People v. Pacific Landmark, LLC, 129 Cal. App. 4th 1203 (2005)

The City of Los Angeles brought a red-light abatement action against the operators of a business and the owners of a strip mall where the business (an illegal massage parlor) was located. The trial court issued a preliminary injunction prohibiting the operation of a massage parlor or house of prostitution. Ron Mavaddat contended that as a manager of Pacific Landmark, a limited liability company, he was exempt from any personal liability. The Court of Appeal disagreed and affirmed the judgment against Mavaddat, holding that “whereas managers of limited liability companies may not be held liable for the wrongful conduct of the companies merely because of the managers’ status, they may nonetheless be held accountable … for their personal participation in tortious or criminal conduct, even when performing their duties as manager.”