Stone Street Capital, LLC v. California State Lottery Commission

Stone Street Capital, LLC (appellant), appeals from a final judgment dismissing its action against the California State Lottery Commission (respondent) after the trial court granted respondent’s motion for judgment on the pleadings. Appellant sought declaratory relief, contending that respondent was required by law to recognize and accommodate an assignment of the last three years of prize winner Linda Foster’s lottery winnings. We reject appellant’s position that certain California Uniform Commercial Code provisions invalidate the California State Lottery Act’s (Gov. Code, § 8880 et seq.) (Lottery Act) restrictions on assignment, and therefore affirm the judgment.

CONTENTIONS

Appellant contends that lottery winnings are fully assignable under division 9 of the California Uniform Commercial Code, particularly because the revised definition of “account” in division 9, made operative in 2001, includes “winnings in a lottery or other game of chance.” (Cal. U. Com. Code, § 9102, subd. (a)(2)(viii).) Appellant argues that division 9 of the California Uniform Commercial Code controls over conflicting provisions of the Lottery Act, specifically Government Code section 8880.325…