March 5, 2026
Court of Appeal, Fourth Appellate District, Division Two
The Rule of Moramarco v. Nowakoski is that a trustee's inability to pay is not a mitigating factor that can reduce a Probate Code section 859 civil penalty for bad faith wrongful taking of trust property, under circumstances where a trustee attorney misappropriated trust funds and the statute provides mandatory double damages.
2/4/26
Court of Appeal, Fourth Appellate District, Division One
The Rule of Parsonage v. Wal-Mart Associates, Inc. is that ICRAA authorizes consumers to recover the statutory sum of $10,000 as a remedy for a violation of their statutory rights, without any further showing of concrete injury or adverse employment decision, under circumstances where an employer fails to comply with any requirement of ICRAA's disclosure and consent provisions.