Section 998: Where Plaintiff Only Obtained A $15,835 Personal Injury Jury Verdict, After Rejecting An Earlier CCP § 988 Offer For $50,000, Plaintiff Properly Was Saddled With Post-Judgment Costs Of The Defense

Plaintiff’s Failure To Develop A Reasoned Appellate Argument For Reversal Doomed The Appeal.

In Cardeas v. Solorzano, Case No. A172766 et al. (1^st Dist., Div. 2 Apr. 28, 2026) (unpublished), plaintiff obtained a $15,835 jury verdict in a personal injury car crash case, after rejecting a defense CCP § 998 offer of $50.000. The lower granted post-judgment costs to the defense, a determination appealed by plaintiff. The costs award stood on appeal because the appellate court determined that plaintiff failed to develop a cogent, understandable argument for reversal given the deferential abuse of discretion review standard.

BLOG OBSERVATION—We have been seeing more appellate decisions, of late, which have found forfeitures based on failures to develop cogent, supporting legal arguments and to provide record citations in support of challenges.