Justice Helen Zukin

Blogger Daniel Faigin recommends Retain (Yes) for Zukin, relaying a 'Google AI' summary: no misconduct; an August 2026 opinion she wrote sanctioning a lawyer $1,000 for unsupported bias accusations; her past chairing of the State Bar's JNE Commission; and a September 2026 recusal request in Doe v. David.

• Conclusion: Retain (Yes).
• Cites her August 2026 sanctions opinion against a lawyer who "accused a lower trial judge of bias without evidence."
• Says a recusal request in Jane Doe v. Alkiviades David (Sept. 2026) does not imply wrongdoing.

LAist explainer on Court of Appeal retention races; its Second District roster lists Helen Zukin with a 2025 State Bar evaluation rating of "Exceptionally well qualified" and appointment by Gov. Newsom. No individual discussion.

• LAist lists the State Bar (JNE) evaluation rating (2025) as "Exceptionally well qualified".
• Retention questions are yes/no; per a state analysis LAist cites, no California appellate justice has lost a retention election since the system began in the 1930s.
• Appellate justices sit on three-member panels reviewing lower-court decisions; they do not retry facts.

Official certified list of judicial contests for Nov. 3, 2026; confirms Presiding Justice Helen Zukin (Division Four) is on the Second District retention ballot.

• Ballot question: "Shall Presiding Justice HELEN ZUKIN be elected to the office for the term provided by law?"

Conservative group Reform California's LA County slate recommends DO NOT RETAIN for Helen Zukin, as it does for nearly every Second District justice (retain only Chavez, Rothschild, Yegan). No reasons are given for any justice.

• Recommendation: Helen Zukin — DO NOT RETAIN.
• Same recommendation for all but three of the listed Second District justices.

Secretary of State voter-guide index of Second District justices on the ballot; lists Helen Zukin under Division Four and links to court biographies. Contains no evaluation.

• Lists Helen Zukin among the Division Four justices on the ballot.

DSA-LA's guide places Zukin among justices with "mostly inoffensive pre-appointment careers" whom voters "should probably vote yes on," noting she represented plaintiffs suing corporations for defective products.

• DSA-LA: Zukin "specialized in plaintiff side civil legislation, suing corporations for shoddy products."

Census of Zukin's published opinions, Oct. 2024 to Oct. 2026, from courts.ca.gov listings: 7 authored, 0 dissents or concurrences. All seven are civil; three entries are one case, Towns v. Hyundai (original, modification, publication order).

• 7 authored published opinions; 0 separate opinions.
• Distinct cases: A Company Hungary v. Bespalov (attorney sanctions, 2026), Bagby v. Davis (judgment collection, 2026), Towns v. Hyundai (lemon law, 2025-26), Lampkin v. County of Los Angeles (2025), Estate of Tarlow (probate, 2025).
• Covers published opinions only; most appellate decisions are unpublished.

Published opinion by Zukin (Mori, Tamzarian concurring) holding attorney Jeremiah Reynolds in direct contempt and fining him $1,000 for 26 unsupported accusations of trial-judge bias in appellate briefs; published "as a warning."

• Opening: "An adverse ruling is not evidence of judicial bias. And lawyers may not accuse a judge of bias without evidence."
• Found counsel's apology "immediately qualified and tacitly retracted" by defending his conduct.
• Ordered the opinion forwarded to the State Bar; merits resolved in a separate unpublished opinion.

Published opinion by Zukin (Collins, Tamzarian concurring) affirming an order letting a judgment creditor levy on a Florida-resident debtor's IRAs: California exemption law governs collection in California courts, and a voluntarily surrendered life insurance policy is treated as matured, so its proceeds are exempt only if needed for support.

• Holds claims of exemption are decided under the law of the forum state, following Division Four's 1977 DeLotel decision; the debtor's domicile is irrelevant.
• Funds in an account are intangible and located wherever the court has jurisdiction over the custodian; the debtor never contested jurisdiction over LPL.
• New rule: a voluntarily surrendered life insurance policy is treated as matured, because treating it as unmatured would make the creditor's statutory right to loan value uncollectible.
• The debtor failed to prove the source plan was designed and used for retirement: he borrowed about a third of its single asset and let another third go to unpaid interest, without explanation.
• Several arguments (funds located in South Carolina, writ expiration, tax holdback) held forfeited for not being raised below.

Order by the Zukin panel (Zukin, Collins, Tamzarian) modifying the December 22, 2025 Towns v. Hyundai opinion and denying Hyundai's rehearing petition, with the unmodified opinion attached. The only change corrects three dates in footnote 5 from 2023 to 2018; the judgment is unchanged.

• Corrects footnote 5 dates (May 30 and April 11) from 2023 to 2018, the year of the events.
• Hyundai's petition for rehearing denied; no change in judgment.
• The attached opinion (by Zukin) holds a non-buyer spouse lacks standing under the Song-Beverly Act and that an insurance payout cannot offset statutory restitution.

The same January 16, 2026 modification order in Towns v. Hyundai, plus a separate order that day publishing the whole opinion, including the formerly unpublished holding that Song-Beverly obligations arise from the statute, not contract, so prejudgment interest is available under Civil Code section 3288.

• Publication ordered on requests from Cynthia E. Tobisman of Greines, Martin, Stein & Richland (plaintiffs' appellate counsel) and Jordan G. Cohen.
• Newly published part: the claim was 'governed by statute, not contract, from beginning to end,' so section 3288 interest applies.
• Rejects Hyundai's argument that a breach-of-warranty label makes the claim contractual, saying it 'elevates the label over the substance.'
• Several Hyundai arguments raised first on reply held forfeited.

Partially published opinion by Zukin (Collins, Tamzarian concurring) in a Song-Beverly lemon-law case: a non-buyer spouse lacks standing, and an insurance payout after the car was totaled may not offset the manufacturer's restitution.

• Held the trial court "stretched Patel too far"; the Act lets only a "buyer" sue, and the record did not support a "de facto buyer."
• Applied Niedermeier: the statutory restitution formula has no exception for insurance payments; damages corrected to $24,085.83.
• Unpublished part: prejudgment interest available under Civ. Code § 3288 because the obligations arise from the Act, not contract.

Zukin's unanimous opinion reverses a $400,000 attorney's-fee award and costs to a sheriff's deputy who proved whistleblower retaliation but lost to the County's "same-decision" defense. It holds a plaintiff who obtains no relief has not brought a "successful action" under Labor Code section 1102.5(j), and declines to extend the Supreme Court's FEHA decision in Harris v. City of Santa Monica.

• The jury found Deputy D'Andre Lampkin's protected activity was a factor in LASD's actions but that LASD would have acted the same anyway, so no damages.
• Harris is distinguished: different procedural posture, FEHA's discretionary prevailing-party fee clause, and section 1102.6's "complete set of instructions."
• Follows Ververka (2024), the only case on the effect of a section 1102.6 defense.
• The County, not Lampkin, is the prevailing party for costs under Code Civ. Proc. section 1032.
• Says extending Harris "would be a rational policy choice" but leaves it to the Legislature.

Zukin's opinion (as Acting Presiding Justice, unanimous) holds that a trustee named in a will has standing under Probate Code section 11700 to petition for a determination of who is entitled to the estate, reversing a demurrer ruling against trustee David Simon. Filed unpublished Feb. 20, 2025, and certified for publication on the court's own motion Feb. 27.

• A trustee named in a will is a "devisee" and so a "person claiming to be . . . entitled to distribution" under section 11700.
• Standing is defined by the statute invoked; section 48's "interested person" definition does not apply because that term is not in section 11700.
• A presumption that a beneficiary's disclaimer is valid cannot be applied on demurrer; the disclaimer's validity goes to the merits, not standing.
• The court expressly expresses no view on the disclaimer or on the beneficiary's $100,000 purchase of a charity's remainder interest, and remands.

Judicial Council release: the Commission on Judicial Appointments unanimously confirmed Zukin as Presiding Justice of Division Four on June 24, 2025.

• Unanimous vote of Chief Justice Guerrero, AG Bonta and Presiding Justice Gilbert.

Governor's release nominating Associate Justice Zukin as Presiding Justice of Division Four, succeeding Brian Currey, with career dates and party (Democrat).

• Associate Justice in Division Four since 2023; LA Superior Court judge 2018-2023; Kiesel Law partner 2006-2018; solo practice 1995-2006.

Court biography: on the Court of Appeal since July 2023, Presiding Justice of Division Four since 2025; LA Superior Court judge 2018-2023; earlier a plaintiffs' complex-litigation lawyer (toxic torts, pharmaceutical and device, product liability).

• Helped establish LA Superior Court's Judicial Mentor Program; co-chairs the Appellate Judicial Mentor Program.
• Former chair of the State Bar's Commission on Judicial Nominees Evaluation (JNE) and of several judicial-selection panels; former president of the Los Angeles Ethics Commission.
• Partner at Kiesel Law (2010); former board member of Consumer Attorneys Association of Los Angeles.