California Code of Civil Procedure Section 187

"Under Code of Civil Procedure, section 187, the court has the authority to amend the judgment to add a judgment debtor. " (Carr v. Barnabey's Hotel Corp. (1994) 23 Cal.App.4th 14, 20 (Carr).) "'As a general rule, "a court may amend its judgment at any time so that the judgment will properly designate the real defendants."'" (Greenspan v. LADT, LLC (2010) 191 Cal.App.4th 486, 508.) "'The greatest liberality is to be encouraged in the allowance of such amendments in order to see that justice is done.' " (Carr, supra, 23 Cal.App.4th at p. 20.) The Court cited Triplett v. Farmers Ins. Exchange (1994) 24 Cal.App.4th 1415 (Triplett) for the holding that "the ability under section 187 to amend a judgment to add a defendant, thereby imposing liability on the new defendant without trial, requires both (1) that the new party be the alter ego of the old party and (2) that the new party had controlled the litigation, thereby having had the opportunity to litigate, in order to satisfy due process concerns." (Id. at p. 1421.) A related line of cases holds that "even if all the formal elements necessary to establish alter ego are not present, an unnamed party may be included as a judgment debtor if 'the equities overwhelmingly favor' the amendment and it is necessary to prevent an injustice. " (Carolina Casualty Ins. Co. v. L.M. Ross Law Group, LLP (2012) 212 Cal.App.4th 1181, 1188-1189 (Carolina Casualty); see also Carr, supra, 23 Cal.App.4th at pp. 21-23.) "The trial court's decision to amend a judgment to add a judgment debtor is reviewed for an abuse of discretion. Factual findings necessary to the court's decision are reviewed to determine whether they are supported by substantial evidence. " (Carolina Casualty, supra, 212 Cal.App.4th at p. 1189.)