California Landmark Cases on Defendant's Misrepresentation

To show injury caused by a defendant's misrepresentation, common law principles require that a plaintiff establish the element of reliance. (Mirkin v. Wasserman (1993) 5 Cal.4th 1082, 1088, 1092.) Reliance exists when "'the representation has played a substantial part, and so has been a substantial factor, in influencing [the plaintiff's] decision.'" (Engalla v. Permanente Medical Group, Inc. (1997) 15 Cal.4th 951, 977.) Reliance also incorporates the concept of a material misrepresentation that underlies actionable fraud; i.e., "'"A misrepresentation of fact is material if it induced the plaintiff to alter his position to his detriment. Stated in terms of reliance, materiality means that without the misrepresentation, the plaintiff would not have acted as he did."'" (Caro v. Procter & Gamble Co. (1993) 18 Cal.App.4th 644, 668.) It must appear, however, not only that the plaintiff acted in reliance on the misrepresentation but also the plaintiff was justified in doing so. (Blankenheim v. E. F. Hutton & Co. (1990) 217 Cal.App.3d 1463, 1474 ; Hadland v. NN Investors Life Ins. Co. (1994) 24 Cal.App.4th 1578, 1586 [fraud requires proof of false representation and plaintiff's reasonable reliance].) Moreover, under California law, whether reliance was reasonable is a question of fact for the jury, and may be decided as a matter of law only if the facts permit reasonable minds to come to just one conclusion. (Boeken v. Philip Morris, Inc. (2005) 127 Cal.App.4th 1640, 1666.) Generally, the reliance, causation, and injury components of a common law misrepresentation claim have been implicitly incorporated into the statutes affording remedies for misrepresentations to consumers.