Law Practice,
Torts/Personal Injury
Jan. 5, 2022
SB 447: Brings California in line with national norm on pre-death pain and suffering damages
After decades as an outlier, California is set to join the vast majority of states in recognizing a right of recovery for pre-death pain and suffering damages.





Douglas S. Saeltzer
Shareholder
Walkup, Melodia, Kelly & Schoenberger
650 California St.
San Francisco , CA 94108
Phone: (415) 617-1277
Email: dsaeltzer@walkuplawoffice.com
UC Hastings COL; San Francisco CA

Spencer J. Pahlke
Shareholder
Walkup, Melodia, Kelly & Schoenberger
Phone: (415) 981-7210
Email: spahlke@walkuplawoffice.com
UC Berkeley SOL Boalt Hall; Berkeley CA

After decades as an outlier, California is set to join the vast majority of states in recognizing a right of recovery for pre-death pain and suffering damages. On October 1, 2021, Gov. Gavin Newsom signed Senate Bill 447, bringing California in line with the 45 states and the District of Columbia that allow recovery of pre-death pain and suffering damages. SB 447 amends California Code of Civil Procedure Section 377.34 -- the survival statute -- which wiped out damage...
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