Justice Armen Tamzarian

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.

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• Covers published opinions only; most appellate decisions are unpublished and do not appear.

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.

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.

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.

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.

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.

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.