Wins

GMSR’s client, a commercial landlord, sued an individual tenant for breach of a lease and obtained a multimillion dollar judgment.  The tenant discharged most of the judgment in bankruptcy.  But years later, he disclosed the existence of a secret partnership among him and his family members, and that the family had always considered the lease a partnership asset.

The landlord invoked California Code of Civil Procedure section 187 and successfully moved the trial court to amend the judgment and add the previously-undisclosed partners as judgment-debtors.  They appealed.

The Court of Appeal affirmed in a published opinion.  The Court agreed with GMSR’s position that section 187 can be used in circumstances that are equitably analogous or equivalent to traditional “alter ego” amendments.  The Court held that on the evidence before it, the trial court had discretion to add the remaining partners as judgment debtors.

The opinion builds on and cites two earlier cases where GMSR successfully persuaded appellate courts that section 187 can be used to add additional judgment debtors for equitable reasons.  (JPV I L.P. v. Koetting (2023) 88 Cal.App.5th 172; Greenspan v. LADT, LLC (2010) 191 Cal.App.4th 486.)

Click here to read the Court of Appeal’s opinion:  8451 Melrose Property, LLC v. Akhtarzad (2026) ___ Cal.App.5th ___ [Second District, Division Eight].