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Friday, October 2, 2015

Tellez v. Rich Voss Trucking: Order Denying Class Certification Reversed where Trial Court States No Reasons for Ruling

Just a quick word on this one. In Tellez v. Rich Voss Trucking (9/30/15) --- Cal.App.4th ---, the trial court denied the plaintiff's motion for class certification, but did not give any reasons for doing so. The Court of Appeal reversed and remanded, holding as follows:

While trial courts generally have broad discretion on motions for class certification,

“appellate review of orders denying class certification differs from ordinary appellate review. Under ordinary appellate review, we do not address the trial court’s reasoning and consider only whether the result was correct. [Citation.] But when denying class certification, the trial court must state its reasons, and we must review those reasons for correctness. [Citation.]” 

“The right result is an inadequate substitute for an incorrect process. Thus the appellate scrutiny should be on the reasons expressed by the trial court in the context of counsel’s arguments, not merely whether the trial court reached a result [that] can be justified by implication.” 
The Court remanded for the trial court to explain its reasons for denying the motion.

The opinion is available here.

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