Myers v. Raley’s, No. C086236 (D3 Mar. 12, 2019)
For reasons that are a little obscure, an appeal of an order denying class cert is not reviewed for its results, but for the validity of the trial court’s reasoning. Unlike in most other appellate contexts, a reviewing court will not affirm for some other unstated reason that is nonetheless supported by the record. Which means in addressing a motion for class cert, a trial court is required set out its reasoning
The court’s ruling here didn’t do that. It just recited the statutory standard under Code of Civil Procedure § 382. So the Court of Appeal, after implying that denial was wrong on the merits based on more recent authority, reverses the trial court for failing to state its reasons.
Reversed.
For reasons that are a little obscure, an appeal of an order denying class cert is not reviewed for its results, but for the validity of the trial court’s reasoning. Unlike in most other appellate contexts, a reviewing court will not affirm for some other unstated reason that is nonetheless supported by the record. Which means in addressing a motion for class cert, a trial court is required set out its reasoning
The court’s ruling here didn’t do that. It just recited the statutory standard under Code of Civil Procedure § 382. So the Court of Appeal, after implying that denial was wrong on the merits based on more recent authority, reverses the trial court for failing to state its reasons.
Reversed.