Deciding what it surprisingly claims to be an issue of the first impression, this decision holds that CCP 472 permits the plaintiff to amend only the original complaint once without leave of court if done before answer or hearing on demurrer.  Any amendment to a later amended complaint may only be filed with leave of court.  The decision also has a good summary of the plaintiff’s burden in preserving for appeal the issue of whether the trial court erred in denying leave to amend.

California Court of Appeal, Second District, Division 4 (Manella, J.); April 19, 2018; 2018 WL 1870543