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Yari v. Producers Guild of America

161 Cal. App. 4th 172, 73 Cal. Rptr. 3d 803 (2008)

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Yari v. Producers Guild of America

California Court of Appeal

161 Cal. App. 4th 172, 73 Cal. Rptr. 3d 803 (2008)

Facts

The Academy of Motion Picture Arts and Sciences (the academy) (defendant) holds the annual Academy Awards wherein it presents awards to those in the movie industry. Per the Academy’s rules, the award for Best Picture is presented to three or fewer of the movie’s producers. The Producers Guild of America (the guild) (defendant) designates which producers qualify for the nomination based on their responsibilities and degrees of involvement in the production of the movie. Bob Yari (plaintiff) was one of six producers for the movie Crash. In 2006, Crash was nominated for Best Picture. The guild sent an eligibility form to all six producers and eventually designated only two as award-eligible producers. Yari was not selected, and he unsuccessfully appealed to the guild and the academy. Yari then filed a complaint in California state court for wrongful denial of the right of fair procedure, breach of fiduciary duty, breach of implied contract, and promissory estoppel. The academy and the guild filed a demurrer, which was granted with leave to amend as to the fair-procedure claim. Yari refused to amend his complaint, and judgment was entered against him. Yari appealed, arguing that, as quasi-public and powerful institutions that control the profession of movie producing, the academy’s and the guild’s arbitrary and unfair decision-making processes are subject to judicial review.

Rule of Law

Issue

Holding and Reasoning (Armstrong, J.)

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