He joined the concurrence and dissent of Justice Edward A. Panelli in Knight v. Jewett (1992), holding assumption of risk could still bar a claim for negligence. In 2008, he was part of the dissenting minority in In re Marriage Cases, a 4–3 decision legalizing same-sex marriage in California.
He participated in Justice Edward A. Panelli's concurrence and dissent in Knight v. Jewett (1992), arguing that assumption of risk could still bar a negligence claim. In 2008, he was part of the minority opposing the majority decision in In re Marriage Cases, which legalized same-sex marriage in California.