# Justice Armen Tamzarian *legal · Court of Appeal, Second Appellate District retention · judge* — November 3, 2026 General Election (2026-11-03), Los Angeles County, California Research pack generated 2026-10-30T23:52:30+00:00 by ballotscope. Summaries are LLM-generated from the linked originals and may contain errors; check the originals before relying on anything. Sources span 2025-12-15 to 2026-10-05. ## Overview (as of 2026-10-29, from 8 sources) Tamzarian joined Division Four in June 2025 after about 11 years as a Los Angeles Superior Court judge [Associate Justice Armen Tamzarian (court biography)]. Court listings show 5 published opinions signed by him from October 2024 to October 2026, all majorities and no dissents or concurrences; two are the same Microsoft case, so four distinct cases [Published opinions by Armen Tamzarian, October 2024 to October 2026 (courts.ca.gov listings); Microsoft Corp. v. Superior Court (2026) B347381; Microsoft Corp. v. Super. Ct. (B347381M, 2026-01-30; opinion by Armen Tamzarian)]. In them he upheld Los Angeles's Measure ULA transfer tax against taxpayer challenges (December 2025) [Howard Jarvis Taxpayers Assn. v. City of Los Angeles (2025) B334071], reversed a default judgment against a tenant (December 2025) [Ammari v. Ammari (B336026, 2025-12-24; opinion by Armen Tamzarian)], upheld a warrant-secrecy order against Microsoft (January 2026) [Microsoft Corp. v. Superior Court (2026) B347381; Microsoft Corp. v. Super. Ct. (B347381M, 2026-01-30; opinion by Armen Tamzarian)], and held that an employer is strictly liable for harassment only by the victim's own supervisor (October 2026, his most recent) [Doe v. Wells Fargo Bank, N.A. (2026) B344642]. The sources contain no criticism or endorsement of his record beyond the court's own biography [Associate Justice Armen Tamzarian (court biography)]. ### Record highlights - Published opinions October 2024 to October 2026: 5 authored listings (4 distinct cases), 0 separate opinions; all civil or writ matters, none criminal. Published opinions only. [Published opinions by Armen Tamzarian, October 2024 to October 2026 (courts.ca.gov listings)] - December 2025: upheld Measure ULA, holding voters keep the initiative power to enact a special real-property transfer tax that the city council itself could not impose; rejected equal protection and First Amendment claims. [Howard Jarvis Taxpayers Assn. v. City of Los Angeles (2025) B334071] - December 2025: reversed a $337,495 default judgment because the defendant's original answer already denied the amended complaint's key facts. [Ammari v. Ammari (B336026, 2025-12-24; opinion by Armen Tamzarian)] - January 2026: denied Microsoft's writ petition and upheld a 90-day order barring it from telling USC about a warrant for a student's email in a rape investigation. [Microsoft Corp. v. Superior Court (2026) B347381; Microsoft Corp. v. Super. Ct. (B347381M, 2026-01-30; opinion by Armen Tamzarian)] - October 2026: held FEHA strict liability for harassment applies only when the harasser is the plaintiff's own supervisor; affirmed summary judgment for Wells Fargo. [Doe v. Wells Fargo Bank, N.A. (2026) B344642] - Superior Court judge from December 2013 (family law and civil), about 100 trials; confirmed to the Court of Appeal in June 2025. [Associate Justice Armen Tamzarian (court biography)] ### Gaps - No published dissent or concurrence, so nothing shows where he parts with colleagues. - No criminal appeals among his published opinions. - Unpublished opinions, the majority of appellate work, are not covered. - No campaign statement, interview, questionnaire, or bar evaluation text beyond the biography's rating. - No commentary from any group supporting or opposing retention. ### Arguments for / praise - Rated "exceptionally well qualified" by the Commission on Judicial Nominees Evaluation, as reported in his court biography. — *California Courts of Appeal, Second Appellate District (court biography)* [Associate Justice Armen Tamzarian (court biography)] ## Analysis of their own words (as of 2026-10-29) Coverage: Systematic sample: from the court's published-opinion listings (Oct 2024 to Oct 2026), all separate opinions (none exist) then the most recent authored opinions, up to five texts. That yields five texts, all majority opinions for Division Four, December 2025 to October 2026: an employment harassment summary judgment (S1), the Microsoft warrant-secrecy writ in its modified (S2) and original (S3) versions, which are the same opinion, a default-judgment appeal (S4), and the Measure ULA transfer-tax challenge (S5). So four distinct cases. No dissent, concurrence, criminal appeal, or unscripted speech. Method: begins with statutory text, and when text does not settle the question, turns to purpose, precedent, and the practical consequences of each reading, rejecting results it calls "arbitrary" (S1). Applies presumptions the Supreme Court has set: a strong presumption for the voters' initiative power, requiring a clear statement before finding it limited (S5), and the policy favoring decisions on the merits over defaults (S4). Defers to a trial court's sealed findings and puts the burden of showing error on the challenger (S2). Holds parties to forfeiture rules (S1, S5). Outcomes run both ways: an employee (S1), a technology company (S2), and taxpayers (S5) lost; a defaulted tenant won reversal (S4). Rights claims (First Amendment, equal protection) were resolved under the standard of review the parties or precedent supplied. Four cases cannot establish a broader philosophy. Articulation: **strong**. Each opinion opens by stating the precise question and answer (S1, S2, S5). Reasoning is structured and tested against concrete hypotheticals, such as the "Pat" and "Morgan" coworkers in S1. Out-of-state and agency authority is engaged and distinguished rather than ignored (S1, S2). Prose is plain. Small drafting slips appear ("can reasonably interpreted" and "did not and could analyze" in S1). Prepared written opinions only; no unscripted speech to assess. Consistency: **adequate**. Across four distinct cases the same habits recur: text first, purpose and consequences when text is unclear (S1, S5), firm forfeiture and burden rules (S1, S2, S5), and assuming contested points without deciding them when unnecessary (S1, S2, S4). No case shows a change of view, but the window is ten months and the issues do not overlap, so consistency on any single question cannot be tested. - Employer strict liability for harassment (FEHA): Strict liability applies only when the harasser is the plaintiff's own supervisor acting as such; a supervisor of other employees is a coworker as to the plaintiff. - "An employer can only be strictly liable for sexual harassment by a supervisor if the harasser is the plaintiff’s supervisor acting in the capacity of a supervisor when the harassment occurs." [Doe v. Wells Fargo Bank, N.A. (2026) B344642] (2026-10-05) - Local initiative power over taxes: Constitutional and charter limits on city governments do not bind voters' initiatives absent a clear statement; Measure ULA was a valid exercise of the initiative power. - "This language does not clearly and unambiguously revoke the people’s initiative power on any municipal topic, including special transaction taxes." [Howard Jarvis Taxpayers Assn. v. City of Los Angeles (2025) B334071] (2025-12-15) - "If we were to adopt Howard Jarvis’s interpretation of section 450(a), we would effectively be holding the initiative power was repealed by implication. This we cannot do." [Howard Jarvis Taxpayers Assn. v. City of Los Angeles (2025) B334071] (2025-12-15) - Warrant nondisclosure orders and the First Amendment: A 90-day order barring a provider from telling its institutional customer about a warrant was narrowly tailored; courts need not vet a provider's chosen confidant. - "The stakes are too high—even if the risk is low—given the ongoing criminal investigation into multiple alleged rapes committed by a suspect who is a foreign national from a nonextradition country." [Microsoft Corp. v. Super. Ct. (B347381M, 2026-01-30; opinion by Armen Tamzarian)] (2026-01-30) - Default judgments: A defendant's original answer still controverts an amended complaint's repeated allegations; a default cannot rest on facts already denied. - "Defendants who answered the initial complaint but fail to answer an amended complaint, however, should not be deemed to have admitted allegations they already denied." [Ammari v. Ammari (B336026, 2025-12-24; opinion by Armen Tamzarian)] (2025-12-24) - Tax classifications and equal protection: Rational-basis review governs a graduated real-property transfer tax; wealth is not a suspect class. - "Wealthy individuals do not, however, form a “suspect class.”" [Howard Jarvis Taxpayers Assn. v. City of Los Angeles (2025) B334071] (2025-12-15) Limitations: Published opinions are a minority of a justice's work, and each is a panel product joined by two colleagues, so the prose may not be Tamzarian's alone. S2 and S3 are one opinion, leaving four cases. The sample has no separate opinions, so it cannot show where he parts with colleagues, and no criminal appeal. ## Timeline (newest first) - **2026-10-05** — Doe v. Wells Fargo Bank filed (Judicial Branch of California) - **2026-10-05** — Published: Doe v. Wells Fargo Bank, N.A. (2026) B344642 (California Court of Appeal, Second District, Division Four) - **2026-10-05** — Opinion filed affirming summary judgment for Wells Fargo (California Court of Appeal, Second District, Division Four) - **2026-01-30** — Microsoft Corp. v. Super. Ct. modified (Judicial Branch of California) - **2026-01-30** — Published: Microsoft Corp. v. Super. Ct. (B347381M, 2026-01-30; opinion by Armen Tamzarian) (California Court of Appeal, Second District, Division 4) - **2026-01-30** — Opinion modified to add a costs sentence (California Court of Appeal, Second District, Division 4) - **2026-01-14** — Published: Microsoft Corp. v. Superior Court (2026) B347381 (California Court of Appeal, Second District, Division Four) - **2026-01-14** — Opinion filed denying the petition (California Court of Appeal, Second District, Division Four) - **2026-01-14** — Microsoft Corp. v. Super. Ct. filed (Judicial Branch of California) - **2025-12-24** — Ammari v. Ammari filed (Judicial Branch of California) - **2025-12-24** — Published: Ammari v. Ammari (B336026, 2025-12-24; opinion by Armen Tamzarian) (California Court of Appeal, Second District, Division 4) - **2025-12-24** — Opinion filed reversing (California Court of Appeal, Second District, Division 4) - **2025-12-15** — Howard Jarvis Taxpayers Assn. v. City of L.A. filed (Judicial Branch of California) - **2025-12-15** — Published: Howard Jarvis Taxpayers Assn. v. City of Los Angeles (2025) B334071 (California Court of Appeal, Second District, Division Four) - **2025-12-15** — Opinion filed affirming dismissal of challenges to Measure ULA (California Court of Appeal, Second District, Division Four) - **2025-10-01** — California Supreme Court granted review and transferred the matter for an order to show cause (California Court of Appeal, Second District, Division Four) - **2025-06** — Confirmed as associate justice, Second District, Division Four (California Courts of Appeal, Second Appellate District) - **2025-05-01** — LAPD applied for the warrant and nondisclosure order (California Court of Appeal, Second District, Division Four) - **2023-10-10** — Motion to set aside under Code Civ. Proc. 473(d) denied (California Court of Appeal, Second District, Division 4) - **2023-06-13** — Default judgment entered (California Court of Appeal, Second District, Division 4) - **2022-11-08** — Measure ULA approved by Los Angeles voters (California Court of Appeal, Second District, Division Four) - **2013-12** — Appointed Los Angeles Superior Court judge by Gov. Brown (California Courts of Appeal, Second Appellate District) ## Sources ### Doe v. Wells Fargo Bank, N.A. (2026) B344642 - California Court of Appeal, Second District, Division Four · court opinion · published 2026-10-05 · stance: not_applicable - Tamzarian's published opinion holds that under FEHA an employer is strictly liable for sexual harassment by a supervisor only when the harasser is the plaintiff's own supervisor acting in that capacity; a coworker who supervises other employees triggers only the negligence standard. Summary judgment for Wells Fargo affirmed. - Finds Gov. Code section 12940(j)(1) ambiguous on the question, finds no helpful legislative history, and reasons from the statute's purpose and the consequences of each reading. - Rejects the plaintiff's reading as producing arbitrary results, illustrated with a hypothetical of two equal-rank coworkers ("Pat" and "Morgan"). - Declines to follow two 1980s Fair Employment and Housing Commission decisions and respectfully disagrees with the Illinois Supreme Court's Sangamon decision. - Holds the plaintiff forfeited her negligence and ratification theories by not raising them below or on appeal. - States expressly that the holding does not limit strict liability to the plaintiff's direct or immediate supervisor. ### Microsoft Corp. v. Super. Ct. (B347381M, 2026-01-30; opinion by Armen Tamzarian) - California Court of Appeal, Second District, Division 4 · court opinion · published 2026-01-30 · stance: not_applicable - A one-line modification order adds a costs sentence ("The parties shall bear their own costs on appeal.") to Tamzarian's January 14, 2026 opinion denying Microsoft's writ petition, with no change in the judgment; the unmodified opinion is attached. That opinion upholds a CalECPA nondisclosure order barring Microsoft from telling a USC contact about a search warrant for a student's email in a rape investigation, finding the trial court made the required findings and the order survives strict scrutiny. - Modification is clerical: costs language only. - Attached opinion: trial court independently reviewed the sealed affidavit and did not outsource its findings to police. - Declines to vet a provider-chosen "trusted" contact, following the Third Circuit; USC was not bound by the order and its interests could diverge. ### Microsoft Corp. v. Superior Court (2026) B347381 - California Court of Appeal, Second District, Division Four · court opinion · published 2026-01-14 · stance: not_applicable - Tamzarian's opinion, the first published California decision on the issue, denies Microsoft's writ petition and upholds a CalECPA nondisclosure order that barred Microsoft from telling a contact at USC about a search warrant for a student's email account in a rape investigation. The court finds the trial court made the required statutory findings and the order survives strict scrutiny. - Decides the moot dispute because it is capable of repetition yet evades review (90-day orders). - Holds the trial court independently reviewed the sealed affidavit and did not outsource its findings to police, distinguishing the D.C. Circuit's In re Sealed Case. - Follows the Third Circuit in declining to vet a provider-chosen "trusted" confidante. - Notes USC's interests (risk management, reputation) may diverge from the investigation's, and USC was not bound by the order. ### Ammari v. Ammari (B336026, 2025-12-24; opinion by Armen Tamzarian) - California Court of Appeal, Second District, Division 4 · court opinion · published 2025-12-24 · stance: not_applicable - Tamzarian's opinion reverses a $337,495 default judgment in a Malibu holdover-damages case. A defendant who answered the original complaint is not in default on an amended complaint as to facts his original answer already denied; here he had denied the plaintiff's ownership and the property's rental value, so the default judgment was void. - Applies Carrasco v. Craft and Drotleff v. Renshaw: an original answer stands against an amended complaint except for new facts. - Grounds the rule in the policy favoring decisions on the merits and courts' gatekeeping duty on defaults. - Assumes without deciding that such a judgment is void, because the respondent did not brief the point. - Rejects the claim that the defendant's attorney lacked authority to file the motion. ### Howard Jarvis Taxpayers Assn. v. City of Los Angeles (2025) B334071 - California Court of Appeal, Second District, Division Four · court opinion · published 2025-12-15 · stance: not_applicable - Tamzarian's opinion upholds Los Angeles's Measure ULA, the voter-approved special tax on real property sales over $5 million. The published part holds that neither City Charter section 450(a) nor Constitution article XIII A, section 4 strips voters of the initiative power to enact such a tax; the unpublished part rejects equal protection, First Amendment, ballot-misrepresentation, and preemption challenges. - Applies the rule that courts resolve doubts in favor of the initiative power and require a clear statement before finding it limited. - Notes Howard Jarvis conceded at oral argument that section 4 does not apply to voter initiatives. - Treats the case as an exception to the general rule that local initiative power is co-extensive with the city council's power. - Applies rational basis review to the tax's value tiers, following Ashford Hospitality. - Declines judicial notice of post-election reports that ULA reduced housing production, as irrelevant under rational basis review. ### Published opinions by Armen Tamzarian, October 2024 to October 2026 (courts.ca.gov listings) - Judicial Branch of California · decision record · published undated · stance: not_applicable - The court's published-opinion listings for October 2024 to October 2026 show 5 entries signed by Tamzarian as author and no dissents or concurrences. Two entries are the same case (Microsoft Corp. v. Superior Court, the original opinion and a modification order), so the listing covers four distinct cases: one employment harassment appeal, one criminal-warrant secrecy writ, one landlord-tenant default appeal, and one challenge to a city transfer tax. - Authored: 5 listings (4 distinct cases); separate opinions: 0. - All civil or writ proceedings; no criminal appeal is listed. - Covers published opinions only; most appellate decisions are unpublished and do not appear. ### Associate Justice Armen Tamzarian (court biography) - California Courts of Appeal, Second Appellate District · other · published undated · stance: neutral - The court's official profile: confirmed to Division Four in June 2025 after serving as a Los Angeles Superior Court judge since December 2013 (family law, civil trial, civil independent calendar; about 100 trials). Earlier a Court of Appeal staff attorney and a civil litigation partner. - Confirmed as associate justice by the Commission on Judicial Appointments in June 2025 after nomination by Gov. Newsom. - Rated "exceptionally well qualified" by the Commission on Judicial Nominees Evaluation, per the profile. - Appointed to the Superior Court in December 2013 by Gov. Brown; presided over 100 jury and non-jury trials. - Practice at Case, Knowlson, Jordan & Wright LLP covered business, real estate, employment, professional malpractice, and constitutional law. - Worked as senior appellate court attorney and lead attorney for Justice Patti Kitching in the Second District, Division 3. ### Official Voter Information Guide: Second District Court of Appeal justices - California Secretary of State · official analysis · published undated · stance: neutral - The Secretary of State's official guide lists Armen Tamzarian, Associate Justice, Division Four, among the Second District justices on the retention ballot. The page gives names and divisions only and links each to the court's biography. - Tamzarian is listed under Division Four with Presiding Justice Helen Zukin and Justices Audra M. Mori and Nicholas Daum. - No qualifications, ratings, or arguments appear on this page. - Reference: Court biography of Armen Tamzarian ## Suggested use Ask me neutral questions about this subject using the material above. Distinguish what the sources say from your own background knowledge, cite the source titles you rely on, and say when information may be out of date given the dates shown.