January 28, 2026
Court of Appeal of the State of California, Second Appellate District, Division One
The Rule of Maynard Matthews et al. v. Patrick Ryan is that a section 998 settlement offer conditioned on consent by the defendant's insurance carrier is valid, under circumstances where the defendant is defended by an insurer whose consent is necessarily required for any settlement regardless of whether such consent is expressly stated in the offer.
1/30/26
Court of Appeal of the State of California, Third Appellate District (Yolo)
The Rule of Tavares v. Zipcar is that remote rental car companies exempt under Civil Code section 1939.37 owe no duty to assess whether renters appear impaired at the time of rental or to equip vehicles with impairment detection technology, under circumstances where the rental is conducted through a membership agreement allowing remote vehicle access without in-person employee interaction.
2/11/26
Court of Appeal, Second Appellate District, Division Eight
The Rule of Chapman v. Avon Products is that expert testimony about asbestos testing methodology is admissible when the witness demonstrates sufficient knowledge, skill, experience, or training to interpret test results relevant to their field of expertise, under circumstances where the expert relies on established scientific principles even if using older or modified techniques.