Park

Angelica Textile Services Inc. v. Park

Bad Law
163 Cal. Rptr. 3d 192·2013 Cal. App. LEXIS 818·220 Cal. App. 4th 495·2013 WL 5615079·36 I.E.R. Cas. (BNA) 1522
Court of Appeal of CaliforniaOctober 15, 2013D062405California4,986 words

Opinion

Opinion

Benke, J.

In this unfair competition lawsuit, plaintiff, a large-scale laundry business that provided linens to local hospitals and other health care facilities, sued a new competitor in the laundry business and one of its own former employees on a variety of theories, including a claim under the Uniform Trade Secrets Act (Civ. Code, § 3426 et seq.; UTS A). Prior to trial, the trial court granted defendants summary adjudication on all of plaintiff’s non-UTSA claims. The trial court found those claims were preempted or displaced by UTS A.

A jury later found that, in fact, none of the information that plaintiff asserted had been wrongfully appropriated was a trade secret within the meaning of UTSA, and the trial court entered a judgment in favor of defendants.

On appeal, plaintiff does not challenge the jury’s verdict but argues the trial court erred in granting summary adjudication with respect to its nonUTSA claims. We agree with plaintiff.

By its terms, UTSA does not displace breach of contract claims, even if they are based in part on the alleged misappropriation of a trade secret. Moreover, UTSA does not displace other claims when they are not based on an alleged…

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