Does the amended bylaws of a California Medical Association of California Board of Directors make a retroactive application to a plaintiff's right to sue?

California, United States of America


The following excerpt is from Anton v. San Antonio Community Hospital, 127 Cal.Rptr. 394, 55 Cal.App.3d 212 (Cal. App. 1976):

In any event the differences between 1968 bylaws and the revised bylaws are all procedural in nature, and, even if the application of the revised bylaws could be said to be retrospective because some of the events occurred prior to their adoption (but see, Coast Bank v. Holmes, 19 Cal.App.3d 581, 593-594, 97 Cal.Rptr. 30 and authorities there cited), the retroactive application of procedural, as opposed to substantive, changes violated no right of plaintiff. (Cf. Angeli v. Lischetti, 58 Cal.2d 474, 478, 24 Cal.Rptr. 845, 374 P.2d 813; Norton v. City of Pomona, 5 Cal.2d 54, 65-66, 53 P.2d 952.

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