While it deserves a more substantial discussion, Evans v. Lasco Bathware, Inc. (November 6, 2009) requires at least a brief mention. In Evans, the Court of Appeal (Fourth Appellate District, Division One) reviewed an Order denying class certification. The Court of Appeal affirmed. The interesting elements of the opinion include (1) a discussion of when, in the Evans Court's view, damages become an issue of sufficient complexity to justify a denial of certification and (2) a discussion of "liability only" certification. In this case, the complications arising when a defective shower pan caused varying degrees of damages in different homes convinced the Court to reject the "liability only" certification option in this case. Nevertheless, that aspect of class actions is so infrequently discussed in California that it is of note that it was even considered here.