Losing a family member because of someone else’s negligence is among the most devastating experiences a person can face. The grief is immediate. The financial consequences — lost income, medical bills, funeral expenses — arrive just as fast. And then, at the worst possible moment, you are expected to make one of the most important legal decisions of your life: choosing who will represent your family.

This guide is written to help Los Angeles families make that decision with clear, factual information. It covers what the term “best wrongful death lawyer” actually means in practice, which credentials signal genuine competence, what questions to ask before hiring anyone, and why local Los Angeles experience matters more than most families realize. It also explains, directly and without false modesty, why families in Los Angeles who consult our firm consistently choose to stay.

What “best” actually means in a wrongful death case

The word “best” is used freely in legal marketing. Every firm claims it. Almost none of them define it. When you are searching for a wrongful death attorney in Los Angeles, “best” should mean something specific and verifiable, not just a tag that appears in a heading.

There are three things that distinguish the best wrongful death lawyers from the average:

1. Demonstrated case results in wrongful death matters

The attorney you hire should have a documented track record of substantial results in wrongful death cases specifically — not just personal injury broadly. Wrongful death litigation involves distinct legal principles under California Code of Civil Procedure §§ 377.60 and 377.30, separate damages calculations for heirs and the estate, and strategic decisions that are different from standard injury claims. An attorney who handles one or two wrongful death cases per year is categorically less equipped than one who has dedicated decades to this practice area.

2. Independent, verifiable credentials

The only credentials that meaningfully separate one attorney from another are those that cannot be purchased and that involve independent review. Super Lawyers, issued annually by Thomson Reuters, requires peer nominations, independent research, and peer evaluations — and it is awarded to fewer than 5% of California attorneys in any given year. The Multi-Million Dollar Advocates Forum requires demonstrating that the attorney has achieved a verdict or settlement of $2 million or more on behalf of a client. Avvo’s 10.0 rating reflects years in practice, disciplinary history, peer endorsements, and client reviews — not payment for placement.

By contrast, dozens of online directories and “award” programs offer premium placements for purchase. A fee-based “top attorney” badge tells you nothing about the quality of representation you will receive.

3. Exclusive plaintiff-side practice

Some personal injury attorneys also represent insurance companies, corporations, or defendants. That creates a conflict at the strategic level: an attorney who understands how insurance defense thinks has an advantage in negotiation and litigation. But an attorney who actively works both sides is serving two masters. The best wrongful death lawyers represent injured people and their families exclusively — every case, every year, for the entirety of their career.

Why Los Angeles experience specifically matters

California wrongful death law applies statewide, but how a case is actually litigated depends heavily on local factors that only come from years of practice in Los Angeles Superior Court. These include:

• Judicial culture and settlement practices. Judges and assigned departments in Los Angeles Superior Court have specific preferences for scheduling, mediation, and trial procedure. Attorneys who have practiced in that courthouse for decades know these dynamics in ways that cannot be absorbed from textbooks or a short practice history.
• Insurance adjuster relationships. The major insurers operating in Los Angeles — State Farm, Allstate, GEICO, Farmers, and others — assign specific adjusters and defense counsel to cases in this market. An experienced Los Angeles wrongful death lawyer recognizes the patterns in how each insurer values claims, which cases they settle early, and which ones they will take to trial.
• Local venue considerations. Where a case is filed in Los Angeles County — the Stanley Mosk Courthouse in downtown LA, the Santa Monica Courthouse, or another branch — affects jury composition, average verdict ranges, and how long a case takes to get to trial. Venue strategy requires local knowledge.
• Expert witness network. Wrongful death cases frequently require medical experts, accident reconstruction specialists, economists, and vocational rehabilitation experts. The best Los Angeles wrongful death attorneys maintain established relationships with the most credible and persuasive expert witnesses in the region.

Steven M. Sweat has practiced personal injury and wrongful death law in Los Angeles for more than 30 years — since 1994. The firm is based at 11500 W. Olympic Blvd., Suite 400, Los Angeles, CA 90064, in the heart of West Los Angeles. Every case the firm has ever accepted has been on the plaintiff’s side. Steven has never represented an insurance company, a corporate defendant, or any party other than injured individuals and grieving families.

Credentials of Steven M. Sweat, Personal Injury Lawyers, APC

Below is a summary of independently verified credentials held by the firm. Each credential involves a process that cannot be purchased and that is described in detail at the

awards and recognition page on victimslawyer.com.

What to ask before hiring any wrongful death lawyer in Los Angeles

The initial consultation is your opportunity to evaluate the attorney — not just the other way around. Before hiring anyone, ask these questions directly:

How many wrongful death cases have you handled in Los Angeles in the past five years?

You are looking for a specific number and a description of case types. An attorney who handles wrongful death cases regularly will answer this question without hesitation. Vague answers like “many” or “quite a few” are a warning sign.

Have you taken wrongful death cases to trial, or do you settle everything?

The willingness and ability to take a case to trial is what creates leverage in settlement negotiations. Insurers and defense counsel know which attorneys will try cases. An attorney who never goes to trial loses that leverage. You should ask for specific examples.

Who will actually handle my case day to day?

Settlement mills — high-volume firms that advertise heavily and settle cases quickly without adequate investigation — often assign cases to paralegals or junior staff after the initial consultation. Ask specifically who will handle your case, attend mediations, and appear in court if necessary.

Do you represent both plaintiffs and defendants, or plaintiffs only?

An attorney who has represented insurance companies or corporate defendants is not necessarily disqualified, but you deserve to know. Exclusive plaintiff-side practice reflects a career-level commitment to the interests of injured people and their families.

What is your fee structure, and are there any costs I should be aware of?

California wrongful death attorneys typically work on a contingency fee basis, meaning no attorney fee unless they recover compensation for you. The standard contingency fee in California is 33⅛% of the gross recovery before litigation and up to 40% if the case goes to trial, though fee agreements can vary. Ask for the fee agreement in writing before signing anything.

Red flags: warning signs when evaluating a wrongful death attorney

As important as knowing what to look for is knowing what to avoid. These are the most common warning signs:

• Immediate pressure to sign a retainer. A reputable wrongful death attorney gives you time to evaluate your options. Any attorney who pressures you to sign at the initial consultation is prioritizing their own interests over yours.
• Vague or evasive answers about case results. If an attorney cannot or will not describe specific outcomes in wrongful death cases, that is meaningful information. Ask for examples. Ask about the range of results. Ask what factors determined the outcome.
• No named attorney handling your case. If the initial consultation is with a case intake specialist rather than a licensed attorney, and if there is no clear answer about who will actually litigate your case, consider that a warning sign.
• Credentials that appear to be paid placements. Many online directories sell premium placement or award designations. If an attorney’s listed credentials do not include any of the independently vetted designations described above — Super Lawyers, National Trial Lawyers, Multi-Million Dollar Advocates Forum, or a bar-verified Avvo rating — apply more scrutiny.
• Fee agreements that are not explained clearly. California law requires contingency fee agreements to be in writing and to clearly state the percentage, what expenses will be deducted, and in what order. If an attorney is vague or evasive about fees, that is a problem.

How California wrongful death law determines what your case is worth

Understanding the legal framework helps you evaluate whether the attorney you are considering genuinely knows this area of law. California wrongful death cases are governed primarily by California Code of Civil Procedure § 377.60, which defines who may file the claim, and § 377.30, which governs the companion survival action. Filing both simultaneously is critical to maximizing total recovery — and many attorneys miss the survival action component entirely.

Damages in a California wrongful death case fall into two broad categories:

Economic damages

• Lost financial support the decedent would have provided to surviving family members
• Lost household services (childcare, household management, care for elderly relatives)
• Funeral and burial expenses
• Medical expenses incurred between the injury and the death (recovered through the survival action)

Non-economic damages

• Loss of companionship, comfort, and society
• Loss of guidance and mentorship for surviving children
• Loss of the decedent’s love, affection, and moral support

California does not cap non-economic damages in wrongful death cases (unlike medical malpractice, where non-economic damages were historically capped at $350,000 under MICRA, with the cap now rising under AB 35). This means that in serious cases involving young decedents, breadwinners, or highly involved parents and spouses, non-economic damages can be substantial.

For a detailed analysis of what California wrongful death cases are actually worth based on real verdict and settlement data, see our post on

average wrongful death settlement values in California.

The statute of limitations: why timing matters from day one

California imposes a strict deadline on wrongful death claims. Under Code of Civil Procedure § 335.1, the general rule is two years from the date of death. But the exceptions to that rule are numerous, and they consistently catch families off guard:

• Government entities. If the death was caused by a government employee or involved government property, a Government Claims Act filing must be submitted within six months of the date of death. Missing this deadline permanently bars the claim — no exceptions.
• Medical malpractice. If negligence by a medical provider caused the death, the deadline may be shortened to one year from the discovery of negligence, or three years from the date of injury, whichever is earlier.
• Delayed discovery. In cases where the cause of death was not immediately apparent — for example, delayed complications from an accident, or a product defect that was not identified until an autopsy — the clock may begin from the date of discovery rather than the date of death. This is highly fact-specific and requires legal analysis.

Insurance adjusters and defense attorneys track these deadlines on every open claim. They know that if your deadline passes during settlement negotiations, they can withdraw from talks entirely and owe you nothing. The time to consult an attorney is now, not after negotiations stall. For a complete analysis, see our post on the

California wrongful death statute of limitations.

Why Los Angeles families choose Steven M. Sweat, Personal Injury Lawyers, APC

This section is not marketing language. It is a specific, factual account of what distinguishes this firm from others in Los Angeles, based on criteria that can be independently verified.

30+ years of plaintiff-side practice in Los Angeles

Steven M. Sweat has been practicing personal injury and wrongful death law exclusively on behalf of plaintiffs since 1994. He has never represented an insurance company. Every year of that practice has been in Los Angeles. That means more than three decades of familiarity with the Los Angeles Superior Court, its judges, its administrative processes, and the defense counsel who appear regularly in personal injury and wrongful death cases.

Super Lawyers recognition since 2012

Fewer than 5% of California attorneys receive Super Lawyers recognition in any given year. Steven has received it continuously since 2012 — more than a decade without interruption. That is not a credential that can be maintained by marketing. It requires meeting the standard year after year as assessed by peers.

Multi-Million Dollar Advocates Forum membership

Membership in this forum requires documenting that you have achieved a verdict, award, or settlement of $2 million or more on behalf of a client. It is the only major personal injury credential that directly ties membership to case outcomes. You can read more about what that means in practice on our

awards and recognition page.

No settlement mills, no case handoffs

This firm takes a limited number of cases so that each one receives direct attorney attention. Steven Sweat personally handles client communication, case strategy, mediations, and litigation. There is no model where your case is assigned to a case manager after the intake consultation.

No fee unless we recover

There is no cost for the initial consultation and no attorney fee of any kind unless the firm recovers compensation for your family. The fee structure, including the percentage and how litigation costs are handled, is explained in writing at the start of every engagement. For a detailed explanation of how contingency fees work in California, see our post on

California contingency fee arrangements.

Frequently asked questions: best wrongful death lawyer Los Angeles

Contact Steven M. Sweat, Personal Injury Lawyers, APC

Related resources on victimslawyer.com

• Average wrongful death settlement values in California — Real verdict and settlement data with breakdown by liability tier
• California wrongful death statute of limitations explained — Deadlines, exceptions, and government entity rules
• Awards, recognition, and client results — Steven M. Sweat — Full credential detail with independent verification
• California contingency fee arrangements explained — How no-win-no-fee works, what percentages are standard
• Why clients rate Steven M. Sweat among LA’s best injury lawyers — Review analysis and credential breakdown
• Wrongful death practice area — victimslawyer.com — California law, damages, and who may file

Losing a family member because of someone else’s negligence is devastating, and the last thing on your mind is a legal deadline. But in California, the california wrongful death statute of limitations sets a strict window for filing a lawsuit, and missing it almost always means losing your right to compensation entirely, no matter how strong your case is.

The general rule is two years from the date of death. That sounds straightforward, but it rarely is. Medical malpractice claims, cases involving government entities, and situations where the cause of death wasn’t immediately apparent can all shift the timeline in ways that catch families off guard. Certain exceptions shorten the deadline to as little as six months, while others may extend it beyond the standard two-year period.

At Steven M. Sweat, Personal Injury Lawyers, APC, we’ve spent over 25 years representing families across California in wrongful death cases and have recovered hundreds of millions of dollars in verdicts and settlements. We wrote this guide to give you a clear breakdown of every deadline, exception, and procedural detail you need to know, so you can protect your claim before time runs out.

Why the statute of limitations matters in wrongful death

The statute of limitations is not a technicality that courts occasionally overlook. It is a hard legal cutoff that ends your right to sue, and California courts enforce it without exception in nearly every case. If you file even one day after your deadline expires, the defendant’s attorney will file a motion to dismiss, and the judge will grant it. Your case ends with that motion, regardless of how strong your evidence is or how negligent the defendant was.

Missing the filing deadline is one of the most preventable reasons wrongful death families permanently lose their right to compensation.

What happens when you miss the deadline

When you file a wrongful death lawsuit after the statute of limitations has passed, the court does not evaluate the merits of your claim. The defendant simply raises the expired deadline as an affirmative defense, and the case ends there. You cannot restart the clock, refile under a different theory, or ask the court for an extension because you were unaware of the deadline. California’s Code of Civil Procedure treats the limitation period as absolute once it expires, which is why understanding exactly when your clock starts and stops is critical from the moment you lose your loved one.

Judges do have narrow discretion to toll, or pause, the statute in specific circumstances, but families who wait to consult an attorney often discover those exceptions do not apply to them. Procrastination is the single biggest threat to a valid wrongful death claim, and it costs families their only legal remedy.

Why the defense side watches your deadline closely

Insurance companies and defense attorneys track the california wrongful death statute of limitations on every open claim they handle. Their legal teams monitor filing dates, and they know that if you miss yours, they owe you nothing. Defense adjusters may draw negotiations out, offering small amounts and requesting more documentation, specifically to consume as much of your remaining time as possible. If the deadline passes while you wait for a settlement offer, they can simply withdraw from talks entirely.

You need to treat the filing deadline as a firm date that exists independent of any settlement discussion. Negotiations do not pause the clock, and an insurance company’s willingness to talk does not mean they have waived the statute of limitations as a defense.

The standard two-year deadline and when it starts

Under California Code of Civil Procedure Section 335.1, wrongful death claimants have two years from the date of the deceased person’s death to file a lawsuit. This baseline rule applies to the large majority of wrongful death cases filed in California. Importantly, the california wrongful death statute of limitations does not measure time from the date of the accident or the original injury; it measures time from the actual date of death, which may occur days, weeks, or even months after the incident that caused the fatal harm.

The two-year period begins on the date of death, not the date of the injury or accident.

Who can file and when their deadline begins

California law strictly limits the people who have legal standing to file a wrongful death lawsuit. The two-year period begins on the same date for all of them: the date of death. Eligible parties under California Code of Civil Procedure Section 377.60 include:

• Surviving spouse or domestic partner
• Children of the deceased
• Grandchildren, if the decedent’s children are also deceased
• Dependent parents or siblings, if no other eligible heirs exist

Each eligible claimant’s two-year window opens on the same date, regardless of when that individual personally learned about the death or its cause.

When the date of death differs from the accident date

Many families mistakenly believe their deadline starts on the date of the accident, but this is incorrect. If your loved one was injured on January 5 and died from those injuries on March 20, your two-year clock begins on March 20, not January 5.

You must document both the incident date and the certified date of death to calculate your actual filing deadline accurately, since courts use that official document to confirm when your limitation period began.

How to calculate your deadline in real situations

Calculating your actual filing deadline requires two confirmed dates: the official date of death and the date you plan to file. Once you have both, the math is simple. Add two years to the date of death, and that is your last possible day to file under the standard rule. But confirming those dates accurately, especially the date of death, requires getting a certified death certificate, not relying on memory or informal records.

A straightforward example

Suppose your spouse was struck by a negligent driver and died at the hospital on August 14, 2024. Under California Code of Civil Procedure Section 335.1, your two-year period expires on August 14, 2026. You do not count the accident date, the date of hospitalization, or the date you retained an attorney. The death certificate controls the start of your window, and your attorney must file the lawsuit before that date closes.

Filing even a single day late permanently bars your claim, which is why you should confirm your exact deadline in writing with your attorney as early as possible.

When the injury and death dates are far apart

Some families deal with situations where a loved one survived for months after an accident before dying from related complications. In those cases, the california wrongful death statute of limitations still starts from the date of death, not the original injury. If your father was injured on March 1, 2023, but passed away on November 10, 2023, your filing deadline is November 10, 2025. You gain time compared to counting from the accident, but you must use the correct start date or risk miscalculating the window entirely.

Special deadlines for medical malpractice wrongful deaths

When a loved one dies because of a doctor’s or hospital’s negligence, the california wrongful death statute of limitations applies differently than in standard accident cases. California Code of Civil Procedure Section 340.5 governs medical malpractice claims, and it imposes either a three-year period from the date of injury or one year from the date you discovered, or reasonably should have discovered, the negligence, whichever comes first.

How the three-year and one-year rules interact

Both timelines run simultaneously, and you must file before whichever deadline arrives first. If your loved one died in a hospital on June 1, 2024, and you suspected malpractice immediately, your one-year window closes on June 1, 2025, which arrives before the three-year outer limit.

In medical malpractice wrongful death cases, the one-year discovery rule often shortens your window far below the standard two-year period.

Waiting to confirm your suspicions does not restart the one-year clock; it runs from the point when a reasonable person would have connected the death to the provider’s negligence. Courts apply an objective standard to that determination, not a subjective one based on your personal awareness.

What qualifies as a medical malpractice wrongful death

A wrongful death qualifies under medical malpractice rules when it stems directly from a licensed healthcare provider’s negligent act or omission, such as a surgical error, a misdiagnosis, or a medication mistake. If the death resulted from a combination of an accident and subsequent hospital negligence, your attorney will need to analyze both timelines to determine which statute controls. Getting this analysis wrong can result in filing under the longer standard rule while the shorter malpractice deadline has already expired, which permanently bars your claim.

Shorter deadlines when a government agency is involved

When the death involved a government employee or agency, such as a city bus driver, a county hospital, or a state worker, the california wrongful death statute of limitations does not apply in the same way. California’s Government Claims Act requires you to file an administrative claim with the responsible agency before you can even file a lawsuit. You typically have only six months from the date of death to submit that claim, which is dramatically shorter than the standard two-year period.

Missing the six-month government claim deadline bars you from suing the agency entirely, regardless of how strong your evidence is.

Filing a government claim before you can sue

Before you file a lawsuit against a government entity, you must submit a written claim directly to that agency. The agency then has 45 days to accept or reject it. If they reject your claim, you have six months from the rejection date to file your lawsuit in court. If the agency does not respond at all, a two-year period from the incident applies, but waiting that long is unnecessary and creates avoidable risk.

Your claim must include specific details to be valid: the date and location of the incident, a description of how the death occurred, and the names of eligible heirs. Submitting an incomplete or late claim typically results in rejection, and courts rarely allow families to proceed against a government defendant without completing this step first.

What counts as a government entity

A government entity includes any city, county, state agency, public school district, or publicly operated hospital functioning under California law. If your loved one was struck by a city-owned vehicle or died due to negligent care at a county medical facility, the Government Claims Act applies. Many families do not realize that a municipal transit authority or a publicly run clinic triggers these shorter administrative deadlines, which makes identifying the correct defendant an urgent first step.

What to do if you may be running out of time

If you believe your deadline is approaching, contact an attorney immediately rather than waiting until you have every document ready. The california wrongful death statute of limitations leaves no room for delays, and an attorney can confirm your exact deadline, identify which exceptions apply to your case, and file the necessary paperwork before your window closes.

Gathering your certified death certificate and any incident-related records before your consultation helps your attorney calculate your precise filing date without guessing. Every day you delay after losing a family member is a day closer to permanently losing your legal remedy, whether through the standard two-year rule, the malpractice timeline, or the six-month government claims deadline.

Speak with our wrongful death attorneys today at Steven M. Sweat, Personal Injury Lawyers, APC for a free 24/7 consultation with no fees unless we recover compensation for your family.

The average wrongful death settlement in California is approximately $973,000, though the median settlement is closer to $294,000. Settlement values range from under $100,000 for low-liability cases to $10 million or more for catastrophic losses involving a breadwinner or clear negligence. No ‘average’ accurately captures individual case value — the specific facts, venue, defendant’s insurance, and quality of legal representation are the dominant variables.

Introduction: What Is the Average Wrongful Death Settlement in California?

When a family loses a loved one due to someone else’s negligence, one of the first questions they face — after the grief, the shock, and the funeral — is: “What is our wrongful death claim worth?” It is one of the most painful and urgent legal questions a family can ask, and the honest answer is that there is no single “average” that captures the reality of these cases.

That said, data from California jury verdict databases, legal industry reports, and decades of litigation experience provide meaningful benchmarks. Studies aggregating California wrongful death settlements and verdicts consistently show:

Why is the mean so much higher than the median? Because a relatively small number of very large verdicts — some exceeding $20 million or $50 million — pull the statistical average upward. The median is often more informative: it reflects the middle-of-the-road outcome for a typical California wrongful death case.

This guide examines the law, the damages, the real-world verdict data, and the strategic factors that determine what your case is actually worth. If you have lost a family member due to negligence in Los Angeles or anywhere in Southern California, the information here is intended to help you understand your rights and protect your family’s future.

What Is a Wrongful Death Claim in California?

California’s wrongful death statute is codified at California Code of Civil Procedure § 377.60. Under this law, surviving family members may bring a civil lawsuit against the person or entity whose negligence, recklessness, or intentional misconduct caused the death of their loved one.

This is entirely separate from any criminal prosecution. A defendant can be acquitted in a criminal trial (as O.J. Simpson famously was) and still be held liable in a civil wrongful death case. The civil standard of proof is a “preponderance of the evidence” — more likely than not — rather than the higher criminal standard of “beyond a reasonable doubt.”

Who Can File a Wrongful Death Claim?

Under CCP § 377.60, the following individuals may bring a wrongful death action in California:

• The surviving spouse or domestic partner
• The children of the deceased
• The grandchildren (if the decedent’s children are also deceased)
• Any other person who was dependent on the decedent — including a putative spouse, stepchildren, or parents — if no surviving spouse or children exist

Critically, if multiple heirs exist (e.g., a spouse and three children), they must typically bring a single, joint wrongful death action. They then divide the recovery among themselves, either by agreement or by court order.

Wrongful Death Claim vs. Survival Action: A Key Distinction

California law actually allows two parallel claims to be brought simultaneously in a wrongful death case:

• Wrongful Death Claim (CCP § 377.60): Compensates the surviving heirs for their own losses — the loss of financial support, the loss of companionship, guidance, and love. The heirs themselves are the plaintiffs.
• Survival Action (CCP § 377.30): Allows the estate to recover for the damages the decedent personally suffered before death — including medical expenses, lost earnings from the moment of injury to death, and (under recent 2021 reforms to CCP § 377.34) non-economic pain and suffering in certain cases.

Filing both claims simultaneously can substantially increase the total recovery available to your family. Many attorneys overlook the survival action component — and families lose money as a result.

Average Wrongful Death Settlement Ranges in California

While no two cases are identical, California wrongful death cases generally fall into three broad tiers based on liability strength, available insurance, decedent’s income, and the venue where the case is filed.

Low-End Cases: $100,000 – $300,000

Cases that settle in this range typically involve one or more of the following limiting factors:

• Low insurance policy limits (e.g., a minimum-limits auto driver with a $15,000/$30,000 policy and no personal assets)
• Shared fault by the decedent (California’s comparative fault rules can reduce recovery proportionally)
• Elderly or non-working decedent with limited quantifiable economic losses
• Weak liability evidence — for example, a premises liability case where the hazard was partially open and obvious
• Cases settled quickly without full investigation of all potentially responsible parties

It is worth emphasizing: a low insurance policy does not mean a low case value. It means a low immediate recovery from one source. A skilled attorney will investigate umbrella policies, employer coverage, product liability theories, and other avenues to maximize total recovery.

Mid-Range Cases: $500,000 – $1,000,000

The broad middle of the California wrongful death settlement landscape includes cases involving:

• Moderate to strong liability with a single, adequately insured defendant
• A working adult decedent with dependents and a calculable income stream
• Cases with emotional weight — the wrongful death of a parent of young children, for example
• Commercial vehicle accidents, premises liability cases at large properties, or product liability with solvent defendants

Many cases in this range settle without trial, often because the insurance company calculates that a jury verdict would likely exceed their insured’s policy limits.

High-Value Cases: $1 Million – $10 Million+

The highest-value wrongful death cases in California typically involve:

• High-income decedents — professionals, business owners, executives whose future earnings can be documented in the millions
• Young decedents with decades of projected earnings and family dependency
• Multiple defendants — creating multiple insurance towers and cross-claims
• Egregious, reckless, or intentional conduct justifying punitive damages
• Corporate or governmental defendants with unlimited resources
• Cases filed in plaintiff-friendly venues (Los Angeles County, in particular, has historically produced large verdicts)

Nuclear verdicts — those exceeding $5 million or even $50 million — have become increasingly common in California. High-profile cases involving trucking companies, pharmaceutical manufacturers, and large employers regularly produce eight-figure results. These verdicts reset settlement expectations across the industry.

Real California Wrongful Death Verdicts and Settlements

Verdict databases such as TopVerdict.com, VerdictSearch, and the Daily Journal’s California Verdicts publication document thousands of California wrongful death outcomes. The following summarized examples are drawn from publicly reported California cases and illustrate the spectrum of outcomes:

Types of Damages in California Wrongful Death Cases

Economic Damages (Financial Losses)

Economic damages are designed to compensate heirs for quantifiable financial losses caused by the death. In California, these include:

• Loss of financial support: The present value of the financial contributions the decedent would have made to the household over their expected lifetime. This includes salary, business income, investment contributions, and any other regular monetary support. Economic experts use actuarial data and the decedent’s work history to project these figures.
• Loss of household services: The economic value of domestic services the decedent provided — childcare, cooking, home maintenance, transportation — which must now be purchased or performed by others.
• Loss of employment benefits: Health insurance, pension contributions, stock options, and other employer-provided benefits the decedent would have received and shared with the family.
• Funeral and burial expenses: Reasonable costs of the funeral, burial or cremation, and related expenses are recoverable directly.
• Medical expenses (survival action): Medical bills incurred between the injury and the death are recoverable through the estate’s survival action, not the wrongful death claim itself.

Non-Economic Damages (Loss of Relationship)

Non-economic damages in California wrongful death cases compensate heirs for losses that are real but not easily reduced to a dollar figure. These are often the largest component of a family’s total damages, particularly when the decedent had a modest income but a rich family life:

• Loss of love, affection, and companionship: The profound human loss of the relationship itself — the daily presence, emotional support, and shared experiences that are now gone permanently.
• Loss of comfort and society: The general sense of security, belonging, and social engagement the deceased provided to the family unit.
• Loss of guidance, training, and education: Particularly significant when minor children lose a parent who would have played a central role in their upbringing, education, and development into adulthood.
• Loss of moral support: The spiritual, emotional, and philosophical guidance that the decedent provided to surviving family members.

What Damages Are NOT Available in a California Wrongful Death Claim?

Under California law, heirs cannot recover the following in a wrongful death claim (though some may be available in a parallel survival action):

• Pain and suffering experienced by the decedent before death — this is recoverable only through a survival action (and was limited to economic damages only prior to the 2021 reforms to CCP § 377.34 for cases where death was not instantaneous)
• Grief, sorrow, or mental anguish experienced by the surviving heirs — California explicitly bars recovery for the heirs’ own emotional pain in a wrongful death claim
• Punitive damages — available only if the defendant’s conduct was oppressive, fraudulent, or malicious, and only through a survival action or related tort claim

Key Factors That Determine Wrongful Death Settlement Value in California

Every wrongful death case is unique, but experienced attorneys and insurance adjusters evaluate the same core set of variables when assessing case value:

1. Age and Life Expectancy of the Decedent

A 35-year-old with four decades of projected earnings and a 7-year-old child at home presents a fundamentally different economic picture than a 78-year-old retiree. California life expectancy tables (drawn from CDC National Vital Statistics Reports and actuarial sources) are used to project the duration of the loss.

2. Income, Earning Capacity, and Career Trajectory

This is often the single largest driver of economic damages. A neurosurgeon with a $750,000 annual income presents a dramatically different economic case than a minimum-wage worker — though both deserve aggressive representation. Economic experts calculate present value by projecting future earnings, accounting for expected raises, promotions, and retirement, then discounting to today’s value.

3. Number and Age of Dependents

The number of people financially dependent on the decedent directly affects the scope of the “loss of financial support” damages. A decedent supporting a spouse, four children, and an elderly parent presents a much larger dependency claim than a childless individual.

4. Strength of Liability

If the defendant was clearly at fault — a drunk driver, a driver who ran a red light captured on camera, a landlord who received written complaints about a hazard — liability is easy to establish, which increases settlement pressure. Conversely, if liability is disputed (comparative fault arguments, unclear causation), defense attorneys negotiate harder and insurers discount offer value.

5. Available Insurance Coverage

California is a “minimum limits” state with notoriously low required minimums ($15,000/$30,000 for bodily injury). Many cases are limited not by their intrinsic value but by the defendant’s insurance coverage. A skilled attorney will investigate all potentially applicable policies: primary auto, umbrella, commercial general liability, employer’s liability, excess carriers, and underinsured motorist (UIM) coverage from the decedent’s own policy.

6. Venue: Los Angeles vs. Other California Counties

Where a case is filed matters enormously. Los Angeles County juries historically return the largest verdicts in California, in part because of the county’s demographic diversity and jurors’ familiarity with high costs of living. San Francisco, Santa Clara, and Alameda Counties also tend to produce larger plaintiff verdicts. Conversely, rural Central Valley counties often produce more conservative results. Defense attorneys sometimes seek to transfer cases to less favorable venues — your attorney must fight to maintain the proper plaintiff-friendly venue.

7. Type of Case: Venue-Specific Considerations

Different case types carry different baseline values and risks:

• Auto accidents: Most common. Value driven primarily by insurance limits and economic loss. Clear liability cases often settle within 12-18 months.
• Trucking accidents: Higher value due to commercial insurance requirements (federal minimums of $750,000 for most commercial carriers), multiple potentially liable parties, and federal regulatory violations.
• Medical malpractice: Subject to MICRA’s cap on non-economic damages. As of January 1, 2023, MICRA’s cap increased from $250,000 to $350,000 for non-death cases, with a further increase to $500,000 by 2027; for wrongful death cases, the cap started at $500,000 in 2023 and will increase to $1 million by 2033.
• Premises liability: Value depends heavily on the property owner’s knowledge of the hazard. Evidence of prior complaints or violations dramatically increases case value.
• Product liability: Often involves large corporate defendants with significant insurance and litigation resources. Can produce very large verdicts; also involves lengthy litigation timelines.

How Insurance Companies Value Wrongful Death Claims

Understanding how the other side evaluates your case is essential to maximizing your recovery. Insurance companies use a combination of mathematical models and strategic discounting to assign a number to your family’s loss.

The primary tool insurers use is a combination of actuarial life expectancy tables and economic multipliers applied to the decedent’s documented income. Their economic experts — hired specifically to minimize damages — will challenge every assumption in your expert’s projections: expected raises, career stability, retirement age, and discount rate.

On non-economic damages, insurers apply a crude “multiplier” to economic damages (typically 1x to 3x) and then systematically discount for comparative fault, venue risk, and the emotional appeal (or lack thereof) of the plaintiffs. They also aggressively argue that their insured’s policy limits represent the maximum rational recovery.

What they do not want you to know: the policy limits are rarely the ceiling of the actual damages. Your attorney’s job is to prove the true case value, force the insurer to evaluate trial risk honestly, and — if necessary — expose the insurer to a bad faith claim for refusing to settle within policy limits when the evidence clearly demands it.

Settlement vs. Trial: What Every California Wrongful Death Family Should Know

More than 95% of California civil cases — including wrongful death cases — settle before trial. This is not because settlement is always the right outcome, but because litigation is expensive, emotionally exhausting, and uncertain for both sides.

Settlement has real advantages: it provides certainty, faster resolution, lower legal costs, and the ability to control the outcome. For families navigating grief, the prospect of a trial that puts the decedent’s life under a microscope — with defense experts challenging their earning capacity and credibility witnesses — can be genuinely traumatic.

Trial, however, can produce dramatically better outcomes. A jury in Los Angeles that hears two weeks of evidence about a family shattered by a negligent corporate defendant may return a verdict that dwarfs any pre-trial offer. And importantly: the known risk of trial drives pre-trial settlement values upward. Defense attorneys and insurers who know your counsel is willing and able to take a case to trial will offer substantially more than they offer to attorneys who always settle.

The lesson: hire trial lawyers, not settlement mills. The value of your representation is largely a function of whether the other side believes you will fight.

Click this link for a more comprehensive discussion of settlement vs. trial in California personal injury cases.

Special Rules in California Wrongful Death Cases

Comparative Fault

California follows a “pure comparative fault” system under Li v. Yellow Cab Co. (1975). This means that even if the decedent was partially at fault for their own death — say, 30% responsible — the heirs’ recovery is reduced by that percentage. A $1 million verdict is reduced to $700,000. Defense attorneys will almost always assert some degree of comparative fault; your attorney must aggressively contest this.

Multiple Heirs: The “One Lawsuit” Rule

All surviving heirs must generally join in a single wrongful death action. This prevents duplicative lawsuits and conflicting verdicts, but it can create family conflicts where spouses and children from different relationships disagree on settlement strategy. An experienced attorney will navigate these dynamics with sensitivity and legal precision.

Statute of Limitations: Two Years

Under California Code of Civil Procedure § 335.1, the statute of limitations for wrongful death claims is two years from the date of death. There are limited exceptions — including cases involving governmental entities (which require a government tort claim within six months of the death) and cases involving minor plaintiffs. Missing the deadline is fatal to the claim. Do not wait.

MICRA Caps in Medical Malpractice Cases

If the death resulted from medical malpractice, California’s Medical Injury Compensation Reform Act (MICRA) imposes a graduated cap on non-economic damages. As of January 1, 2023, the wrongful death cap began at $500,000 and will increase by $50,000 per year until it reaches $1,000,000 in 2033. This cap does not limit economic damages, which remain uncapped.

Government Defendants: Different Rules Apply

If the death was caused by a government employee or agency (a city bus driver, a public hospital, a county employee), the California Government Claims Act requires filing a government tort claim within six months of the death — a much shorter deadline than the standard two-year statute. Failure to file this administrative claim will bar the lawsuit entirely.

Wrongful Death Case Value by Scenario

The following scenarios illustrate how case value is estimated in practice. These are general ranges based on historical California outcomes and are not guarantees of any specific outcome.

Common Mistakes That Reduce Wrongful Death Case Value

Families pursuing wrongful death claims in California — often while grieving and unfamiliar with the legal process — are vulnerable to making decisions that reduce their recovery. The most costly mistakes include:

• Settling too early: Insurance adjusters are trained to contact families quickly and make initial offers while grief is acute and families are financially stressed. These initial offers are almost never the true value of the case. Accepting a quick settlement forfeits the right to any additional recovery.
• Hiring a settlement-focused attorney: Many personal injury attorneys have business models built around quick settlements. They lack the infrastructure, capital, or willingness to take cases to trial. Hire an attorney who has actually tried wrongful death cases to verdict.
• Failing to document economic loss: Economic damages require expert documentation. Without retained forensic economists and vocational experts, the projected earnings evidence may be insufficient, leaving substantial money on the table.
• Accepting policy limits without investigation: The at-fault party’s primary policy is rarely the only source of recovery. Umbrella policies, excess coverage, employer liability, product manufacturers, and UIM coverage are routinely overlooked by inexperienced attorneys.
• Missing the government claims deadline: If a government entity is responsible, the six-month government tort claim deadline is absolute. Missing it means no recovery at all, regardless of how strong the underlying case is.
• Not filing a survival action: The survival action is a separate and substantial claim that many attorneys fail to plead. It can add significantly to the total recovery available to the estate.

How to Maximize a California Wrongful Death Settlement

The families who achieve the best outcomes in California wrongful death cases are those who take these steps immediately:

• Engage experienced trial counsel within days, not months: Evidence degrades. Witnesses move. Cell phone data gets overwritten. The sooner an attorney can begin preservation efforts — sending spoliation letters, issuing subpoenas, photographing the scene — the stronger the eventual case.
• Retain a forensic economist from the beginning: Economic expert testimony is the foundation of the largest damage categories. The expert must have time to review the decedent’s tax returns, work history, benefits, and earning trajectory. Waiting until trial preparation is too late.
• Identify every potential defendant and insurance source: In a commercial vehicle accident, this may include the driver, the owner of the vehicle, the employer, a leasing company, a maintenance contractor, and a cargo loading company — each with separate insurance. Never assume there is only one defendant.
• File the survival action alongside the wrongful death claim: A single filing can dramatically increase the total damages available. The survival action also preserves the estate’s right to recover the decedent’s pre-death pain and suffering, which is unavailable in the wrongful death claim.
• Leverage California’s comparative verdict data: Experienced trial attorneys use jury verdict databases to present insurance companies with comparable California verdicts. This resets settlement expectations and demonstrates the genuine trial risk the insurer faces.
• Be prepared to litigate through trial: The willingness to actually try a case — not just threaten to — is the single most powerful settlement leverage tool available. Cases handled by known trial attorneys routinely settle for substantially more than cases handled by settlement-focused practitioners.

Frequently Asked Questions: California Wrongful Death Settlements

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The deaths of Kobe and Gianna Bryant along with the other people who were on the helicopter with them shocked the world. As thousands of mourners went to the Staples Center in Los Angeles for a memorial service to remember the victims, Kobe Bryant’s widow, Vanessa Bryant, filed a wrongful death lawsuit against the pilot’s estate and the helicopter company on several grounds. The civil complaint was filed in the Los Angeles Superior Court. While Kobe Bryant’s estate is estimated at $600 million, there are several reasons why Vanessa Bryant may have filed a lawsuit other than to add to her family’s vast wealth.

Key legal issues in the wrongful death lawsuit

Vanessa Bryant’s lawsuit names the estate of Ara Zobayan, who was the pilot who also died in the crash, Island Express Helicopters, and Island Express Holdings as defendants. Her claims against the estate are based on negligence, and the claims against Island Express Helicopters and Island Express Holdings are based on principles of vicarious liability. Note: For a full copy of the actual lawsuit filed in Los Angeles Superior Court click here: 1784052393(1-72)

Claims against the estate of Zobayan

Vanessa Bryant stated three legal claims against the pilot’s estate. She argued that he was negligent in failing to abort the flight. She also argued that Zobayan was negligent in his failure to monitor and assess the weather conditions. Finally, she argued that Zobayan negligently failed to maintain a safe distance between the helicopter and natural obstacles.

To prevail on negligence claims, plaintiffs are required to prove the elements of their claims by a preponderance of the evidence, which can be understood to mean that it was more likely than not to have occurred as the plaintiff argued. For each of the negligence claims against the estate of Zobayan, Vanessa Bryant will need to present evidence that proves the following elements of negligence:

• Zobayan owed a duty of care to Kobe and Gianna Bryant.
• Zobayan’s acts or omissions breached the duty of care.
• The breach of Zobayan’s duty of care caused the accident and the resulting deaths.
• Vanessa Bryant suffered harm as a result.

On the day of the accident, there were reports of heavy fog in the area where the crash occurred. Other companies had grounded their helicopters because of the conditions. However, Zobayan still decided to fly the helicopter despite the conditions. As the pilot, he certainly owed a duty of care to all of the passengers on the flight. Vanessa Bryant argued that he should have either grounded the flight or should have aborted it when the conditions worsened. If she prevails on the negligence claims against the pilot’s estate, she might recover damages from the estate. However, the company for which he was employed might end up being primarily responsible for paying damages because of vicarious or direct liability of its own.

Claims against Island Express Helicopters and Island Express Holdings

The claims against Island Express Helicopters and Island Express Holdings are based on a legal theory called respondeat superior. Under this principle, employers are liable for the negligence of their employees when they are acting in the scope and course of their employment.

Zobayan had been employed by Island Express Helicopters and its parent company, Island Express Holdings, for more than 20 years as a helicopter pilot. To prevail in a claim based on the vicarious liability of the company, Vanessa Bryant would first need to prove that Zobayan was negligent and that his negligent actions or omissions directly or proximately caused the accident, Kobe and Gianna’s deaths, and her resulting harms. She would also need to prove that the employment relationship existed between Zobayan and the company and that Zobayan was working in the scope and course of his employment at the time of the accident.

Another potential claim that could be asserted against Island Express Helicopters and Island Express Holdings might be a claim of negligent hiring, retention, or supervision. This type of claim might apply if the company hired, retained, or supervised Zobayan negligently. For example, if Zobayan had a history of recklessness in his flying, the company might be directly liable for retaining him.

In Zobayan’s case, he received a reprimand from the Federal Aviation Administration in 2015 after he flew into airspace that had visibility that was much too low in 2015. However, there is little else to suggest whether he had a pattern of such actions. Whether this type of claim might be asserted would depend on how the company handled the previous incident.

Another issue in the case is that the company did not have the proper federal certification for flying in low-visibility conditions. Under the company’s certification, Zobayan was only authorized to fly the helicopter in conditions that allowed him to visually navigate. In this case, however, Zobayan did not have any ability to visually navigate at the time of the accident because of the thick fog.

Wrongful death claims

In California, only certain parties are allowed to file wrongful death claims. The parties who can file these types of claims are people with specific familial relationships with the deceased. In the first category of people who have the ability to file claims are spouses. As Kobe Bryant’s spouse, Vanessa Bryant has the necessary standing to file the wrongful death claim against the estate of the pilot and his employer. She likewise has the ability to file the wrongful death claim on behalf of her daughter as her daughter’s surviving parent.

The surviving family members of people who are killed because of the negligence of others will go through a few steps before an attorney will determine whether the claim has merits. The first step that the lawyer will take is to look at the relationship of the claimant to the decedent to make certain that he or she is the right person to file the lawsuit. The attorney will next need to value the claim by figuring out the actual financial losses that the plaintiff has suffered. Finally, the lawyer will want to learn more about the quality of the relationship between the plaintiff and the victim to figure out whether they might have grounds to request loss of consortium damages and other noneconomic losses.

Reasons why Vanessa Bryant might have decided to file a lawsuit

There are several reasons why Vanessa Bryant might have decided to file a lawsuit against the company and the pilot’s estate even though she is already wealthy. Filing a wrongful death lawsuit might allow her to hold the responsible parties accountable for the loss of her husband and daughter. Wrongful death lawsuits can allow people to hold others accountable for their actions even when no criminal charges are filed. She might also have decided to file a lawsuit against the company as a prophylactic measure against potential claims that the families of the other passengers might file against Kobe Bryant’s estate. For example, if Kobe Bryant ordered the pilot to continue flying, the other family members might have grounds to file lawsuits against his estate. There is no evidence that this occurred, however.

Get help from an experienced personal injury and wrongful death lawyer

If you have lost a loved one because of the negligence of another person or company, you may have legal rights to recover damages. An experienced personal injury and wrongful death attorney at the law firm of Steven M. Sweat, Personal Injury Lawyers can review the facts and circumstances of what occurred and explain the merits and potential value of your claim. Contact us today to schedule a consultation by calling us at 866.966.5240.

When people participate in sports and are injured, they may have legal rights to sue in some cases even if they signed waivers of liability. In Hass v. RhodyCo Productions, Cal. Ct. App., Case No. A142418, a wrongful death lawsuit, the court found that an express waiver of liability and the primary assumption of the risk doctrine do not bar lawsuits when the conduct amounts to gross negligence.

Factual background

Peter Hass was a man who participated in the 2011 Kaiser Permanente San Francisco Half Marathon. After he crossed the finish line, Hass suffered a heart attack and subsequently died. The organizer of the event, RhodyCo Productions, provided production services and event management for the half-marathon from 2006 to 2011. RhodyCo Productions had to submit an emergency medical services plan to the city in order to get the permits to close the streets. The plan said that medical services would be provided by American Medical Response and the Palmer College of Chiropractic – West. The plan said that PCCW would supply event-trained medical personnel who were students with CPR certifications. It also said that there would be med tents located at several places, including at the finish line and that the head clinician, a chiropractic doctor, would be located in the postrace tent on the day of the race. In other parts of the plan, it stated that there would be one medical doctor and six emergency medical technicians at the finish line along with an automatic external defibrillator.

Hass signed a waiver of liability when he registered for the race. After Hass passed the finish line and collapsed, another participant heard him fall and began administering CPR. The other participant was a doctor. He performed CPR for five to eight minutes before another bystander took over. A third person went to the postrace tent and returned with the AED about 11 minutes after Hass’s cardiac arrest. When the AED was used on Hass, it did not show any heart rhythm. The doctor and the other bystander continued CPR until they were relieved by personnel from the fire department. Despite the efforts, Hass could not be revived and was pronounced dead.

Hass’s widow and two minor children filed a wrongful death lawsuit against RhodyCo Productions on May 4, 2012. The plaintiffs alleged in their complaint that RhodyCo was negligent in its planning and organizing of the half-marathon and that it negligently retained, supervised and controlled the medical and emergency services for the event. In RhodyCo’s answer, it denied the allegations and asserted that Hass had assumed the risk and that its liability would be barred by the express waiver that Hass had signed. In a hearing on RhodyCo’s motion for summary judgment, the court initially granted the motion on the basis of an assumption of the risk and express waiver. The plaintiffs filed a motion for a new trial, and the court reversed itself. It ruled that it had erred and that the primary assumption of the risk would not apply. It also gave leave to the plaintiffs to amend their complaint to add gross negligence. RhodyCo filed an appeal, and the Hass family filed a cross-appeal.

Issue: Whether the negligence action was completely barred by the primary assumption of the risk or whether gross negligence presented a material issue of triable fact

RhodyCo argued that the trial court erred when it granted the Hass family’s motion for a new trial. It argued that suffering a heart attack is an inherent risk of long-distance running. Since Hass had electronically signed an express waiver of liability that barred any claims against RhodyCo for negligence, the company argued that the waiver of liability barred claims of ordinary negligence. It also argued that the primary assumption of the risk doctrine barred claims of ordinary negligence and that its provision of medical services did not rise to the level of gross negligence. The Hass family argued that they should not be required to amend their complaint to add gross negligence since it is not recognized as a separate cause of action. They also argued that they had met their burden to establish that gross negligence presented an issue of triable fact. The Hass family argued that the primary assumption of the risk did not apply in their case and that the waiver of liability did not apply to a wrongful death lawsuit.

Rule: Participants in sports assume the inherent risks of the sport, and express waivers of liability bar ordinary negligence claims.

The doctrine of the assumption of the risk in California shifts the injury liability to the person who voluntarily participates in a recreational activity or sport. However, a claim will not be barred if the defendant’s conduct was grossly negligent or when the conduct was far outside of the range of the ordinary expected activity of the sport. This defense is often raised in situations in which people have been injured when they participated in sports or recreational activities and when they have signed express waivers of liability. In California, people can ask others to waive liability for ordinary negligence. However, claims for gross negligence, intentional acts or recklessness cannot be barred by express waivers.

Analysis

The court first looked at whether the express waiver of liability that was signed by Hass was sufficient to bar his family members from filing a wrongful death claim based on ordinary negligence. In Saenz v. Whitewater Voyages, Inc., 226 Cal. App.3d 758 (1990), the court found that while a wrongful death action by the heirs of a decedent is a distinct lawsuit, an express waiver of liability that waives all rights to sue for negligence is a complete defense to a wrongful death action. This meant that the express waiver of liability that Hass signed would serve as a bar to a wrongful death lawsuit based on ordinary negligence.

The court then looked at whether the express waiver of liability would bar claims based on gross negligence. In City of Santa Barbara v. Superior Court, 41 Cal.4th 747 (2007), the court distinguished between ordinary negligence and gross negligence. While waivers of liability may serve as complete bars to lawsuits based on ordinary negligence, they do not serve as bars to lawsuits that are based on gross negligence. The Hass family argued that RhodyCo’s management of the event and its provision of medical services were grossly negligent. The court found that the Hass family had met its burden for gross negligence as a triable issue of material fact. Finally, the court analyzed whether the case was barred by the primary assumption of the risk by Hass when he participated. RhodyCo argued that heart attacks are inherent risks of participating in long-distance running. However, the court looked at the California Supreme Court’s decision in Knight v. Jewett, 3 Cal. 4th 296(1992) in which it found that an organizer has a duty to minimize the risks of a sport without altering its nature. However, the organizer’s duty for inherent risks of a sport is to not do anything to increase the risks. The court then considered whether a cardiac arrest is an inherent risk of long-distance running or is an extrinsic risk. Both parties had agreed that heart attacks were an inherent risk of the sport. However, the court found that the provision of medical services was an extrinsic risk, meaning that the primary assumption of the risk doctrine would not be a bar to the action.

Conclusion

The court affirmed the lower court’s ruling that summary judgment was not warranted in this case. It found that a triable issue of material fact existed as to whether or not RhodyCo’s actions amounted to gross negligence and returned the case to the trial court for further proceedings.

If you have been seriously injured or have lost a loved one while playing sports, you might be entitled to relief. If you or your loved one signed a waiver of liability, an experienced personal injury lawyer may review what happened to determine whether or not it amounted to gross negligence. Call the Law Offices of Steven M. Sweat today to schedule an appointment.

Resources

https://law.justia.com/cases/california/court-of-appeal/2018/a142418.html

https://www.justia.com/trials-litigation/docs/caci/400/408/

https://law.justia.com/cases/california/court-of-appeal/3d/226/758.html

https://caselaw.findlaw.com/ca-supreme-court/1196693.html

https://law.justia.com/cases/california/supreme-court/4th/3/296.html