May 1, 2026
Court of Appeal, Fourth Appellate District, Division Three
The Rule of In re Marriage of Nishida and Kamoda is that a family law fraud action filed timely in civil court and transferred to family law court may proceed on the merits rather than being dismissed for jurisdictional reasons, under circumstances where the plaintiff filed a civil complaint within the one-year discovery period of Family Code section 2122(a) and the case was properly transferred between departments of the same superior court.
March 18, 2026
Court of Appeal, First Appellate District, Division Four
The Rule of In re Marriage of Jenkins is that a default judgment in dissolution proceedings that awards specific property division relief exceeds the relief requested where the dissolution petition listed all property division issues as "To be determined," under circumstances where the defaulted party lacked proper notice of the prove-up hearing and the specific property division being sought.