California, United States of America
The following excerpt is from King v. U.S. Bank Nat'l Ass'n, 266 Cal.Rptr.3d 520, 53 Cal.App.5th 675 (Cal. App. 2020):
"Regardless of the nature or number of legal theories advanced by the plaintiff, he is not entitled to more than a single recovery for each distinct item of compensable damage supported by the evidence. [Citation.] Double or duplicative recovery for the same items of damage amounts to overcompensation and is therefore prohibited." ( Tavaglione v. Billings (1993) 4 Cal.4th 1150, 1158-1159, 17 Cal.Rptr.2d 608, 847 P.2d 574.) "In contrast, where separate items of compensable damage are shown by distinct and independent evidence, the plaintiff is entitled to recover the entire amount of his damages, whether that amount is expressed by the jury in a single verdict or multiple verdicts referring to different claims or legal theories." ( Id . at p. 1159, 17 Cal.Rptr.2d 608, 847 P.2d 574.)
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