Does a litigant have to argue new theories for the first time on appeal?

California, United States of America


The following excerpt is from Sanowicz v. Bacal, 184 Cal.Rptr.3d 517, 234 Cal.App.4th 1027 (Cal. App. 2015):

These claims will be addressed, albeit briefly, because the rule that a litigant may not argue new theories for the first time on appeal does not apply to pure questions of law (Carman v. Alvord, supra, 31 Cal.3d 318, 324, 182 Cal.Rptr. 506, 644 P.2d 192 [new

[234 Cal.App.4th 1043]

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