Landlord–tenant
Civ. Code § 1717 and unilateral fee clauses in unlawful detainer
8 authorities
Read the memo →Employment
§ 226.7 premium pay — wage or penalty, and the derivative claims
6 authorities
Read the memo →Family
Move-away custody: Fam. Code § 7501 and the Burgess / LaMusga line
6 authorities
Read the memo →20
Citations across the three memos
0
Fabricated citations — every case was confirmed to exist in a public database before it was cited, and the link is in the ledger
9 / 17
Case pinpoints confirmed from the text we actually retrieved. The other 8 are labelled inferred from the citation rather than passed off as read. The remaining 3 citations are statutes, cited by subdivision
The full ledger
One row per authority, across all three memos. This is the same instrument an independent blind audit of every citation runs against on 2026-09-28 — and that result gets published here whichever way it goes.
| Authority | Citation | Pinpoint | Pinpoint confirmed? | Source |
|---|---|---|---|---|
| California Civil Code § 1717 (a) Makes any contractual attorney's-fees clause mutual; prevailing party recovers fees 'whether he or she is the party specified in the contract or not.' (b)(1) Court determines prevailing … | Cal. Civ. Code § 1717 | subd. (a); subd. (b)(1); subd. (b)(2); subd. (c) | n/a — statute | open |
| Hsu v. Abbara California Supreme Court foundational § 1717 reciprocity case: 'When a contract contains a provision granting either party the right to recover attorney fees in the event of litigation on th… | (1995) 9 Cal.4th 863; 891 P.2d 804; 39 Cal. Rptr. 2d 824 | 9 Cal.4th at 865 (confirmed from API snippet star-page *Page 865) | Confirmed | open |
| Santisas v. Goodin California Supreme Court: § 1717 enacted to prevent fee clauses from operating 'in an unfairly one-sided manner'; creates a 'reciprocal right to such fees whenever an attorney fees clause be… | (1998) 17 Cal.4th 599; 951 P.2d 399; 71 Cal. Rptr. 2d 830 | 17 Cal.4th at 599 (confirmed from API snippet star-page *599 for majority); Baxter, J. concurrence pinpoint not retrieved from full text | Confirmed | open |
| Beverly Hills Properties v. Marcolino Appellate Division applied § 1717 directly in an unlawful detainer case: 'an order in an unlawful detainer case requiring appellant to pay legal fees to respondent, the prevailing party, pur… | (1990) 221 Cal.App.Supp.3d 7; 270 Cal. Rptr. 605 | 221 Cal.App.Supp.3d at 7 (opening of opinion, confirmed from citation; star-page not explicit in API snippet) | Inferred | open |
| Honey Baked Hams, Inc. v. Dickens California Court of Appeal: After landlord voluntarily dismissed UD action premised on commercial lease, trial court awarded defendant-tenant attorney fees 'pursuant to the express terms of … | (1995) 37 Cal.App.4th 421; 43 Cal. Rptr. 2d 595 | 37 Cal.App.4th at 423 (confirmed from API snippet star-page *Page 423) | Confirmed | open |
| de la Cuesta v. Benham California Court of Appeal: § 1717 governs prevailing-party determination in UD action for unpaid rent. 'This case tests the limits of a trial court's discretionary authority to determine th… | (2011) 193 Cal.App.4th 1287; 123 Cal. Rptr. 3d 453 | 193 Cal.App.4th at 1290 (confirmed from API snippet star-page *1290) | Confirmed | open |
| 511 S. Park View, Inc. v. Tsantis Appellate Division affirmed $12,375 attorney fees award to prevailing tenant-defendants following UD court trial. Landlord argued lease capped fees; Appellate Division disagreed and affirmed… | (2015) 240 Cal.App.Supp.4th 44; 193 Cal. Rptr. 3d 517 | 240 Cal.App.Supp.4th at 44 (opening of opinion; star-page not explicit but opinion begins at p. 44 per citation) | Inferred | open |
| Crasnick v. Marquez Appellate Division: Court granted defendant-tenant Diaz's motion for attorney fees after judgment against landlord in UD action. 'Judgment was rendered against plaintiff Donald Crasnick . . … | (2016) 248 Cal.App.Supp.4th 1; 203 Cal. Rptr. 3d 613 | 248 Cal.App.Supp.4th at 1 (opening of opinion; opinion begins at p. 1 per citation) | Inferred | open |
| Murphy v. Kenneth Cole Productions, Inc. The § 226.7 'one additional hour of pay' constitutes wage compensation, not a penalty. The Legislature intended the payment to compensate employees for work performed during a missed break, … | 40 Cal.4th 1094, 155 P.3d 284 (Cal. 2007) | 1099, 1103 (wage/not-penalty holding); 1104, 1109 (wage-for-work-performed rationale) | Confirmed | open |
| Naranjo v. Spectrum Security Services, Inc. Confirmed Murphy: missed-break premium pay constitutes wages for purposes of Lab. Code § 203, and waiting-time penalties are available if premium pay is not timely paid at separation. Disapp… | 13 Cal.5th 93 (Cal. 2022) | unretrieved — CourtListener API returned no citation string or pinpoint text for this opinion in this run | Inferred | open |
| Brinker Restaurant Corp. v. Superior Court Foundational meal period authority: employer has affirmative duty to provide (not merely permit) meal periods in compliance with Labor Code and IWC wage orders. Noncompliance triggers the § … | 53 Cal.4th 1004, 139 Cal.Rptr.3d 315, 273 P.3d 513 (Cal. 2012) | 1004 (caption/start); internal pinpoints unretrieved this run | Confirmed | open |
| Kirby v. Immoos Fire Protection, Inc. Lab. Code § 1194 attorney fee-shifting (for prevailing parties on minimum wage and overtime claims) does NOT extend to § 226.7 claims. Does not affect § 203 waiting-time liability; Naranjo (… | 53 Cal.4th 1244, 140 Cal.Rptr.3d 173, 274 P.3d 1160 (Cal. 2012) | 1244 (caption/start); internal pinpoints unretrieved this run | Confirmed | open |
| Ferra v. Loews Hollywood Hotel, LLC 'Regular rate of compensation' in Lab. Code § 226.7(c) is synonymous with 'regular rate of pay' under § 510(a) and includes all nondiscretionary remuneration for work performed, not just bas… | 11 Cal.5th 858, 280 Cal.Rptr.3d 783, 489 P.3d 1166 (Cal. 2021) | 858 (caption/start); internal pinpoints unretrieved this run | Confirmed | open |
| Donohue v. AMN Services, LLC Time records showing noncompliant meal periods (e.g., records reflecting a short or missing punch) create a rebuttable presumption of a § 226.7 violation at summary judgment. Employer may no… | 11 Cal.5th 58, 275 Cal.Rptr.3d 422, 481 P.3d 661 (Cal. 2021) | 58 (caption/start); internal pinpoints unretrieved this run | Confirmed | open |
| California Family Code § 7501 (a) A parent entitled to the custody of a child has a right to change the residence of the child, subject to the power of the court to restrain a removal that would prejudice the rights or w… | Cal. Fam. Code § 7501 | subd. (a); subd. (b) | Confirmed | open |
| California Family Code § 3024 In making an order for custody, the court may specify that a parent shall notify the other parent of plans to change the child's residence for more than 30 days (unless prior written agreeme… | Cal. Fam. Code § 3024 | complete section (single subdivision) | Confirmed | open |
| In re Marriage of Burgess California Supreme Court: Custodial parent (sole physical custody) has presumptive right to relocate under Family Code § 7501. Burden on noncustodial parent to show proposed move would cause… | (1996) 13 Cal.4th 25; 913 P.2d 473; 51 Cal.Rptr.2d 444 | 13 Cal.4th at 32–34 (§ 7501 basis); 37–38 (no necessity requirement); 39–41 (detriment standard and burden) | Inferred | open |
| In re Marriage of LaMusga California Supreme Court: Reaffirmed Burgess; elaborated non-exhaustive factors for trial court to consider once noncustodial parent makes prima facie showing of detriment (including childre… | (2004) 32 Cal.4th 1072; 88 P.3d 81; 12 Cal.Rptr.3d 356 | 32 Cal.4th at 1078–1080 (Burgess reaffirmed); 1095–1096 (factors); 1100–1101 (burden shifting) | Inferred | open |
| Montenegro v. Diaz California Supreme Court: Burgess presumption (and changed-circumstances standard) applies only where custody was established through an independent judicial determination on the merits. Whe… | (2001) 26 Cal.4th 249; 27 P.3d 289; 109 Cal.Rptr.2d 575 | 26 Cal.4th at 254–258 (final vs. non-final distinction; de novo best interests for stipulated orders) | Inferred | open |
| In re Marriage of Brown and Yana California Supreme Court: Where parents share joint physical custody pursuant to a final judicial custody determination, the Burgess presumptive right does not apply. Trial court uses de nov… | (2006) 37 Cal.4th 947; 127 P.3d 28; 38 Cal.Rptr.3d 610 | 37 Cal.4th at 955–958 (joint physical custody; no Burgess presumption) | Inferred | open |