New opinion confirms UCL and CLRA remedies are cumulative to each other: Flores v. Southcoast Automotive Liquidators, Inc.

In Flores v. Southcoast Automotive Liquidators, Inc., ___ Cal.App.5th ___ (Nov. 27, 2017), the Court of Appeal (Second Appellate District, Division Five) held that "an appropriate correction offer under the Consumers Legal Remedies Act (CLRA; Civ. Code, § 1750 et seq.) does not prevent a consumer from pursuing causes of action for fraud and violation of the UCL based on the same conduct, because the remedies are cumulative."  Slip op. at 2 (footnote omitted).