Earlier this year, in Schermer v. Tatum, 245 Cal.App.4th 912 (Mar. 18, 2016), the Court of Appeal (Fourth Appellate District, Division One) affirmed the trial court's order sustaining the defendants' demurrer to the class allegations without leave to amend. The action alleged UCL and other violations in connection with various aspects of defendants' operation of eighteen separate mobilehome parks.
In a fact-heavy discussion, the Court of Appeal determined that common questions did not predominate. Id. at 922-30.