On December 4, 2012, the Court of Appeal (First Appellate District, Division Two) handed down an interesting, but unpublished, UCL opinion. People ex rel. Herrera v. Stender, 2012 WL 6016722, No. A131625 (Dec. 4, 2012).
The San Francisco City Attorney sought to invoke the UCL in an attempt to shut down an immigration law practice allegedly headed up by an attorney who had resigned from the Bar with disciplinary charges pending. The opinion holds that the Rules of Professional Conduct can form the predicate of a UCL "unlawful" prong claim. Slip op. at 17-18. It also addresses the economic abstention doctrine (id. at 29-30) and the scope of injunctive relief available under the UCL.