Dawson v. Washington Mutual Bank, F.A., 367 F.3d 1174 (9th Cir. 2004)
The Ninth Circuit Court of Appeals held that emotional distress damages were not recoverable from Washington Mutual Bank, represented by Malcolm Cisneros, for the bank’s violation of the automatic stay. The opinion was later withdrawn. Upon reconsideration, the Ninth Circuit held that emotional distress damages are recoverable for violations of the automatic stay in Dawson v. Washington Mutual Bank, F.A., 390 F.3d 1139 (2004).