L.A. Unified School Dist. v. Super. Ct. - Case Brief

Case Number: S269608
Court: California Supreme Court
Date Filed: September 02, 2025

Holding

The court held that the treble‑damage award authorized by Code Civ. Proc. § 340.1(b)(1) functions as punitive or exemplary damages and therefore is prohibited against a public entity by Government Code § 818, which immunizes public bodies from damages “imposed primarily for the sake of example and by way of punishing the defendant.”

Narrative

Lead
In a decision that sharpens the boundary between victim‑compensation schemes and the sovereign‑immunity shield protecting public bodies, the California Court of Appeal affirmed a lower‑court order striking a plaintiff’s request for treble damages under the “cover‑up” provision of Code Civ. Proc. § 340.1(b)(1). The ruling confirms that, despite the legislature’s intent to encourage accountability for childhood sexual‑assault cover‑ups, the statutory language of Government Code § 818 precludes the imposition of any damages that are “primarily punitive” on a public entity such as a school district.

Procedural History
Jane Doe, a former student of Los Angeles Unified School District (the District), sued the District and the employee who allegedly assaulted her, alleging sexual abuse, intentional infliction of emotional distress, and sexual harassment. In addition to ordinary compensatory damages, Doe sought treble damages under § 340.1(b)(1), which the 2019 amendment to the statute permits when a plaintiff proves that the assault resulted from a “cover‑up.” The District moved to strike the treble‑damage claim, arguing that Government Code § 818 barred such an award. The trial court denied the motion, interpreting the treble‑damage provision as “compensatory, not punitive.” The District appealed, and the Court of Appeal granted a writ, directing the trial court to strike the treble‑damage request. The District then petitioned the California Supreme Court for review, which granted certiorari and issued the opinion summarized here.

Facts
Doe attended Daniel Pearl Magnet High School, operated by the District, during the 2014‑15 school year. While a school aide at a different campus, employee Daniel Garcia entered a “boyfriend‑girlfriend” relationship with another student, H.M., in early 2014. The District learned of this relationship but did not terminate Garcia; instead, it transferred him to the high school where Doe was enrolled. Garcia allegedly began “special attention” toward Doe—rubbing her legs, holding her hand, and sending flirtatious texts. In November 2014, Garcia sexually assaulted Doe. After the assault, Doe’s parents reported the conduct to police; Garcia was arrested in May 2016.

The complaint alleges that the District, aware of Garcia’s prior misconduct, fabricated a false employment‑date report to conceal his earlier relationship with H.M., thereby “covering up” Garcia’s prior sexual misconduct. The plaintiff contends that this alleged cover‑up enabled Garcia’s later assault of Doe. Against Garcia, Doe seeks ordinary tort damages and punitive damages. Against the District, she asserts negligence, a failure to report suspected child abuse, and, crucially, treble damages under § 340.1(b)(1) for the alleged cover‑up.

Issues

Does Government Code § 818, which bars public entities from “damages…imposed primarily for the sake of example and by way of punishing the defendant,” preclude the award of treble damages under Code Civ. Proc. § 340.1(b)(1) against a public entity?
If so, is the treble‑damage provision in § 340.1(b)(1) “primarily punitive” despite the legislature’s language that the award is “unless prohibited by another law”?

Court’s Analysis

Statutory Framework
The Court began by dissecting the two statutes at issue. Government Code § 818 expressly shields public entities from damages “awarded under Section 3294 of the Civil Code or other damages imposed primarily for the sake of example and by way of punishing the defendant.” The phrase “primarily” signals a broader sweep than the narrower “simply and solely” language used in earlier case law. The Court emphasized that the Legislature deliberately used “primarily” to capture any award whose chief purpose is punitive, even if it has ancillary remedial effects.

Code Civ. Proc. § 340.1(b)(1) was enacted in 1986 to extend the statute of limitations for childhood sexual‑assault claims. The 2019 amendment (AB 218) added a treble‑damage remedy for plaintiffs who prove the assault resulted from a “cover‑up.” The statutory text states that a plaintiff “may recover up to treble damages…unless prohibited by another law,” a clear reference to the Government Claims Act and, by implication, to § 818.

Characterizing Treble Damages
The Court surveyed California precedent on treble damages, noting that courts have repeatedly labeled such awards “exemplary” or “punitive” (e.g., Imperial Merchant Services; Harris v. Capital Growth Investors XIV; Circle Oaks Sales Co. v. Smith). While acknowledging that treble damages can sometimes serve a remedial purpose, the Court held that the decisive inquiry is whether the award is “primarily” punitive. The presence of a multiplier that can exceed the plaintiff’s actual loss, coupled with the statutory language “unless prohibited by another law,” demonstrates legislative intent that the award is meant to punish and deter cover‑ups, not merely to compensate.

Application of § 818
The Court applied its own interpretive framework for § 818, which requires a fact‑specific analysis of whether the damages “function, in essence, as punitive or exemplary.” The analysis includes (1) whether the award exceeds the amount necessary to fully compensate the plaintiff; (2) whether the award is conditioned on morally culpable conduct; (3) whether the award involves discretionary discretion by the fact‑finder; and (4) whether the award serves a deterrent function. The treble‑damage provision satisfies each factor: it can inflate recovery beyond actual loss, it is triggered only by proof of a cover‑up (a morally reprehensible act), it leaves the jury to decide the multiplier within statutory limits, and its purpose is expressly deterrence of future cover‑ups.

Overruling Narrow Interpretations
The Court expressly overruled People ex rel. Younger v. Superior Court, San Francisco Civil Service Assn. v. Superior Court, and Kizer v. County of San Mateo to the extent those cases limited § 818 to damages that are “simply and solely” punitive. The Court argued that “simply” and “solely” are inconsistent with the statutory term “primarily,” and that the earlier cases artificially narrowed the immunity shield, contrary to legislative intent.

Conclusion
Because the treble‑damage award under § 340.1(b)(1) is “primarily punitive,” it is barred by Government Code § 818. Accordingly, the Court affirmed the Court of Appeal’s order striking the treble‑damage claim and the related cover‑up allegations against the District.

Impact and Unresolved Issues

The decision solidifies the principle that any statutory damages scheme that includes a multiplier—whether labeled “treble,” “double,” or otherwise—will be scrutinized under § 818 when the defendant is a public entity. Practitioners representing municipalities, school districts, or other governmental bodies can now rely on § 818 to defeat enhanced‑damage claims that are framed as “compensatory” but functionally serve a punitive purpose.

The ruling also clarifies that the “unless prohibited by another law” catch‑all in § 340.1(b)(1) was intended to incorporate § 818, effectively limiting the legislature’s ability to impose punitive‑style awards on sovereign entities without an explicit waiver. Future legislative attempts to expand victim compensation must either (a) craft a compensatory‑only remedy that does not exceed actual loss, or (b) include a clear, express waiver of § 818 immunity.

Unresolved questions remain regarding the line between “primarily punitive” and “primarily compensatory” in statutes that blend both goals. For example, statutes that provide for “enhanced” damages tied to a specific injury‑type but capped at a modest multiplier may still be vulnerable to § 818 challenges. Additionally, the decision leaves open whether a statutory “penalty” that funds a public‑policy program—such as environmental civil penalties—could be deemed permissible despite a punitive flavor, as earlier cases (e.g., Younger) have allowed penalties that serve a remedial purpose.

Finally, the Court’s overruling of Younger and its progeny may invite further appellate review of other § 818 applications, especially where lower courts have relied on the “simply and solely” test. Practitioners should anticipate renewed litigation over the scope of § 818 in contexts ranging from labor‑code penalties to health‑code enforcement actions.

Referenced Statutes and Doctrines

Government Code § 818 – Immunity of public entities from damages “imposed primarily for the sake of example and by way of punishing the defendant.”
Code Civ. Proc. § 340.1(b)(1) – Treble‑damage award for childhood sexual‑assault victims who prove a “cover‑up.”
Civil Code § 3294(a) – Punitive damages for oppression, fraud, or malice.
Government Claims Act (Gov. Code §§ 810‑822) – Framework for tort claims against public entities.
Doctrine of Sovereign Immunity – Public entities shielded from punitive damages absent clear legislative waiver.
Statutory Interpretation Principles – Plain‑meaning rule, “primarily” vs. “simply and solely,” legislative intent analysis.

Major Cases Cited

Los Angeles Unified School Dist. v. Superior Court, 64 Cal. App. 5th 549 (2021) (Court of Appeal decision affirmed).
X.M. v. Superior Court, 68 Cal. App. 5th 1014 (2021).
K.M. v. Grossmont Union High School Dist., 84 Cal. App. 5th 717 (2022).
People ex rel. Younger v. Superior Court, 16 Cal. 3d 30 (1976).
San Francisco Civil Service Assn. v. Superior Court, 16 Cal. 3d 46 (1976).
Kizer v. County of San Mateo, 53 Cal. 3d 139 (1991).
Imperial Merchant Services, Inc. v. Hunt, 47 Cal. 4th 381 (2009).
Harris v. Capital Growth Investors XIV, 52 Cal. 3d 1142 (1991).
Circle Oaks Sales Co. v. Smith, 16 Cal. App. 3d 682 (1971).
DuBois v. Workers’ Comp. Appeals Bd., 5 Cal. 4th 382 (1993).
Wells v. One2One Learning Foundation, 39 Cal. 4th 1164 (2006).
Miller v. Municipal Court, 22 Cal. 2d 818 (1943).
Brunswick Corp. v. Pueblo Bowl‑O‑Mat, Inc., 429 U.S. 477 (1977).

These authorities collectively shape the Court’s reasoning that treble damages, when applied to a public entity, constitute “primarily punitive” awards barred by Government Code § 818.

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