Angelica Textile Services Inc. v. Park
163 Cal. Rptr. 3d 192
Cal. Ct. App.2013Background
- Angelica sues Emerald and Park for misappropriation of trade secrets and non-UTSA claims; UTSA displacement urged by defendants.
- Trial court granted summary adjudication on non-UTSA claims, holding they were displaced by UTSA.
- Jury found no trade secret misappropriation; judgment for Emerald and Park on that claim.
- Angelica appeals, challenging summary adjudication on six non-UTSA claims; argues UTSA does not displace them.
- Court holds UTSA does not displace contract claims or independent non-UTSA claims; reverses on non-UTSA claims and remands.
- Non-UTSA claims include breach of contract, breach of fiduciary duty, unfair competition, interference with business relations, and conversion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does UTSA displace non-UTSA claims based on misappropriation of trade secrets? | Angelica argues UTSA preempts all misappropriation-based claims. | Emerald/Park contend UTSA displaces those claims altogether. | UTSA does not displace noncontractual claims that are independent of misappropriation. |
| Are non-UTSA claims that are not based on misappropriation displaced by UTSA? | Angelica asserts certain non-UTSA claims remain viable. | UTSA preempts based on misappropriation when the claims rely on same nucleus of facts. | Non-UTSA claims not based on misappropriation are not displaced. |
| Can contract-based claims be displaced by UTSA? | Angelica argues breach of contract may be grounded in misappropriation. | UTSA displacement covers only misappropriation-based aspects. | UTSA does not displace contractual remedies. |
Key Cases Cited
- KC Multimedia, Inc. v. Bank of America Technology & Operations, Inc., 171 Cal.App.4th 939 (Cal. Ct. App. 2009) (UTSA breadth and preemption of trade secrets claims exists; displacement analysis guided by scope of UTSA)
- Silvaco Data Systems v. Intel Corp., 184 Cal.App.4th 210 (Cal. Ct. App. 2010) (UTSA does not displace noncontractual claims based on independent facts)