Section 998: Smalley Opinion Is Now Published

Shows How A Nicely Crafted 998 Offer Can Benefit A Defendant In A Lemon Law Case.

            In a December 13, 2022 post, we reviewed Smalley v. Subaru of America, Inc., a 4/3 DCA unpublished case at the time which showed how a defendant in a lemon law case crafted a nice CCP § 998 offer which limited exposure to potential fees and costs because plaintiff did not beat the 998 offer.  We can now report that the case was certified for partial publication on January 11, 2023 (although not posted until January 12).