I was at a seminar this weekend about the all of the new cases that were decided in 2015. The moderator of the seminar made a joke about the theme of 2015 for the Court of Appeal in California. That theme was “play nice.” Now to be clear, the moderator was joking, but there were several cases that came down in 2015 where the Court of Appeal appeared to have based their decisions on how the parties (and their attorneys) conducted themselves during the litigation. Without going into detail, suffice it to say bad behavior was not rewarded in 2015.