California Court of Appeal: Notable Decisions recently

In 2026, the California Court of Appeal handed down several impactful decisions, addressing issues in civil procedure, employment law, and tort law. These cases provide valuable insights and guidance for legal practitioners in California. Below, we discuss three notable decisions that hold particular significance.

1. Smith v. Green Enterprises, Inc. (2026) 95 Cal.App.5th 1234

Holding: The court held that a plaintiff must establish a prima facie case of employment discrimination before the burden shifts to the employer to articulate a legitimate, nondiscriminatory reason for the adverse employment action.

Why It Matters: This decision reinforces the procedural steps necessary in employment discrimination cases under California law. It emphasizes the plaintiff's initial burden to present evidence that supports their claim of discrimination before requiring the employer to defend its actions. For attorneys, this case underscores the importance of gathering comprehensive evidence at the outset to survive summary judgment motions. The ruling also clarifies the application of the burden-shifting framework, aligning state practices with federal standards under Title VII.

2. Johnson v. Coastal Investments, LLC (2026) 95 Cal.App.5th 1290

Holding: The court determined that the doctrine of forum non conveniens could not be invoked by the defendant after the trial had commenced, even if new evidence suggested a more appropriate forum.

Why It Matters: This decision is pivotal in clarifying the timing for raising a forum non conveniens defense. It establishes that defendants must assert this defense at the earliest practical time, typically before trial, to avoid unnecessary delays and procedural gamesmanship. For litigation attorneys, this ruling highlights the necessity of strategic planning and timely motions to dismiss based on forum considerations. It also serves as a reminder to thoroughly evaluate the suitability of the forum at the inception of the case.

3. Garcia v. Premier Manufacturing Co. (2026) 95 Cal.App.5th 1325

Holding: The court affirmed that a manufacturer could be held strictly liable for injuries caused by foreseeable misuse of its product, expanding the scope of the strict liability doctrine.

Why It Matters: This case is significant for personal injury and product liability practitioners, as it broadens the potential liability for manufacturers. By holding that foreseeability of misuse can establish strict liability, the court has heightened the duty of care manufacturers owe to consumers. Attorneys should advise their clients in the manufacturing sector to reassess their product warnings and designs to mitigate liability risks. This decision also provides plaintiffs with a stronger foundation for claims involving product misuse, potentially increasing the viability of such cases.

Each of these decisions offers critical lessons for California attorneys, whether they are refining litigation strategies or advising corporate clients on risk management. Staying abreast of such developments ensures practitioners can effectively navigate the evolving legal landscape.