The Fourth Appellate District affirmed a judgment. The court held that a causes of action for the conversion of evidence and for breach of privacy related to the evidence were properly as mislabeled causes of action for spoliation of evidence, a category of claims not recognized under California law.
Robin Rosen was injured in an auto accident involving a Los Angeles County Metropolitan Transportation Authority (MTA) bus. A month later, she suffered a debilitating stroke. Rosen’s physician performed an angiogram. That angiogram allegedly revealed that the impact of the collision with the MTA bus tore Rosen’s left internal carotid artery, causing her subsequent stroke.
