Toyota Motor Corp. v. Superior Court
130 Cal. Rptr. 3d 131
Cal. Ct. App.2011Background
- Toyota moved to prevent deposition of five Japanese-resident executives in California; witnesses would be deposed as individuals, not corporate reps.
- Plaintiffs sought California depositions despite section 1989’s residency constraint, arguing section 2025.260 allowed travel beyond 75/150 miles.
- Trial court granted deposition in California with conditions (travel-paid, one-day deposition in Gardena).
- Toyota petitioned for writ of mandate arguing 1989 precludes nonresidents from California depositions; argued 2025.260 balanced factors cannot override 1989.
- California Court of Appeal conducted de novo statutory interpretation, emphasizing residency-based limitation and lack of conflict between 1989 and 2025.260.
- Court remanded, vacating the deposition order and directing denial of the motion to compel deposition in California.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 1989 prohibit nonresident witnesses from California depositions? | Stewart argues 1989 permits depositions beyond, if allowed by 2025.260. | Toyota argues 1989 restricts, but 2025.260 may authorize under balancing. | Yes; 1989 forbids nonresidents from California depositions. |
| Can 2025.260 override 1989 through the balancing test? | Stewart relies on 2025.260 to justify travel. | Toyota asserts 1989 remains controlling; balancing cannot override. | No; 1989 controls despite 2025.260 balancing. |
| Is Glass controlling after 1986 reforms and 2004 renumbering? | Glass should govern nonresident depositions in California. | Glass misreads Twin Lock and is superseded by statutory history. | Glass not controlling; legislative history supports not overruling 1989. |
Key Cases Cited
- Twin Lock, Inc. v. Superior Court, 52 Cal.2d 754 (1958) (deposition outside 1989 permitted with balancing provision)
- Glass v. Superior Court, 204 Cal.App.3d 1048 (1988) (limited force; subsequent reforms undermined its reasoning)
- Amoco Chemical Co. v. Certain Underwriters at Lloyd's of London, 34 Cal.App.4th 554 (1995) (deposition location considerations under discovery rules)
- Suman v. BMW of North America, Inc., 23 Cal.App.4th 1 (1994) (statutory interpretation; de novo review on CPP provisions)