2/4 DCA Finds Persuasive Reasoning From Prior 2/8 Decision On This Issue.
We found Baiul-Farina v. Crown Media Holdings, Inc., Case No. B279653 (2d Dist., Div. 4 Aug. 21, 2019) (unpublished) interesting, not because it affirmed discovery sanctions rulings, but for its discussion on appealability. Appellant argued that discovery sanctions rulings were not appealable under CCP ยง 906 because they were not on the merits. The 2/4 DCA disagreed, finding persuasive the reasoning in In re A.L., 224 Cal.App.4th 354, 362 n. 4 (2014), a Second District, Division 8 decision, which found that an appeal of a final judgment will encompass prior discovery rulings also.
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