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4206 REVIEW GRANTED If the California Supreme Court's decision in Koebke v Bernardo Heights could be read to extend protection of the Unruh Civil Rights Act to discrimination on the basis of sexual orientation, it would not be applicable to a cause of action that arose before its publication; an amendment to the Unruh Civil Rights Act prohibiting discrimination on the basis of sexual orientation cannot be applied to a cause of action that arose before its effective date.CitationNORTH COAST WOMEN'S CARE v SUPERIOR COURT (Intrauterine Insemination) 137 CA4 781 [See: CivC 51; Curran v Mount Diablo 17 C4 670, T/AT 4/98; King v Hofer 42 CA4 678, T/AT 3/96; Koebke v Bernardo Heights 36 C4 824, T/AT 9/05]
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