Does the term "managing agent" in the terms of section 3294.01 of the California Civil Code apply to managing agents?

California, United States of America

The following excerpt is from In re Transient Occupancy Tax Cases, B230457 (Cal. App. 2012):

The City points out that the ordinance does not incorporate the terms of Civil Code section 3294. Instead, the ordinance refers to managing agents "of any type or character" ( 2.12.005.050), indicating that different types of managing agents may fall within the scope of the provision. Further, the City argues, the term "managing agent" did not receive a settled judicial interpretation until 1999. (See White v. Ultramar, Inc. (1999) 21 Cal.4th 563, 566 (White).)

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