By Colin McCarthy, J.D., Robinson & Wood, San Jose, CA

There’s been an awful lot of discussion around this blog regarding a landlord’s liability for personal injuries and property damage occasioned to tenants and third parties. It would seem like the landlord is exposed in all manner of fronts for all manner of different circumstances. Appearances notwithstanding, the blog readers will know that the issue of notice, control, and an opportunity to remedy are all important in California in determining whether a landlord owes a duty to protect someone from injury. If they do, more forward-planning readers might be thinking: “Well I’ll just protect myself by inserting a clause in my lease agreement that waives the tenant’s rights against me.” There are two problems with that.

The first is that in California, any such language is prohibited by statute (Civil Code §1953) and public policy. The statute provides that unless the lease is presented to the lessee before she takes possession of the property, any provision in a lease which purports to waive the lessor’s liability to the landlord for breach of a duty which leads to personal injury or property damage is void. This might suggest that if you show the lease agreement before the tenant takes possession, you might be able to work around it. Not so. Case law takes this exception away in the case of residential leases. The public policy behind it is that housing is important and difficult to come by, so a person should not be forced to waive these rights just to get a great apartment. So in California, you cannot require your tenant to waive the right to sue you for these types of injuries.

The second problem is that any such release would not inure to the landlord’s benefit regarding those other third parties who visit your tenant and get injured. The landlord still has to protect them from potentially dangerous conditions of which he is or should be aware, over which he has control, and over which he has an opportunity to exert that control. If he does, he should fix the problem, warn about it, or do something to prevent injury or damage to that third person.

It is always best to get counsel to review a lease agreement or draft it for you so that the agreement puts into effect those things you need to be in effect, does not have unnecessary verbiage (such as a clause referenced above), and which clearly spells out each party’s responsibilities, obligations, and rights under the agreement. A good lawyer can help the landlord or the tenant get what each needs. I recommend employing one.

This blog submission is only for purposes of disseminating information. It does not constitute legal advice. The statements in this blog submissions do not necessarily reflect the opinions of Robinson & Wood, Inc. or its clients. No attorney-client relationship is formed by virtue of reading this blog entry or submitting a comment thereto. If you need legal advice, please hire a licensed attorney in your state.

A guest post by Tracy Myers, homeinsurance.org, Houston, Texas

The importance of renters insurance really cannot be highlighted enough. Tenants often forget about renters insurance, because a lease is temporary and the property is not their own. Some believe that if their landlord already has the property insured, they have nothing to worry about, but if you think about it, you wouldn’t lease a car without purchasing car insurance. Not just because it would be illegal to not buy car insurance, but because your finances would be ruined if you were to get into a car accident or suffer some other form of loss. Although residents are not required by law to buy renters insurance, the financial ramifications of not having it are great.

Even if a landlord or property owner has insured the building, there are still many reasons why residents need renters insurance. For example:

To Cover the Loss of Personal Property

If a resident loses personal property (clothing, electronics, furniture, home ware, etc.) because of damage from fire or smoke, severe weather damage, theft, and more, they will be left to replace those items out of pocket if they don’t have renters insurance. With insurance, the depreciated value of their possessions will be covered. They can even upgrade the policy to cover the actual value. Just the thought of losing everything they own should be enough to convince them to insure their belongings. For those who believe they don’t own enough for it to matter, most people’s personal property is worth more than what they think. If they don’t have the extra cash to replace everything with their own money, they need to consider buying renters insurance, which only costs around $15 per month.

For Liability Protection

If some accident starts in a tenant’s home and the damage spreads to other homes, renters insurance will protect the tenant from any legal action. For example, if a neighbor suffers personal property loss or injury from a fire that started in another resident’s home, that resident will be protected from any potential legal action taken by the neighbor.

For Guest Medical Coverage

If a resident has a guest at their home who suffers injuries from an accident on the property, renters insurance can cover the medical expenses incurred by the incident. For example, if a guest gets bitten by the resident’s dog, the resident’s insurance policy will pay for all necessary medical treatment.

These reasons clearly show just how essential renters insurance is to the protection of your personal property and your personal finances. If you are a landlord or property manager, share this information with your tenants and encourage them to purchase a policy as soon as possible. If you are very serious about every tenant having insurance, consider making renters insurance a stipulation in the lease agreement. You can enforce this requirement by only giving a renter their apartment keys after they have shown an official copy of their policy. To be sure that every tenant maintains their policy, ask for an updated declaration of insurance every six months.

If you are timid about requiring renters insurance, consider this: many renters are only interested in leasing at properties that require it, because they know that it is important for all of their neighbors to be insured as well. Renters also like to see that their landlords care about their well-being.

Tracy Myers is a freelance blogger with a passion for helping others navigate the dark waters of personal finance. As a regular contributor to several consumer help websites, such as www.HomeInsurance.org, Tracy often covers topics related to personal property advice, retirement, and financial planning.

By Steve Boudreault, Buildium, Boston, MA

It’s about time that Buildium’s top wordsmith started writing blogs for All Things Property Management. So here I am and here we go!

I’m going to use my first ATPM blog to connect property management to my number-one passion: Star Trek. Specifically, Star Trek: Deep Space Nine (DS9).

Deep Space Nine focused on the space station of the same name, in orbit around a planet called Bajor. Originally an outpost of the evil Cardassians, it was built using Bajoran slave labor during The Occupation, which lasted nearly 50 years. When the Bajorans finally ousted the Cardassians, Starfleet sent officers to take over administration of the station, and try to help Bajor and the Bajorans get back on their feet.

The wrinkle comes in with the discovery of a stable wormhole that connects the area of space right around Bajor to the distant and completely unexplored Gamma Quadrant. Now instead of being at the end of a quiet cul-de-sac in space, Deep Space Nine is at the crossroads of a major interstellar highway. That’s progress for you.

So what connections does Deep Space Nine herself have to property management? I’m glad you asked:

• Responsibility. The station was built by Bajorans for the Cardassians but is administrated by Starfleet. So one of the first questions was this: Whose responsibility is it to clean up and repair the station, which the Cardassians were so kind to trash before they left? Is it the owner’s responsibility or the manager’s? Well, since this is science fiction (heavy on the fiction) the responsibility is shared. (Good luck getting that to work in real life.)
• Ownership. At one point later in the series, the Cardassians returned and reclaimed the station. Sure, they’re evil, but the station did belong to them. Should they have a claim to it? It’s in orbit around Bajor, so does that make it Bajoran property? Back here on Earth, when a property changes hands from one owner to another, it can be confusing and frustrating for property managers when they’re not sure to whom they’re answering.
• Tenancy. Deep Space Nine houses the staff who work there, but it also houses the merchants who operate businesses on the Promenade, visitors, dignitaries, allies, and pretty much anyone who’s passing through. And despite the kinder, gentler nature of Star Trek, not all races get along and things sometimes get heated. Similarly, property managers can face the challenges inherent in renting to people of different cultures, backgrounds, and beliefs.

Though fictional, DS9 dealt with many of the same issues that today’s property managers deal with. And though the writers were probably blissfully unaware, they taught us a thing or two about cooperation and compromise when it comes to running a property. Hopefully we can all take something away from it.

But only if we all watch it.

By Salvatore Friscia, San Diego Premier Property Management, San Diego, CA

I have to admit that recently I started watching a new cable show called “World’s Worst Tenants” on Spike TV. The premise for the show if you haven’t seen it depicts three individuals who are hired by various property management companies to handle unusually odd tenant related issues. The issues range from your basic nonpayment of rent to more bizarre and serious issues that can leave any self-respecting property manager shaking their head in disbelief. The show makes for great TV and entertainment, but on a serious note it can offer some insight to the importance of exterior and interior property inspections.

I noticed that usually the trio of characters hired to resolve the tenant related issues would indicate that the out of state owner or property manager had lost communication with the tenant and in most cases both were unaware of the property condition. This dangerous combination usually lead to disastrous situations leaving the rental property completely destroyed, and in some cases declared uninhabitable by city, state, and federal laws. I can’t help but think that regularly scheduled inspections would act as a deterrent in the outcome of some of these situations.Here at SDP Management our company policy is to conduct two exterior and one interior inspection annually. At the lease signing we advise the tenants of this policy and make it known that the property owner and the management company have a vested interest in making sure that the condition of the property is maintained. The exterior inspections are done randomly and documented via photo log. The interior inspections which are preceded by 24 hour written notice are detailed in a report. If concerns or violations are found during the course of either inspection, a notice of cure or solution to remedy the problem will be issued to the tenant before the situation gets out of control or causes damage to our client’s property.

Inspections are not intended to be viewed as “Big Brother” looming but more like a friendly reminder that the property management company will enforce the tenants contractual lease agreement to maintain the property in a certain condition. In some instances we hold raffle drawings and issue gift cards as a “Thank You” to unsuspecting tenants for maintaining curb appeal and general upkeep of their rental property. Keeping both parties happy (owners & tenants) may not always be easy but when you conduct regular exterior and interior inspections you may just avoid being on the next episode of “The World’s Worst Tenants.”

A guest post by Gabriel Knight, Mortgage Fit, Chicago, IL

It’s no secret that the still-sputtering economy has made it a rough go for property managers. After all, one of their primary responsibilities is making sure that rental properties are rented, and with still so many unemployed and underemployed folks out there, renting has become a real problem – the pool of eligible renters is shrinking.

But while things are tough for the property managers out there, it pales in comparison to the hardships that potential renters are facing. Keep in mind that many prospective tenants were homeowners before the recession came along and forced them into short sales, default, and foreclosure. These people have little rental experience or history, if any, so property managers have to question whether or not they’ll be able to pay their rent. Ironic, given that these people once managed to pay a mortgage every month.

Many of these potential renters are dealing with bad credit because of tough decisions they were forced to make regarding their homes. Often they are considered higher risks, so they face tougher standards, higher deposits, or rejected applications.

While there isn’t much property managers can do beyond waiting for the economy to stabilize, there are things potential tenants can do to better their chances of approval. For one, having pay stubs from a current job can show that your employment is ongoing and steady. And a reference from a former landlord, if you have one, helps as well. You can also run a free credit check on yourself through various online services so that you have an idea of what the landlord is going to see when they pull your report, and you can explain any extenuating circumstances that drove your FICO score down.

Of course, the best policy is to have first and last month’s rent and a security deposit ready for the property manager. That probably goes without saying, but ultimately that’s what the property manager is going to look for if they give you a shot. Potential tenants can also check with their local government’s Housing and Urban Development (HUD) department for expert advice.

Renting these days is hard, but not impossible. Preparation is key!

A guest post by Gabriel Knight, Mortgage Fit, Chicago, IL

While rental property investment might look like a rewarding and positive venture, managing both tenants and properties can be overwhelming. As such, you may need to hire a professional property manager to make your life easier. This is an especially good idea for rental property owners who have no experience or don’t want to spend their time managing a rental property on their own. With a property manager, you’ll be able to ask mortgage questions if you run into any trouble with your property. Here are some reasons why you should hire a residential property manager to manage your residential property properly.

Set the right price – You can look online to see what the other landlords are charging for the same kind of property to get an idea of the rent you should charge, but a good property manager will do a complete analysis of the market to choose a rental sweet spot. You’ll have the right balance between increasing your monthly income and preserving low rents.

Search for the right tenants – An experienced property manager can help you find the right tenants. The property manager also takes care of all the details related to your property, like sorting through legal issues, evaluating credit reports, verifying employment, performing security checks, and checking references. You’ll wind up with the best fit between property and tenant.

Collect and deposit the rent payments – If you have any experience in billing, you know that collecting payments from customers is not an easy task. Property managers have efficient systems to collect monthly rent from tenants in a timely manner. This is important when you’ve reached the threshold of properties that makes collecting rent too time-consuming.

Proper marketing of your property – An experienced property manager knows exactly where and how to advertise and market your property. He also knows how to time advertisements so your property can be rented quickly, thus avoiding long-term vacancies.

Maximize profits – Hiring a property manager will help you maximize profits on your rental property. A property manager usually receives a percentage of your property’s monthly rent in return for their services. This rate ranges between 6% and 10%, which is usually less than what you’d pay to hire a team of professionals to handle the things the property manager will handle/streamline.

Landlord/Tenant Relations – In addition to finding good tenants, a property manager will stay on top of things to maintain a good relationship between the tenants and the landlord. The property manager takes care of routine inspections and deals with every situation that comes up.

By hiring a good residential property manager, you’ll successfully reduce the risks involved in the real estate game. This makes the things much simpler and more enjoyable for you.

By Colin McCarthy, J.D., Robinson & Wood, San Jose, CA

As everyone knows, Monty Python and the Holy Grail is the greatest movie ever made. Especially for the scene involving the Killer Rabbit of Caerbannog. In it, several of the Knights of the Round Table are cut down in a blood bath by a particularly vicious, cute, cuddly white bunny rabbit. Why? They were not aware of its dangerous propensities! Their Scottish guide tried to warn them before the unlucky Knights marched into certain death. He tried, but they wouldn’t listen.*

We have already discussed the issue of control as being the hook on which a landlord will/can be liable for injuries related to property. If the landlord has control over the property in question, and could have taken steps to prevent an injury because of that control, they will not be able to avoid responsibility for injuries related to dangerous conditions on that property they control. Which leads to the obvious question: What about dogs?

Well, I mean animals. Cats, Parakeets, Vicious bunnies, etc. What’s a landlord to do about these animals? Well, again, it’s all very clear. It depends on how dangerous the particular animal is, what the landlord knows, and where the animal is.

If the animal is not on property the landlord controls, there is no duty. This is in accord with our earlier control discussion. However, if the animal is a permanent guest of the landlord’s tenant, the issue is two-fold:

1. The animal’s dangerous propensity.

2. The landlord’s knowledge of the same.

Regarding the first, the question focuses on the animal’s tendencies. Is it a vicious animal, i.e. does it have known behaviors that are likely or have a tendency to cause harm? For example, dogs that bite are construed as vicious. Even dogs which are unusually large and happy, that create a fall hazard, can be construed as being dangerous.

This was the issue in a case that I litigated a long time ago. The whole issue was whether a large dog had a known propensity to greet visitors in a particular fashion which subjected the visitors to a fall risk. The plaintiff was so greeted and injured herself. The issue was prior knowledge of the propensity and whether it was dangerous. The dog owner was the defendant, but the landlord might have been liable, IF . . .

The landlord had knowledge of the tenant’s animal’s dangerous propensities. If they had no knowledge of the animals, the landlord is not likely liable. If they did know, then they may be found liable for – wait for it – not removing the animal by evicting its owner. It is the failure to use reasonable care in this regard, if it leads to injury to a third party, which attaches liability.

The Scottish guide, in the Holy Grail, who had knowledge of the bunny’s dangerous propensities, did what the law might require of a landlord in California. He warned of the animals dangerous propensities. Had the guide owned or controlled the property on which the dangerous bunny was present, he could’ve and maybe should’ve evicted that owner, and thus protected any visitors to the premises from its vicious attacks!

* After several knights were felled by the vicious bunny, the rest of the knights and King Arthur had to resort to the old reliable: Holy Hand Grenade of Antioch.

This blog submission is only for purposes of disseminating information. It does not constitute legal advice. The statements in this blog submission do not necessarily reflect the opinions of Robinson & Wood, Inc. or its clients. No attorney-client relationship is formed by virtue of reading this blog entry or submitting a comment thereto. If you need legal advice, please hire a licensed attorney in your state.

By Linda Day Harrison, theBrokerList, Chicago, IL

In the history of property ownership and property management, as far back as the Stone Age (maybe not that far back), we have always called our customers “tenants” and for some reason it just stuck like glue. We can try to shake the term, but no matter how we spin it, turn it, or twist it the relationship comes back full circle to calling them “tenants” and not customers. It is rather maddening to say the least. Even though I preach this and believe it, I catch myself using the term because nobody understands who I am speaking about when I say “customer!”

What drives me batty is that when you consider all of the blood, sweat, and tears we put into marketing, promotions, “tenant” retention, newsletters, “tenant” parties, and “tenant” appreciation, why do we not refer to our “tenants” as customers? It just does not make logical sense.

If you go to Disney World, the tourists are called “guests” NOT “tourists”! Disney had a good idea and they pushed that idea so hard that it is ingrained in everybody, including the “guests!” If you have ever been to Disney World or Disney Land you know what I mean. The point is Disney believed that each person who entered “the property” was a guest and NOT a tourist or even a customer. Disney wants everyone to feel special and privileged, just like a guest.

So back to my original point, why in our industry of property management, do we not refer to our valuable tenants as customers? I think we need to understand this concept; even if we are stuck on the word “tenant” the meaning still needs to be customer. As an industry, let us all put the word “customer” back on the table. First of all, let’s start with who our customer is, as that may be the core of our problem. The conflict now arises in your mind because you are all thinking, “Wait a minute Linda, the owner of the property is my customer too!” Yes, that is correct and that is a fact for us as property managers. Without our property owner, we have no job! So, our property owners are customers as well. Now there is a pull and tug for some of us. It may also cause a debate. Which customer do you please or better yet which customer is more important?

The answer is quite simple. You do what makes both customers happy! Yes, it is actually achievable. Okay, so there are exceptions to everything, but for the most part, if your customers are happy, your other customers are happy too!

How? Well for instance, every single time a customer (tenant) moves in, your customer (property owner) is happy. Now, the job is to keep that customer (tenant) happy so they do not move out. Again, that is keeping your customer (property owner) happy. What is the point of doing all of the work to keep a customer (spending money on improvements, marketing, and signs), and then they move out of your property because of something you control? So what does this boil down to? Customer service, of course! Customer service is the core of it all. You can twist it, turn it, tweak it and maneuver it, but no matter what you say or do, good customer service will always win! Is it easy? Absolutely not! Nobody said our jobs were easy. Remember, if it were easy, they would not need us. (Read Circle of (A Property’s) Life).

However, no matter the difficulty, your job must be done to the best of your ability; with the talent and the cards you have been dealt. You owe that to your customer (property owner), and by contract you are legally obligated to deliver those services. The same holds true for the other customer (tenant) because they too have signed a contract (lease). Funny how there are so many parallels to these business relationships.

For example, if you manage a building that was built in 1904 you cannot expect it to perform like a building that was built in 2012! So if you think your building is old or tired and needs upgrading, you are probably correct. However, it should still be impeccably clean, painted, safe, and in good repair. No it is not high-tech or state of the art, but those occupying the property and those who own the property expect you to do the best you can with what you have! In other words, if you know who your customer is at all times, you can deliver what the customer needs and cater to what is there, not what is not there.

Now that you understand these simple points you need to go back and think of ways to deliver the excellence. Every single day we need to ask ourselves and our team, “What have we done for our customers (tenants and owners) today?” Make this a question your entire team thinks about. What is it that you can do around your property that would actually please your customers? For a property owner customer it may be timely information, accurate reports, 100% occupancy, community awards, maximization of real estate value, and return calls, etc. For the tenant customer it might be clean common areas, friendly staff, responsive maintenance technicians, follow up, etc. In any case, no matter what type of property it is and no matter its age, there is always room for improvement. Just keep the focus on customer service every single day, and you will naturally begin to deliver the excellence all of your customers expect!

By Colin McCarthy, J.D., Robinson & Wood, San Jose, CA

I once lived in a house in downtown San Jose that was next to an abandoned “historic” house. The house was only abandoned because it was “historic.” The city had an ordinance that prevented the owner from demolishing the building and rebuilding it, or selling it. Because the house was built before a certain time, the city ordinance prohibited him from doing anything with the property other than fixing it up. Rather than doing that, in protest, he did nothing with the property. And I mean nothing, other than board it up.

Mistake! You see it was downtown San Jose. It was right in the middle of urban, night time activities. The abandoned home soon became a sort of an attractive spot for the seedier and less fortunate souls. We frequently had to call the police. There were the typical late night guests, drinking, broken glass, and other non-printable activities going on in there. After enough of these visits, the neighbors reported the landlord to the city, and hearings were held. Fines were levied. Landlords got mad. Fences were put up.

Pulling the restrictive ordinance and the obstinacy of the landlord out of the equation, the landlord had a duty to know what was going on at his property. He should have inspected it, even if he did not have tenants.

What kinds of things can happen, from a legal perspective, if you do not inspect and repair? What will happen if the property falls into disrepair under your watch? Well, you can be sued for breach of contract. But if it gets really bad, you can be sued for a tort, too. How about for emotional distressed caused by an uninhabitable residence? For unfair business practices?

At least in California you can. Consider the facts in a case we cited in a recent post:

“Regarding the condition of the subject premises, appellant alleged that: ‘On or about October 8, 1974, to the present, numerous defective and dangerous conditions were in existence, including, but not limited to leaking of sewage from the bathroom plumbing; defective and dangerous electrical wiring; structural weaknesses in the walls; deteriorated flooring; falling ceiling; leaking roof; dilapidated doors; broken windows; and other unsafe and dangerous conditions. These defective conditions were unknown to plaintiff at the time she moved in to the premises, but as she continued to live on the premises, she became increasingly aware of them.” (Italics added.)

Also attached to the complaint was a copy of the Kern County Health Department’s notice to vacate and demolish the subject premises, which listed the following violations among others: heavy cockroach infestation, broken interior walls, broken deteriorated flooring on front porch, falling ceiling, deteriorated, overfused electrical wiring, lack of proper plumbing connection to sewage system in bathroom, sewage under bathroom floor, leaking roof, broken windows, and fire hazard.”*

Pretty bad, no doubt. But this particular landlord was sued not only for rent, but for the intentional infliction of emotional distress the tenant suffered. She repeatedly asked for repairs and informed the landlord of these problems. He did nothing. She informed him again. He did nothing. She did what all smart people do in such circumstances. She talked to a lawyer and sued.

At first it did not look good. The trial court limited her to breach of implied warranty of habitability, and limited her damages to rent payment. The appellate court disagreed, and allowed her to sue for all manner of civil wrongs related to the landlord’s alleged intentional neglect.

And although it’s not a discussion for this post, most insurance policies do not cover damages caused by intentional conduct. So not only was this landlord being sued, his insurance company might not have paid for any award against him.

So remember. If a tenant asks for a repair, don’t ignore. Inspect.

*Stoiber v. Honeychuck, 101 Cal. App. 3d 903, 912 (1980)

This blog submission is only for purposes of disseminating information. It does not constitute legal advice. The statements in these blog submissions do not necessarily reflect the opinions of Robinson & Wood, Inc. or its clients. No attorney-client relationship is formed by virtue of reading this blog entry or submitting a comment thereto. If you need legal advice, please hire a licensed attorney in your state.

By Colin McCarthy, J.D., Robinson & Wood, San Jose, CA

I enjoyed philosophy classes in college. I enjoyed thinking about such questions, as: If a tree falls in the forest and no one hears it, does it make a sound? I enjoyed even more Bart Simpson’s reply to the question: What is the sound of one hand clapping? (He immediately held up his one hand and patted his fingers against his palm, making a muted clapping sound).

My enjoyment of these questions has found a natural outlet in the law. The law ostensibly provides you with an answer, whether it be found in a book, or in a code section, or recommended by experts. So it is one of those questions today that is our focus: If a tenant hurts himself in an apartment and the landlord did not know about the condition which caused the injury, was the landlord at fault?

As is always the case, the answer in law is perfectly clear: it depends. There is a duty to inspect premises when the property is given to the tenant. Landlords are in the best position to assess the relative safety of the property before the tenant takes control, so they should inspect and repair as needed. The inspection should comport with general negligence principles – i.e. be “reasonable” and make it “reasonably safe.” *

Yes, but how do we know if it is reasonable? Well that answer is clear and simple and straightforward: it depends. It depends on the facts of your case! In California:

“The burden of reducing or avoiding the risk and the likelihood of injury will affect the determination of what constitutes a reasonable inspection. The landlord’s obligation is only to do what is reasonable under the circumstances. The landlord need not take extraordinary measures or make unreasonable expenditures of time and money in trying to discover hazards unless the circumstances so warrant.”**

Clear as mud, right? So we fall back on common sense. If you are intimately familiar with the property you are about to rent – having lived there for five years – your duty to inspect probably is not great. You know what works, what does not, what is likely to injure (hopefully not much), and what is not. You know where the cracks in the slab in the garage are. In contrast, if you are not familiar with the property, you ought to conduct a more thorough inspection. If you just bought the property and have not had extensive time with it, you might consider a more thorough inspection. You might document what you find and give it to the tenant in writing, or repair as required.

Obviously, as we’ve discussed previously, if the inspection uncovers something dangerous, you ought to repair the condition before giving possession to the tenant. But if there is an open and obvious condition that is itself a warning to and is patent to the tenant that it is dangerous, the landlord might not be liable for any resultant injuries.

And further, if one possesses legal title but does not yet have control – that key word in our liability analysis – they cannot be held liable for injuries. If they have no opportunity to inspect and/or repair, their liability is usually precluded.

*Swanberg v. O’Mectin, 157 CA3d 325 (1984)

**Mora v. Baker Commodities, Inc., 210 Cal. App.3d 771, 782 (1989)

This blog submission is only for purposes of disseminating information. It does not constitute legal advice. The statements in these blog submissions do not necessarily reflect the opinions of Robinson & Wood, Inc. or its clients. No attorney-client relationship is formed by virtue of reading this blog entry or submitting a comment thereto. If you need legal advice, please hire a licensed attorney in your state.