A. W. B. Simpson. …

L.S. Sealy – Categories of Fiduciary Duties

In a law review article published 50 years ago, Cambridge law professor L.S. Sealy reviewed two centuries of English case law on fiduciary relationships.  He concluded, correctly, that different relationships give rise to different duties. As a starting point, “Fletcher Moulton L.J. once warned against what he called ‘the danger of trusting to verbal formulae’ …