City of Los Angeles v. Pricewaterhousecoopers, LLP

Summary

The California Supreme Court held that the general provisions of the Civil Discovery Act independently authorize trial courts to impose monetary sanctions for unusual or pervasive discovery abuses not addressed by a more specific discovery-method provision. The court concluded that the statutory language, structure, legislative purpose, and safeguards supported the trial court’s $2.5 million sanctions award against the City. The court reversed the Court of Appeal’s contrary judgment.