California Legal Brief

The Rule of Guardian Storage Centers, LLC is that attorneys must comply with State Fund obligations when they receive attorney-client privileged materials that were impermissibly taken from the privilege holder without authorization, even when the materials were originally sent to the disclosing person in their corporate capacity, under circumstances where the person later provides the materials to their attorney in their individual capacity against the privilege holder.

The Rule of In re the Domestic Partnership of Torres Campos and Munoz is that a party forfeits the right to challenge a trial court's reliance on fictitious case authorities when that party's own counsel drafted and submitted the order containing those fabricated citations without objecting or alerting the court to the error, under circumstances where the party had ample opportunity to verify the citations and correct the error in the trial court.