Yari

Under the Marinship-Pinsker line of cases (James v. Marinship Corp. (1944) 25 Cal.2d 721 [ 155 P.2d 329 ]; Pinsker v. Pacific Coast Soc. of Orthodontists (1969) 1 Cal.3d 160, 166 [ 81 Cal.Rptr. 623 , 460 P.2d 495 ] (Pinsker)), a private organization’s decisionmaking process can, under certain circumstances, be subject to a common law right of fair procedure which includes judicial review. The central question in this case concerns that right.

Plaintiff and appellant Bob Yari contends that the right applies to decisions made by defendants and respondents the Academy of Motion Picture Arts and Sciences (Academy) and the Producers Guild of America, Inc. (Guild), in connection with the Academy Awards. Specifically, he contends that the right applies to defendants’ decision that, for purposes of the “Best Picture” award, he was not a producer of Crash (Lions Gate Films 2005), the movie which won that award in 2006.

We find, as did the trial court, that the right of fair procedure does not apply to the decisions private organizations such as these defendants make about their own awards, and also find that Yari did not state a cause of action under any of his remaining…