Yet another unpublished Prop. 64 retroactivity opinion: Young America Corp. v. Superior Court

In Young America Corp. v. Superior Court, no. C049337 (Third Appellate District) (Jan. 30, 2006), the Court had this to say about Prop. 64's "injury in fact" language:

We do not consider and need not decide the precise meaning of “injury in fact” for purposes of amended sections 17203 and 17204. It is clear after the enactment of Proposition 64 the sections require some wrong or harm to an interest or right over and above the interests and rights held in common with the public at large in order for an individual to have standing to sue. Otherwise, the amendments to sections 17203 and 17204 enacted by Proposition 64 will have changed nothing ....

(Slip op. at 11-12.)