The law-of-the-case doctrine provides that, “where an appellate court states a rule of law necessary to its decision, such rule must be adhered to in any subsequent appeal in the same case, even where the former decision appears to be erroneous.” People v. Whitt, 51 Cal.3d 620, 638 (1990). “The primary purpose served by the law-of-the-case rule is one of judicial economy.” Searle v. Allstate Life Ins. Co., 38 Cal. 3d 425, 435 (1985). The doctrine prevents the parties from seeking appellate reconsideration of an already decided issue in the same case absent some significant change in circumstances. See George Arakelian Farms, Inc. v. Agricultural Labor Relations Bd., 49 Cal. 3d 1279, 1291 (1989) (“Like res judicata, the doctrine of the law of the case serves to promote finality of litigation by preventing a party from relitigating questions previously decided by a reviewing court.”)
There are several recognized exceptions to the law-of-the-case doctrine. The courts “have recognized that as a procedural rule the law of the case may operate harshly, and [courts] have fashioned a number of exceptions to the doctrine when (1) there has been an intervening change in the law, or (2) the disputed issue was not presented or considered in the proceedings below, or (3) application of the doctrine would result in a manifest injustice.” Id.; see also DiGenova v. State Board of Education, 57 Cal. 2d 167, 179-80 (1962) (“The doctrine of the law of the case does not extend to points of law which might have been but were not presented and determined on a prior appeal . . . Moreover, the doctrine of the law of the case, which is merely a rule of procedure and does not go to the power of the court, has been recognized as being harsh, and it will not be adhered to where its application will result in an unjust decision.”); Clemente v. California, 40 Cal.3d 202, 212 (1985) (“The principal ground for making an exception to the doctrine of law of the case is an intervening or contemporaneous change in the law.”).