May 5, 2026
Court of Appeal of the State of California, Second Appellate District, Division Eight
The Rule of People v. Mijares is that a defendant's attack remains the but-for cause and proximate cause of death even when the victim suffers from serious preexisting medical conditions, under circumstances where the coroner testifies that the defendant's assault caused the death and the victim would have survived at least several more years absent the attack.
February 26, 2026
Court of Appeal, Fourth Appellate District, Division One
The Rule of Fisher v. Fisher is that intentional infliction of emotional distress can be the legal cause of a wrongful death when the tortious conduct is a substantial factor in causing severe emotional distress that leads to the victim's death, under the broader scope of liability standard applicable to intentional torts rather than the narrower "scope of risk" standard used for negligence.
December 30, 2025
Court of Appeal of the State of California, First Appellate District, Division Four
The Rule of Vallejo City Unified School District v. Superior Court is that a school district is immune from liability under Education Code section 44808 for harm to parents caused by a student's off-campus suicide, under circumstances where the student was not and should not have been under the immediate and direct supervision of district employees at the time of death, even if the district was allegedly negligent in its on-campus supervision and response to the student's mental health crisis.