If a party dies after trial and submission of the case to a judge sitting without a jury for decision or after a verdict upon any issue of fact, and before judgment, the court may nevertheless render judgment thereon.
§ 669.Death of Party After Trial
Title 8. Of the Trial and Judgment In Civil Actions · Chapter 8. The Manner of Giving and Entering Judgment · Last amended 1980 · Last verified July 28, 2026
In one sentenceSection 669 lets a court render judgment even though a party died after the case was submitted for decision, or after a jury verdict, but before judgment was entered.
Full Text of § 669
Plain-English Summary
Death doesn't always stop a case that's already been decided in substance. If a party dies after the case was submitted to a judge for decision without a jury, or after a jury returns a verdict, but before judgment gets entered, § 669 lets the court go ahead and render judgment anyway.
This keeps a case from being thrown back to square one over timing alone — the substantive decision was already made while the party was alive; entering judgment on it afterward finishes what the case had already resolved.
Frequently Asked Questions
Can a court still enter judgment if a party dies before judgment is entered?
Yes, if the party died after the case was submitted for decision or after a jury verdict.
Does this apply to jury trials as well as bench trials?
Yes, it covers a verdict on any issue of fact as well as a case submitted to a judge without a jury.
Amendment History
Amended by Stats. 1980, Ch. 124, Sec. 2.
Source & verification. Section text is reproduced verbatim from
the Deering's California Codes Annotated / vLex. Enacted by the California Legislature.
Last verified July 28, 2026.
· Official source
Also known as: death of party before judgment california