Cooke v. Parton CA1/4

California Court of Appeal·Decided August 27, 2026·No. A174204·Unpublished

Opinion

Filed 8/27/26 Cooke v. Parton CA1/4 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

PHILIP COOKE, Plaintiff and Appellant, A174204

v. ERIC PARTON, (San Francisco County Super. Ct. No. CGC-21-594052)

Defendants and Respondents.

Usury is addressed in article XV, section 1 of the California Constitution, which sets permissible interest rates with many exceptions. As relevant here, that provision states that the interest rate for a loan of money primarily for personal, family, or household purposes may not exceed 10 percent per annum. (Ibid.) The interest rate for a loan of money not primarily for personal, family or household purposes may not exceed the higher of (1) 10 percent per annum or (2) 5 percent per annum plus the prevailing rate for member banks of the Federal Reserve Bank. (Ibid.)

In the present action, Philip Cooke sought, among other things, to recover allegedly usurious interest collected by Eric Parton on a $195,000 loan secured by a promissory note. At trial, it was undisputed that the interest rate on the loan was 18 percent per annum. The trial court entered

judgment1 in favor of Parton.2 The court found that Cooke had not proven that the 18 percent interest rate paid on the loan exceeded the constitutional maximum because Cooke did not present evidence of the applicable interest rate of the Federal Reserve Bank.

On appeal, Cooke contends that he presented evidence of the Federal Reserve rate of interest by “alleg[ing]” it in his first amended complaint and trial brief, and that this “contention” was never challenged. He further argues that he raised this point in an objection to the June 2025 Decision and that the trial court abused its discretion by failing to rule on his objection before judgment was entered. Alternatively, he argues that this court should take judicial notice of the applicable Federal Reserve Bank rate of interest, which he asserts was 2.5 percent. We find that Cooke’s arguments do not establish error, and therefore we must affirm the judgment.

BACKGROUND

Cooke executed a promissory note in exchange for a loan in the principal sum of $150,000 from Parton’s father. The interest rate on the loan was 10 percent per annum. About three weeks later, Cooke requested additional funds and executed an updated note in the principal sum of

1 Cooke’s notice sought to appeal from a statement of decision

(Decision) entered in June 2025. Following entry of judgment in October 2025, Cooke filed a second appeal. On Cooke’s motion, we construed the present appeal to be taken from the October 2025 judgment and dismissed the second appeal as duplicative.

2 Judgment was also entered in favor of defendant Robert Tayac, who is

an attorney who was hired by Parton to enforce the promissory note. Cooke’s complaint alleged that the $60,000 in attorney fees collected by Tayac was additional usurious interest collected on the loan. The trial court rejected this claim and Cooke has not challenged that ruling on appeal.

$195,000 with interest charged at the rate of 18 percent per annum.3 Both notes were secured by his personal residence. Cooke did not pay the note when due, but later satisfied the loan through escrow following the sale of his home. This action was commenced shortly thereafter.

Cooke’s first amended complaint alleged causes of action for breach of contract, rescission, fraud, conversion, and usury. With respect to the issue on appeal, Cooke argued at the bench trial that “18% per annum is a usurious interest rate. This is beyond dispute. Cooke is entitled to return of all interest paid . . . .” He acknowledged the two constitutional limitations set forth above and concluded: “Given the rate of interest set by the Federal Reserve Bank at the time of the subject loan, regardless of whether the loan to Cooke is characterized as primarily business or personal, the maximum amount of interest which could have been charged . . . and/or collected . . . was 10%—not 18%.” In his closing trial brief, Parton argued that Cooke’s claim that the 18 percent per year interest rate was usurious must be denied because Cooke failed to present evidence that the rate charged exceeded the constitutional limit applicable to loans for nonpersonal use. Specifically, he noted the absence of any evidence regarding the applicable interest rate for the Federal Reserve Bank: “There can be no dispute that Plaintiff Cooke offered no such testimony at trial through any of the witnesses who testified at trial or through the exhibits entered into evidence. Not a single witness even uttered the phrase ‘federal reserve,’ let alone provided testimony on this subject.”

On May 22, 2025, the trial court issued a tentative statement of decision finding in Cooke’s favor on the usury claim and rejecting Cooke’s

3 Following the father’s passing, the updated promissory note was

assigned to Parton.

remaining claims. Parton objected to the tentative decision, arguing that Cooke had not satisfied his burden of proof as to the usury claim. Parton argued that the proceeds of the loan were for commercial, rather than personal, use so that the constitutional limit on interest rates for personal loans was not applicable and that Cooke failed establish that the rate was usurious under the provision applicable to nonpersonal loans because he did not admit evidence of the Federal Reserve Bank’s interest rate. Cooke did not file a response to Parton’s objection.

On June 13, 2025, the court issued its Decision finding in favor of Parton on the usury claim. The Decision reads in relevant part, “The Court finds that plaintiff failed to present evidence that the interest paid exceeded the higher of either 10% or 5% plus the prevailing rate for member banks of the Federal Reserve Bank.”

On June 20, 2025, Cooke filed an objection to the Decision. His objection states:

“1. The loan between Cooke and Ralph Parton was primarily for personal, family or household purposes. Any such loan cannot exceed 10% and the Federal Reserve interest rate is irrelevant since it applies only to business loans.

“2. Cooke had no obligation to produce evidence to confirm a matter of public record since it is a matter as to which the Court can and should take judicial notice.

“3. Mr. Parton did not and does not dispute that 18% interest is usurious, under any circumstance, and he conceded at trial that the interest charged and collected was usurious.”

The court did not rule on Cooke’s objections. Judgment was entered on October 6, 2025.4 After judgment was entered, Cooke moved for new trial based on irregularity, abuse of discretion, surprise, and error of law.5 Cooke reiterated the arguments asserted in his objection to the Decision. Along with this motion, Cooke filed a formal request for judicial notice of the applicable Federal Reserve interest rate.

The trial court denied Cooke’s motion. The court explained: “Plaintiff did not identify any irregularities or abuse of discretion as set forth in [Code of Civil Procedure] [section] 657. Rather, Plaintiff asks that the Court take judicial notice of evidence not presented at trial, specifically the percentage rate of the Federal Reserve Interest Rate at the time of the subject loans. This Court denies to do so. Plaintiff is effectively seeking to reverse the final Statement of Decision based on evidence not submitted during trial.”

DISCUSSION

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