DISCUSSION I. Standard of Review a trial decision on a disqualification motion is reviewed “Generally, court’s for abuse of discretion. [Citations.] If the trial court resolved disputed factual issues, the reviewing court should not substitute its judgment for the trial express or implied court’s findings supported by substantial evidence. [Citations.] When substantial evidence supports the trial factual findings, the appellate court reviews the conclusions court’s based on those findings for abuse of discretion. [Citation.] However, the trial court’s discretion is limited by the applicable legal principles. [Citation.] Thus, where there are no material disputed factual issues, the appellate court reviews the trial court’s determination as a question of law. [Citation.] In any event, a disqualification motion involves concerns that justify careful review of the trial exercise of court’s discretion.” (People ex rel. Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 11431144 (SpeeDee Oil).) II. The Trial Court Erred by Granting the Motion to Disqualify The court granted the motion to disqualify on two grounds: (1) “the confidential nonclient between Spainhour and SLG, on the one hand, and relationship” Lynn and ALR, on the other, and (2) potential attorneyclient relationship with the “the alleged Each ground is discussed in turn below. Neither ground supports partnership.” disqualification of counsel. The parties also raise the issue of standing. To bring a motion to disqualify counsel, the moving party must have standing; that is, the invasion of a legally cognizable interest. (Great (2010) 186 Cal.App.4th 1347, 1357.) Lakes Construction, Inc. v. Burman Standing may arise from an attorney-client relationship between the moving party and targeted counsel or from a duty of confidentiality owed by the attorney to the moving party despite the absence of an attorneyclient relationship. (Id. at pp. 13561357; see
DISCUSSION I. Standard of Review “Generally, a trial court’s decision on a disqualification motion is reviewed for abuse of discretion. [Citations.] If the trial court resolved disputed factual issues, the reviewing court should not substitute its judgment for the trial court’s express or implied findings supported by substantial evidence. [Citations.] When substantial evidence supports the trial court’s factual findings, the appellate court reviews the conclusions based on those findings for abuse of discretion. [Citation.] However, the trial court’s discretion is limited by the applicable legal principles. [Citation.] Thus, where there are no material disputed factual issues, the appellate court reviews the trial court’s determination as a question of law. [Citation.] In any event, a disqualification motion involves concerns that justify careful review of the trial court’s exercise of discretion.” (People ex rel. Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 11431144 (SpeeDee Oil).) II. The Trial Court Erred by Granting the Motion to Disqualify The court granted the motion to disqualify on two grounds: (1) “the confidential nonclient relationship” between Spainhour and SLG, on the one hand, and Lynn and ALR, on the other, and (2) “the potential attorneyclient relationship with the alleged partnership.” Each ground is discussed in turn below. Neither ground supports disqualification of counsel. The parties also raise the issue of standing. To bring a motion to disqualify counsel, the moving party must have standing; that is, the invasion of a legally cognizable interest. (Great Lakes Construction, Inc. v. Burman (2010) 186 Cal.App.4th 1347, 1357.) Standing may arise from an attorney-client relationship between the moving party and targeted counsel or from a duty of confidentiality owed by the attorney to the moving party despite the absence of an attorneyclient relationship. (Id. at pp. 13561357; see