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Consistency is one of the most important values of our judicial system. Without steady, reliable, and (reasonably) predictable decisions, the courts would be in disarray. The doctrine of stare decisis is one method of ensuring this value is upheld. Stare decisis is a legal principle that requires courts to adhere to precedent in rendering their decisions. When a court is called upon to resolve a legal dispute, it should be bound by similarly decided cases. In some jurisdictions, this rule applies horizontally (applying decisions of the same court); California applies vertical stare decisis (applying decisions from higher courts). The concept of stare decisis was clarified in a California Supreme Court case, Auto Equity Sales, Inc. v. Superior Court. Here, Gusdorff Law examines a few of the lessons learned from that decision.
Stare Decisis in the California Courts
The seminal application of stare decisis was outlined in a California Supreme Court decision, Auto Equity Sales, Inc. v. Superior Court. The Court discussed a case from the superior court in Santa Clara County which disregarded a Court of Appeal decision. A lower municipal court had correctly concluded it was bound by the Court of Appeal decision (known as Kroiss). But the superior court’s appellate division refused to apply Kroiss. Although recognizing that Kroiss was on point, the court decided nonetheless that it was improperly decided.
But this is not the purview of courts of inferior jurisdiction. All courts are required to faithfully apply precedent from courts of superior jurisdiction. Here, the appellate division of the superior court admitted that Kroiss, as decided, would result in a particular outcome. However, the court refused to render that outcome by deciding the Kroiss decision was erroneous. In this way, the court exceeded its jurisdiction.
Appellate divisions of superior courts had been operating under a different rule not long before the Auto Equity Sales decision. These courts were not subject to appellate review except by the use of original writs in exceptional cases. But the Court clarified that not binding all lower courts by higher ones would create “chaos in our legal system.”
As Auto Equity Sales held, “all tribunals exercising inferior jurisdiction are required to follow decisions of courts exercising superior jurisdiction.” Decisions of every division of the District Courts of appeal are binding on all lower courts. This includes superior courts, whether they are acting as trial or appellate courts. Lower courts simply do not have the jurisdiction to overrule higher courts.
What About Conflicting Appellate Court Decisions?
This general rule does not apply where there is more than one conflicting appellate court decision. In a situation like this, the lower court must essentially choose which higher court decision it will follow. But a court cannot disingenuously interpose another decision to create a conflict with a decision it doesn’t wish to follow. The superior court in Auto Equity Sales tried to do this. The Supreme Court concluded the other Court of Appeal decision (White) did not announce a rule contrary to that of Kroiss.
Gusdorff Law applies the principle of stare decisis to enhance the work we do on behalf of our clients. We also recognize when parties are disregarding stare decisis to attempt to gain an advantage. We also understand arguments to avoid its application in certain circumstances. Our firm has developed a strong reputation of understanding the numerous principles that govern our courts. Turn to us for all of your California appellate legal needs.
