Garcetti (1993) 5 Cal.4th 561, 568; see also In re Marriage of Reuling (1994) 23 Cal.App.4th 1428, 1440 ["A statute that creates new obligations by raising a standard of care and imposing, for the first time, a specific penalty for breach of the new standard, constitutes more than a simple clarification of existing law; it manifests and intent to change it. [read post]