Yeo Lai Sah Monastery v. Nelidov
In its ruling on a summary judgment motion the trial court resolved a boundary dispute in the underlying quiet title action, and a jury thereafter found the Yeo Lai Sah Buddhist Monastery and Zen Temple of America (Temple) and Seol Jo Lee (Master Lee) had slandered their neighbors' title and interfered with the neighbors' right to use an easement for ingress and egress. On appeal, the Temple challenges the sufficiency of the evidence, the applicability of the litigation privilege, and the admissibility of the trial court's ruling on the summary judgment motion. Court conclude that decisional law has expanded the litigation privilege to encompass all litigation-related conduct and renders the Temple's recording of an erroneous survey absolutely privileged. (Civ. Code, S 47, subd. (b).) Because the evidentiary and instructional errors related to the survey were harmless in light of four other disparaging communications, court affirm.
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