Planned Parenthood Golden Gate v. Garibaldi
California Court of Appeals
132 Cal. Rptr. 2d 46 (2003)
Planned Parenthood (plaintiff) obtained a 1995 permanent injunction against Operation Rescue of California and Robert Cochran restricting anti-abortion clinic protest activity, with the injunction also purporting to apply to anyone acting in concert with them or anyone with actual notice of it. In 2001, Planned Parenthood sought a declaration that the injunction bound Rossi Foti and Jeannette and Louie Garibaldi (defendants), who were not original parties, and the trial court granted summary judgment enforcing the injunction against them; Foti and the Garibaldis appealed.
Whether an injunction must be directed against specific persons or classes of persons based on their own past actions in a specific dispute between real parties, applying only to those persons or classes, rather than to anyone with mere notice of it.