Orloff v. Los Angeles Turf Club

In Orloff v. Los Angeles Turf Club (1947) 30 Cal. 2d 110 180 P.2d 321, 171 A.L.R. 913, the plaintiff was refused admission to a racetrack and sued for injunctive relief under civil rights statutes that codified the law previously addressed in Greenberg, supra, 140 Cal. 357. The court found that even though the statute provided only for a monetary penalty of $ 100 and did not mention injunctive relief, injunctive relief was nonetheless available. The court explained that the $ 100 penalty was "a relatively insignificant recovery when we consider that a positive and unequivocal right has been established and violated." (Orloff, at p. 114.) The court found that the inadequacy of the remedy provided by the statute was "manifest" and that there were no valid reasons why injunctive relief should not be provided. (Ibid.)