Div. Two of the First District Court of Appeal held yesterday that where a buyer was forced to sue the sellers for specific performance as the result of third parties interfering with the sale, attorney fees that were incurred in that action may be recovered in a subsequent lawsuit under a tort-of-another theory, but may not be awarded in connection with that follow-up litigation.

Div. One of the Fourth District Court of Appeal held yesterday that a trial judge erred in declining to set aside a declaration of parentage based on a presumption in California law that a mother’s husband is the father, finding that the Family Code makes clear that even “attempted marriages” trigger the rule even if the confidential union may have been legally invalid due to falsities in an affidavit accompanying the license application.

On Thursday, the state Senate passed a bill fast tracked through the Legislature that changed Cesar Chavez Day, which falls on March 31, to Farmworkers Day, seeking to take a day dedicated to the now deeply sullied figure and convert it into a broader acknowledgement of largely immigrant workers who labor in California fields.

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