Seacrist v. So. Cal. EdisonAnnotate this Case
Kathy Seacrist and her son, John McDonald sued Southern California Edison (Edison); the City of Palm Desert; J.R. Roberts; and Does 5 through 100. Seacrist owned a home near an Edison substation. Plaintiffs Seacrist and McDonald alleged stray electrical currents from the substation were causing them to suffer various medical issues. The Fourth Amended Complaint included seven causes of action against Edison: (a) negligence; (b) nuisance; (c) trespass; (d) strict liability/products liability; (e) strict liability/implied warranty of fitness; (f) strict liability/ultra hazardous activity; and (g) intentional infliction of emotional distress. The trial court sustained Edison’s demurrer without leave to amend, concluding “Plaintiffs claims are within the exclusive jurisdiction of the California Public Utilities Commission,” and thus, the trial court did not have jurisdiction over the dispute with Edison. The Court of Appeal held previously that the California Public Utilities Commission (PUC) did not have exclusive jurisdiction over a case involving injuries resulting from stray electrical currents from a substation. On appeal, plaintiffs contended the trial court erred by sustaining Edison’s demurrer because the PUC did not have exclusive jurisdiction over claims related to injuries from stray electrical currents. Edison asserts, among other things, that controlling case law was wrongly decided. The Court of Appeal reversed the trial court's judgment.