California Supreme Court

New England Country Foods v. Vanlaw Food Products

April 24, 2025

Summary

The court answered a certified question by holding that Civil Code section 1668 invalidates contractual limitations on damages for willful injury to another's person or property, not merely complete releases of liability. It rejected a context-dependent inquiry for such provisions and distinguished pure contractual breaches, for which liability limitations generally remain governed by contract principles absent an independent duty within section 1668.