Trial courts have broad authority issue discovery sanctions

In City of Los Angeles v. Pricewaterhousecoopers, the Supreme Court today reinstated a $2.5 million discovery sanction against the City of Los Angeles, reversing an opinion by the Second Appellate District, Division Five, which held that the sanction exceeded the trial court’s authority.

This passage from the Supreme Court’s unanimous opinion succinctly summarizes the court’s holding that trial courts have broad discretion to impose sanctions for a wide variety of discovery misconduct:

Under the general sanctions provisions of the Civil Discovery Act, Code of Civil Procedure sections 2023.010 and 2023.030, the trial court had the authority to impose monetary sanctions for the City’s pattern of discovery abuse. The court was not limited to imposing sanctions for each individual violation of the rules governing depositions or other methods of discovery. We reverse the Court of Appeal’s judgment to the contrary.