Akkerman v. Santa Barbara Cottage Hosp.
Defendant appeals a judgment in favor of plaintiffs on their cause of action for an unfair business practice injunction. The trial court enjoined SBCH from performing electro-convulsive therapy (ECT) treatments because it used inadequate patient consent forms and had an unauthorized ECT review process. Proposition 64 amends the Unfair Competition Law (UCL) by requiring new standing requirements. Court concluded Proposition 64 is applicable here. Court reversed and remanded with instructions that the trial court: 1) determine whether the defendant should be allowed to amend their complaint and 2) decide SBCH's claim that there is no current need for an injunction.
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