Special Fee Shifting Statute: UCL Does Not Allow For Fee Recovery Based On “Borrowed” Statute

Second District, Division One Departs Company From Contrary Rutter Group Commentary.

     In People ex rel. City of Santa Monica v. Gabriel, Case No. B214828 (2d Dist., Div. 1 July 14, 2010) (certified for publication), a panel of the Second District departed from some Rutter Group treatise commentary, deciding that Business and Professions Code section 17200 “borrowing” violations do not independently provide the basis for a fee award—even if the “borrowing” statutes permits for fee recovery.

Scroll to Top