In 1990, the California Supreme Court rules in the case involving Seattle’s John Moore that a patient does not have rights to profits derived from his cell line. With one justice dissenting, the Court of Appeal reversed, holding that the complaint did state a cause of action for conversion.

The Court of Appeal agreed with the superior court that the allegations against Genetics Institute and Sandoz were insufficient, but directed the superior court to give Moore leave to amend. The Court of Appeal also directed the superior court to decide “the remaining causes of action, which [had] never been expressly ruled upon.”