The GP was talking about Small Claims specifically -- I don't see anything on the linked page that refutes that. In fact, it seems like this applies very narrowly and only where specified by statute.

It was the best I could find. My understanding is that here in CA, if your landlord does not refund your deposit (or properly itemize legitimate expenses against said deposit) you can sue in small claims court and recover 3x damages, up to the small claims court maximum of $7500.

That said, I've never tried it, so it's possible my understanding is wrong.