The UCL Practitioner was on a brief hiatus, but she returns none too soon with an interesting post, containing information that slipped by me. The Supreme Court has just issued a "grant and hold" order in O'Brien v. Camisasca Automotive Mfg., no. S163207. In O'Brien, the Court of Appeal held that the plaintiff lacked standing under the UCL and CLRA because he failed to allege reliance. The opinion overlooks the distinction been causation and reliance, resulting in a very strict reading of the "injury in fact" element added to the UCL via Proposition 64. It appears that the Supreme Court will try to issue something comprehensive as to the changes incorporated into the UCL by Proposition 64.