Mazzulla v. Eliminator Custom Boats CA1/2

CourtCalifornia Court of Appeal
DecidedDecember 19, 2025
DocketA172272
StatusUnpublished

This text of Mazzulla v. Eliminator Custom Boats CA1/2 (Mazzulla v. Eliminator Custom Boats CA1/2) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mazzulla v. Eliminator Custom Boats CA1/2, (Cal. Ct. App. 2025).

Opinion

Filed 12/19/25 Mazzulla v. Eliminator Custom Boats CA1/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 TWO

NICK MAZZULLA, Plaintiff and Appellant, A172272 v. ELIMINATOR CUSTOM BOATS, (San Bernardino County INC., ET AL., Super. Ct. No. CIVDS1812883) Defendants and Respondents.

Appellant Nick Mazzulla and respondent Sean O’Connor were long- time friends. Both had extensive experience with boats, and over the years each had been a guest on the other’s boats. In May 2017, O’Connor acquired a speed boat and invited Mazzulla to join him on its first trip, a Memorial Day outing on the Colorado River. In the course of the outing, O’Connor drove at speeds up to 70 miles per hour, and then reduced his speed as he came to a more congested section of the river, when the boat hit a wake, became airborne, crashed back down into the water, the hull “came apart”— and Mazzulla was thrown out of the boat. Mazzulla sued O’Connor and the manufacturer of the hull. The case came on for jury trial in 2024 and, following lengthy deliberations, the jury found both O’Connor and the manufacturer negligent, but further found that

1 neither’s negligence was a substantial factor in causing Mazzulla’s injuries. Mazzulla appeals, making two arguments: (1) the trial court erred in instructing the jury on assumption of risk, and (2) “the jury[’s] confusion and bias created by the” instruction were “substantial in prejudicial scope and effect.” We reject the arguments and we affirm. PROLOGUE This appeal comes to us by order transferring it from the Fourth Appellate District Court of Appeal, Division Two, and arises out of a jury trial in San Bernardino Superior Court. Mazzulla, represented in the appeal by the same attorneys who represented him below, has provided an appellate record that is woefully inadequate, a record that consists of two items: (1) seven volumes of reporter’s transcripts that contains trial proceedings over five days (despite Mazzulla’s attorney’s representation that the case lasted 10 days); and (2) an “appellant’s appendix” that consists in its entirety of seven items that the appendix lists as “exhibits”.1 Such appendix violates the Rules of Court. Rule 8.124 of the California Rules of Court, entitled “Appendixes,”

1 The appendix reads as follows: “Index of Appendix Exhibits “Exhibit A: Subject CACI 470 Primary Assumption of Risk Instruction (Filed and Given at Trial March 20, 2024) “Exhibit B: Appellant’s Objection to Subject CACI 470 Primary Assumption of Risk Instruction [¶] (Filed March 20, 2024) “Exhibit C: Subject Special Verdict Form and Judgment (Filed May 8, 2024) “Exhibit D: Appellant’s Motion for New Trial (Filed May 30, 2024) “Exhibit E: Exhibit 3-1 (Picture of Damaged Boat in Water Following Accident) [¶] (Admitted March 4, 2024) “Exhibit F: Exhibit 49-2 (Picture of Damaged Boat Out of Water) (Admitted March 4, 2024)

2 mandates in subsection (b) the required “[c]ontents of appendix” (boldface and capitalization omitted), and provides in pertinent part as follows: “(1) A joint appendix or an appellant’s appendix must contain: “(A) All items required by rule 8.122(b)(1), showing the dates required by rule 8.122(b)(2); “(B) Any item listed in rule 8.122(b)(3) that is necessary for proper consideration of the issues, including, for an appellant’s appendix, any item that the appellant should reasonably assume the respondent will rely on; [and] “(C) The notice of election . . . .” The referenced Rule 8.122, entitled, “Clerk’s Transcript,” provides what must be in it—and thus in an appellant’s appendix: “(b) Contents of transcript “(1) The transcript must contain: “(A) The notice of appeal; “(B) Any judgment appealed from and any notice of its entry; “(C) Any order appealed from and any notice of its entry; “(D) Any notice of intention to move for a new trial, or motion to vacate the judgment, for judgment notwithstanding the verdict, or for reconsideration of an appealed order, and any order on such motion and any notice of its entry; “(E) Any notices or stipulations to prepare clerk’s or

“Exhibit G: Subject Howell Stipulation [¶] (Given to Jury March 20, 2024)[.]” (Capitalization omitted.)

3 reporter’s transcripts or to proceed by agreed or settled statement; and “(F) The register of actions, if any. “(2) Each document listed in (1)(A), (B), (C), and (D) must show the date necessary to determine the timeliness of the appeal under rule 8.104 or 8.108.” As is apparent from a comparison of the rules to the index, with the exception of two items (the judgment and the motion for new trial), all the many required documents are missing from the appendix. In addition, the absence of the materials bears directly on various assertions in Mazzulla’s brief, most significantly the fundamental contention that assumption of risk was injected late in the game—as his brief puts it, “inappropriate, last minute.” Mazzulla’s appendix does not contain the defendants’ answers that would reflect whether the defense was asserted in those answers—as it was. And the absence of the proposed instructions does not allow us to determine whether the instruction was proposed pre-trial as required (see Code Civ. Proc., § 607a)—as it apparently was. Finally, we note that Mazzulla’s “Statement of the Facts” purports to describe the “negligence” of the defendants, doing so with hardly any record citations,2 a statement that ignores much of what occurred in this lengthy trial. This too is a violation of a Rule of Court, this time California Rules of Court, rule of 8.204(a)(2)(C) that provides that an appellant’s opening brief

2 California Rules of Court, rule 8.204(a)(1)(C) requires that any reference to a matter in the record, whether factual or procedural, be supported by a citation to the volume and page number of the record where the matter appears. (Professional Collection Consultants v. Lauron (2017) 8 Cal.App.5th 958, 970; Myers v. Trendwest Resorts, Inc. (2009) 178 Cal.App.4th 735, 745.)

4 shall “[p]rovide a summary of the significant facts . . . .” And the leading California appellate practice guide instructs about this: “Before addressing the legal issues, your brief should accurately and fairly state the critical facts (including the evidence), free of bias; and likewise as to the applicable law. [Citation.] [¶] Misstatements, misrepresentations and/or material omissions of the relevant facts or law can instantly ‘undo’ an otherwise effective brief, waiving issues and arguments; it will certainly cast doubt on your credibility, may draw sanctions [citation], and may well cause you to lose the case.” (Eisenberg et al., Cal. Practice Guide: Civil Appeals and Writs (The Rutter Group 2024) [¶] 9:27 (Eisenberg), italics omitted.) Such summary is missing here. Furthermore, where, as here, “the appellant fails to provide an adequate record of the challenged proceedings, we must presume that the appealed judgment or order is correct, and on that basis, affirm.” (Jade Fashion & Co., Inc. v. Harkham Industries, Inc. (2014) 229 Cal.App.4th 635, 644.) As our Supreme Court explained: “[I]t is a fundamental principle of appellate procedure that a trial court judgment is ordinarily presumed to be correct and the burden is on an appellant to demonstrate, on the basis of the record presented to the appellate court, that the trial court committed an error that justifies reversal of the judgment. [Citations.] . . .

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