This is another case from earlier in the year.
In Orcilla v. Big Sur, Inc., 244 Cal.App.4th 982 (Feb. 11, 2016), the plaintiffs sued their bank (and other defendants) for wrongful foreclosure, asserting UCL and other claims. Id. at 990-93. The bank raised a standing challenge to the UCL claim, arguing that the plaintiffs had not adequately alleged that they "lost money or property as a result of" any wrongdoing by the bank, as required by Prop. 64 (Bus. & Prof. Code § 17204 (emphasis added)). According to the bank, the plaintiffs lost their home because they defaulted on their loan, not because of anything the bank did later. Id. at 1012-13.
The Court of Appeal disagreed with this supervening-cause-style argument:
Liberally construed, count 12 and the allegations it incorporates allege that the Bank Defendants engaged in an unlawful or unfair business practice by enforcing the underlying loan and the loan modification agreement, both of which were unconscionable. (Shadoan v. World Savings & Loan Assn. (1990) 219 Cal.App.3d 97, 101-102 [“that a contractual provision is unconscionable may be relevant to the question of whether a party who drafted—and seeks to enforce—the provision, has committed an unfair business practice”].) We have already concluded that the complaint adequately alleges that both agreements were unconscionable. With respect to causation, we can reasonably infer from the allegations that the Orcillas would not have lost the Property if the Bank Defendants had not enforced the unconscionable agreements by way of foreclosure proceedings.
Id. at 1013. Orcilla thus stands for the proposition that for UCL standing purposes, the defendant's conduct must be a cause of the plaintiff's loss, but it need not be the only cause, or even the primary cause. This is consistent with ordinary principles of causation in other contexts.