Private Attorney General – Cal Attorneys Fees

Private Attorney General: CCP § 1021 Catalyst Fee Recovery Not Available To Plaintiffs Where The Other Side Voluntarily Provided Relief Only After Plaintiffs Had Lost Relief In A Prior Merits Judgment

Case Found That Plaintiffs Could Not Meet The Successful Parties Element, Even Under A Catalyst Theory. In Physicians for Social Responsibility – L.A. v. Dept. of Toxic Substances Control, Case No. C100487 (3d Dist. Mar. 4, 2026) (published), the appellate court affirmed a denial of private attorney general fees, under a catalyst theory, where the […]

Private Attorney General: Where Prior Prevailing Parties Had Their Rulings Abrogated By Legislative Action Resulting In A Reversal Of Prior Opinions, They Were Not Successful Under CCP § 1021.5

Cases: Private Attorney General (CCP 1021.5)

December 22, 2025

Prior Opinions In Plaintiffs’ Favor Had No Precedential Value. In Make UC A Good Neighbor et al. v. Regents of University of California, Case No. A172510 (1st Dist., Div. 5 Dec. 19, 2025) (published), the appellate court affirmed that plaintiffs were not “successful” parties for private attorney general purposes despite winning favorable appellate precedents at