Angelica Textile Services Inc. v. Park

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that 20 this theory of liability “was independent of any trade secret claim” and therefore not preempted
• holding that a conversion claim against a former employee who took documents with him upon leaving the plaintiffs employ was not displaced by the CUTSA, where the conversion claim could be based on the taking of “tangible property” that was not a trade secret
• asking whether the other state law claims are “based on facts distinct from the facts that support the misappropriation claim”
• declining to apply 21 CUTSA’s savings clause to the plaintiff’s conversion claim because the claim was based on the 22 employee’s “alleged theft of tangible property”
• noting employee's possession of \thousands of pages of [tangible] documents that plaintiff owns\ supports a conversion claim, but also that the claim may ultimately fail if the defendant is \able to show that they have no value\
• “Breach of contract claims, even 27 when they are based on misappropriation or misuse of a trade secret, are not displaced by [C]UTSA.”

Source: CourtListener parenthetical corpus (CC0).