Justia California Supreme Court Opinion Summaries

In 2018, the California Legislature amended the law of homicide, eliminating several theories of liability based on imputed malice and offering relief to those convicted under certain now-invalid theories, such as the natural and probable consequences doctrine. Petitioners seeking relief must file a facially valid petition and make a prima facie showing before a court issues an order to show cause and holds an evidentiary hearing.Ramon Patton, who pleaded guilty to attempted murder and intentionally discharging a firearm, filed a petition for resentencing under the amended law. The People referenced the preliminary hearing transcript, which indicated Patton was the sole shooter, to argue against his prima facie showing. Patton offered no factual counterweight, relying solely on checkbox allegations.The Los Angeles County Superior Court found Patton failed to establish a prima facie case and denied the petition. The Court of Appeal affirmed, noting the preliminary hearing transcript showed Patton was the sole shooter, and his conviction did not implicate an invalid theory.The Supreme Court of California held that a petitioner who offers only conclusory allegations in response to a record of conviction demonstrating the conviction was under a still-valid theory has not made a prima facie showing. The court affirmed the judgment but remanded to allow Patton an opportunity to amend his petition. The court clarified that at the prima facie stage, courts may reference the record of conviction to refute conclusory allegations without engaging in impermissible factfinding. View "P. v. Patton" on Justia Law

Brian Ranger, a maintenance worker for Alamitos Bay Yacht Club, was injured while performing his duties, which included hoisting and mooring vessels. On August 28, 2018, he slipped and fell while boarding a vessel, resulting in serious injuries. Ranger applied for state workers' compensation and subsequently sued the Club under general maritime law, alleging negligence and unseaworthiness.The Los Angeles County Superior Court sustained the Club's demurrer without leave to amend, concluding that Ranger failed to allege facts implicating federal admiralty jurisdiction. Although the court acknowledged the tort occurred on navigable waters, it found that Ranger did not demonstrate his fall posed more than a fanciful risk to maritime commerce. The Court of Appeal affirmed the decision but on different grounds, holding that the Longshore and Harbor Workers’ Compensation Act (LHWCA) displaced general maritime law, making California’s workers’ compensation scheme Ranger’s exclusive remedy.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that the 1984 amendments to the LHWCA, which exclude certain workers from federal workers' compensation if they are covered by state laws, did not abrogate general maritime remedies for those outside the LHWCA’s scope. The court also determined that California’s workers’ compensation exclusive-remedy provision could not deprive Ranger of his substantive federal maritime rights under the supremacy clause of the federal Constitution. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings to address unresolved issues, including whether Ranger’s claims properly invoked admiralty jurisdiction. View "Ranger v. Alamitos Bay Yacht Club" on Justia Law

Michael Ayala, a correctional officer for California’s Department of Corrections and Rehabilitation (CDCR), was injured in a planned attack by inmates. He filed a workers’ compensation claim, asserting that his injuries were due to CDCR’s serious and willful misconduct in failing to address a credible threat of inmate violence. A workers’ compensation administrative law judge (WCJ) initially rejected this claim, but the Workers’ Compensation Appeals Board (Board) found in favor of Ayala, concluding that he was entitled to a 50 percent increase in compensation under Labor Code section 4553 due to CDCR’s serious and willful misconduct.The CDCR did not dispute the finding of serious and willful misconduct but argued that the 50 percent increase should be calculated based on the temporary disability (TD) benefits Ayala would have received under the workers’ compensation law, not the more generous industrial disability leave (IDL) and enhanced industrial disability leave (EIDL) benefits he received under the Government Code. The WCJ agreed with CDCR, but the Board reversed, including IDL and EIDL benefits in the calculation of the increased compensation.The California Supreme Court reviewed the case and agreed with the Court of Appeal, which had reversed the Board’s decision. The Supreme Court held that the term “compensation” under Labor Code section 4553, as defined in section 3207, is limited to benefits provided under the workers’ compensation law. Therefore, the 50 percent increase in compensation for serious and willful misconduct should be calculated based on the TD benefits Ayala was entitled to under the workers’ compensation law, not the IDL and EIDL benefits provided under the Government Code. The judgment of the Court of Appeal was affirmed. View "Dept. of Corrections & Rehabilitation v. Workers' Comp. Appeals Bd." on Justia Law

The defendant was convicted and sentenced to death for the murder of Alfonso Martinez during a robbery and kidnapping, and for the attempted murder of Deborah Pizano. The jury also found him guilty of several other crimes, including second-degree robbery and multiple counts of attempted murder related to a separate drive-by shooting. The jury found true the allegations that a principal discharged a firearm causing death or great bodily injury but did not find that the crimes were committed for the benefit of a criminal street gang.The trial court denied the defendant's motion to suppress his custodial statements, finding that he was properly advised of his Miranda rights and that his waiver was voluntary. The court also denied the defendant's motion to sever the charges related to the two incidents, finding that the evidence was cross-admissible and that the charges were of the same class. The jury was instructed on multiple theories of liability, including direct aiding and abetting, natural and probable consequences, and felony murder.The California Supreme Court reviewed the case and reversed the six counts of attempted premeditated murder and the one count of being an active participant in a criminal street gang. The court also vacated the gang-murder special-circumstance true finding. The court affirmed the judgment in all other respects, including the first-degree murder conviction and the death sentence. The court found that the instructional errors related to the natural and probable consequences doctrine and felony murder were harmless beyond a reasonable doubt for the murder conviction but not for the attempted murder convictions. The court also held that the evidence was insufficient to support the gang allegations under the amended statute. View "P. v. Hin" on Justia Law

A landowner sought to confirm that a conveyance occurring before March 4, 1972, created separate parcels under the Subdivision Map Act. The property in question was described in a 1944 deed as Lot 18, Lot 17, and a portion of Lot 16 on an antiquated subdivision map. The landowner argued that this conveyance created three separate parcels, including Lot 18, and sought a certificate of compliance to confirm Lot 18 as a separate legal parcel.The Alameda County Superior Court denied the landowner's petition for a writ of mandate to compel the City of Oakland to issue the certificate. The landowner appealed, and the First Appellate District, Division One, reversed the trial court's decision, concluding that Lot 18 was a separate parcel entitled to the conclusive presumption of legality under section 66412.6(a) of the Subdivision Map Act.The Supreme Court of California reviewed the case and reversed the Court of Appeal's judgment. The court held that the phrase "division of land" in section 66412.6(a) should be interpreted in light of the Act’s general definition of "subdivision" in section 66424. The court concluded that a conveyance does not create multiple parcels merely by referring separately to lots of the contiguous property being conveyed. Since Lot 18 was always conveyed together with contiguous land and never separately, it was not created as a separate parcel under the Act. Therefore, the landowner was not entitled to a certificate of compliance for Lot 18 as a separate legal parcel. View "Cox v. City of Oakland" on Justia Law

In October 2014, Oscar Lopez and Sergio Vidrio stopped their car next to Nestor M. and Noel A.'s car. After a brief exchange, Lopez and Vidrio fired multiple shots, killing Nestor and injuring Noel. Lopez was convicted of first-degree murder, attempted premeditated murder, shooting at an occupied vehicle, and possession of a firearm by a felon. The jury found that Lopez committed the crimes for the benefit of a criminal street gang and used a firearm. Lopez was sentenced to 141 years to life in prison.Lopez appealed, and the Court of Appeal modified his sentence and conditionally reversed the judgment, remanding the case to the trial court for resentencing under Senate Bill Nos. 620 and 1393. While awaiting resentencing, Assembly Bill 333, which amended the gang enhancement statute, was enacted. The trial court declined to apply Assembly Bill 333 retroactively, resentencing Lopez to 101 years to life. Lopez appealed again, and the Court of Appeal held that the judgment was nonfinal for Estrada purposes but that the superior court lacked jurisdiction to apply Assembly Bill 333.The Supreme Court of California reviewed the case and held that Lopez was entitled to the retroactive application of Assembly Bill 333 because his judgment was not final for Estrada purposes. The court clarified that a criminal case is not final until the entire prosecution, including sentencing, is complete. The court reversed the judgment below and remanded for further proceedings consistent with its opinion, allowing Lopez to renew his arguments for resentencing under Senate Bill Nos. 567 and 81. View "P. v. Lopez" on Justia Law

Brittney Collins was convicted of second-degree murder for the death of her two-month-old son, Abel James Norwood, who was killed by his father, Matthew Norwood. Norwood committed the fatal act while Abel was under his care, and Collins was in another room. Collins and Norwood had a history of drug use, and Norwood had previously expressed not wanting the baby and had been abusive towards Collins during her pregnancy. On the day of the incident, Collins was recovering from childbirth complications and was in the front room while Norwood was caring for Abel in the back bedroom. Collins heard a bang but did not check on Abel immediately. Later, she found Abel in a state of medical emergency, and he was taken to the hospital, where he later died from blunt force trauma.The Kern County Superior Court convicted Collins of second-degree murder and assault with force likely to cause great bodily injury. The Court of Appeal affirmed the murder conviction, reasoning that Collins knew of Norwood’s abuse and intentionally failed to protect Abel, including on the day of the fatal act.The Supreme Court of California reviewed the case and held that the evidence was insufficient to convict Collins of second-degree murder. The court clarified that for implied malice murder based on a failure-to-protect theory, the evidence must show that the parent knew to a substantial degree of certainty that a life-endangering act was occurring or about to occur and failed to act in conscious disregard for life. The court found that Collins did not have the requisite mens rea to support a conviction under either a direct aider and abettor theory or a direct perpetrator theory. The court reversed the judgment of the Court of Appeal and remanded with instructions to vacate Collins’s conviction for second-degree murder and resentence her accordingly. View "People v. Collins" on Justia Law

The case involves Taylor Capito, who filed a class action lawsuit against San Jose Healthcare System, LP, also known as Regional Medical Center San Jose, challenging the assessment of Evaluation and Management Services (EMS) fees for two emergency room visits. Capito argued that Regional had a duty to notify emergency room patients about EMS fees beyond listing them in the chargemaster, such as through posted signage or during the patient registration process. She claimed that Regional's failure to do so constituted an unlawful, unfair, or fraudulent business practice under the Unfair Competition Law (UCL) and violated the Consumers Legal Remedies Act (CLRA).The trial court sustained Regional's demurrer without leave to amend, and the Court of Appeal affirmed. The appellate court reasoned that hospitals do not have a duty to disclose EMS fees beyond what is required by the relevant statutory and regulatory framework, following the reasoning in similar cases like Gray v. Dignity Health and Saini v. Sutter Health. The Court of Appeal also affirmed the trial court's order striking the class allegations in Capito's first amended complaint.The Supreme Court of California reviewed the case and affirmed the Court of Appeal's judgment. The court held that hospitals do not have a duty under the UCL or CLRA, beyond their obligations under the relevant statutory and regulatory scheme, to disclose EMS fees prior to treating emergency room patients. The court emphasized that requiring such disclosure would alter the balance of competing interests, including price transparency and the provision of emergency care without regard to cost, as reflected in the multifaceted scheme developed by state and federal authorities. The court also dismissed Capito's appeal from the trial court's order striking her class allegations as moot. View "Capito v. San Jose Healthcare System, LP" on Justia Law

A landlord, JJD-HOV Elk Grove, LLC (JJD), owns a shopping center in Elk Grove, California, and leased space to Jo-Ann Stores, LLC (Jo-Ann). The lease included a cotenancy provision allowing Jo-Ann to pay reduced rent if the number of anchor tenants or overall occupancy fell below a specified threshold. When two anchor tenants closed, Jo-Ann invoked this provision and paid reduced rent for about 20 months until the occupancy threshold was met again.The Sacramento County Superior Court ruled in favor of Jo-Ann, finding the cotenancy provision to be an alternative performance rather than a penalty. The Court of Appeal for the Third Appellate District affirmed this decision, distinguishing the case from a previous ruling in Grand Prospect Partners, L.P. v. Ross Dress For Less, Inc., which found a similar provision to be an unenforceable penalty.The Supreme Court of California reviewed the case to determine the validity of the cotenancy provision. The court held that the provision was a valid form of alternative performance, allowing JJD a realistic choice between accepting lower rent or taking steps to increase occupancy. The court found that the provision did not constitute an unreasonable penalty under California Civil Code section 1671, nor did it result in a forfeiture under section 3275. The court emphasized that contracts should be enforced as written, especially when negotiated by sophisticated parties.The Supreme Court of California affirmed the judgment of the Court of Appeal, upholding the cotenancy provision as a valid and enforceable part of the lease agreement. View "JJD-HOV Elk Grove, LLC v. Jo-Ann Stores, LLC" on Justia Law

In 2018, Richard Allen Mitchell was charged with one felony count of resisting an executive officer and one misdemeanor count of possessing a controlled substance. The prosecution also alleged that Mitchell had a prior "strike" conviction. Five years later, just before the trial was to begin, the trial court reduced the felony charge to a misdemeanor and referred Mitchell to a veterans court program.The Ventura County District Attorney sought review of the trial court's order by filing both an appeal and a petition for writ of mandate in the Court of Appeal. The district attorney argued that the trial court lacked statutory authority to reduce the felony charge to a misdemeanor before sentencing. The Court of Appeal stayed the trial court proceedings and issued an order to show cause. After briefing, the Court of Appeal held that the trial court's order was unauthorized and granted the requested relief, determining that the order was appealable under certain statutory provisions.The Supreme Court of California reviewed the case and disagreed with the Court of Appeal's finding on appealability. The Supreme Court held that the trial court's order was not appealable under the cited statutory provisions because it did not set aside or terminate any portion of the action but merely modified the charges. However, the Supreme Court concluded that the trial court's order was unauthorized and in excess of its jurisdiction, making it subject to writ review. The Supreme Court affirmed the judgment of the Court of Appeal but noted that the trial court's subsequent actions, taken while a temporary stay was in effect, were void. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "People v. Superior Court (Mitchell)" on Justia Law