Justia California Supreme Court Opinion Summaries

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The Supreme Court held that equitable tolling can lessen the otherwise strict time limit on the availability of writs of administrative mandate under Cal. Gov't Code 11523. The State Department of Public Health (the Department) imposed a fine on Saint Francis Memorial Hospital when it learned that doctors left a surgical sponge in a patient during a surgery. The Department later denied Saint Francis's request for reconsideration. Eleven days after the Department denied reconsideration but forty-one days after being served with the Department's final decision Saint Francis filed a petition for a writ of administrative mandate.The Department demurred on the ground that the petition was untimely under section 11523. The superior court sustained the Department's demurrer, reasoning that Saint Francis's petition was time-barred and that Saint Francis's mistake about the availability of reconsideration was not a sufficient basis to excuse a late filing. The court of appeal affirmed. The Supreme Court vacated the court of appeal's judgment, holding (1) equitable tolling may apply to petitions filed under section 11523; and (2) because the court of appeal didn't address equitable tolling's third element, the case is remanded for further proceedings. View "Saint Francis Memorial Hospital v. State Department of Public Health" on Justia Law

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In this case concerning the application of various California wage and hour laws to flight attendants who work primarily outside California's territorial jurisdiction, the Supreme Court held that California's wage statement laws apply only to flight attendants who have their base of work operations in California. Plaintiffs, flight attendants for Delta Air Lines, Inc., filed a putative class action in federal court alleging that Delta violates California labor law by failing to pay its flight attendants minimum wage. The federal district court ruled in favor of Delta. On appeal, the United States Court of Appeals for the Ninth Circuit asked that the Supreme Court resolve unsettled questions of California law underlying Plaintiffs' claims. The Supreme Court held (1) California's wage statement laws apply only to flight attendants who have their base of work operations in California, and the same is true of California laws governing the timing of wage payments; and (2) whether or not California's minimum wage laws apply to work performed on the ground during Plaintiffs' brief and episodic stops in California, the challenged pay scheme complies with the state requirement that employers pay their employees at least the minimum wage for all hours worked. View "Oman v. Delta Air Lines, Inc." on Justia Law

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The Supreme Court held that the question of whether Plaintiffs, pilots and flight attendants who resided in California but performed most of their work in airspace outside California's jurisdiction, were entitled to California-compliant wage statements depended on whether Plaintiffs' principal place of work was in California. Plaintiffs worked for a global airline based outside California. Plaintiffs were not paid according to California wage law but according to the terms of a collective bargaining agreement entered under federal law. At issue before the Supreme Court was whether the airline-employer was required to provide Plaintiffs with wage statements that met the requirements of California law. The Supreme Court held (1) workers are entitled to California-complaint wage statements if they are based for work purposes in California; and (2) for interstate transportation workers who do not perform a majority of their work in any one state, this test is satisfied when California serves as the workers' base of work operations, regardless of their place of residence or whether a collective bargaining agreement governs their pay. View "Ward v. United Airlines, Inc." on Justia Law

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The Supreme Court held that the unfair competition law (UCL), Cal. Bus. & Prof. Code 17200 et seq., is not limited to the geographic boundaries of Orange County and therefore does not preclude a district attorney from including allegations of violations occurring outside as well as within the borders of her or his county. The Orange County District Attorney brought this action against several pharmaceutical companies, alleging that Defendants had intentionally delayed the sale of a generic version of a popular pharmaceutical drug to maximize their profits. The District Attorney sought statewide monetary relief. Defendants moved to strike references to "California" in their complaint, arguing that the district attorney's authority to enforce California's consumer protection laws is limited to Orange County's borders. The trial court denied the motion to strike. The court of appeals directed the trial court to vacate its order and granted the motion to strike. The Supreme Court reversed, holding that the trial court did not err in denying the motion to strike because the UCL did not preclude the District Attorney from including allegations of violations occurring outside the borders of Orange County. View "Abbott Laboratories v. Superior Court of Orange County" on Justia Law

Posted in: Consumer Law
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In this appeal stemming from a first degree murder judgment the Supreme Court reversed the judgment of the court of appeal denying Petitioner's petition for writ of habeas corpus challenging the jury's special circumstance finding that the murder was committed during an attempted robbery, holding that Petitioner did not act with reckless indifference to human life and thus the special circumstance finding must be reversed. After a trial, the jury convicted Petitioner of first degree murder and attempted robbery and found true the special circumstance allegation that the murder was committed during an attempted robbery. After Petitioner's conviction became final, the Supreme Court decided People v. Banks, 61 Cal.4th 788 (2015), and People v. Clark, 63 Cal.4th 522 (2016), which clarified the meaning of the special circumstances statute. After the court of appeal denied Petitioner's habeas corpus petition, the Supreme Court granted review to determine whether Petitioner's conduct was proscribed by the special circumstances statute as construed in Banks and Clark. The Supreme Court reversed the court of appeal's judgment, holding that the evidence did not support a finding that Petitioner acted with reckless indifference to human life. View "In re Scoggins" on Justia Law

Posted in: Criminal Law
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The Supreme Court remanded this matter to the superior court to allow Defendant an opportunity to seek relief under Senate Bill 1393, holding that the court of appeals properly concluded that a certificate of probable causewas not required and that Senate Bill 1393 applied retroactively to Defendant. Pursuant to a plea agreement, Defendant pled guilty to one first degree burglary and admitted one serious felony conviction in exchange for a nine-year sentence. The sentence was based on the low term for burglary, doubled under the Three Strikes law, plus five years for the serious felony enhancement. While Defendant's appeal was pending, a new law went into effect - Cal. Penal Code 1385, subd. (a) - permitting the trial court to strike a serious felony enhancement in furtherance of justice. The Supreme Court held (1) Defendant was not required to obtain a certificate of probable cause to claim on appeal that the new law applied to him retroactively; (2) the new law applied to Defendant because his case was not yet final on appeal; and (3) the superior court is not authorized to exercise its discretion to strike the enhancement but otherwise maintain the plea bargain. View "People v. Stamps" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the court of appeal conditionally reversing Defendant's convictions and sentence with instructions for the trial court to consider Defendant's eligibility for diversion under Cal. Penal Code 1001.36, holding that the court of appeal did not err when it remanded this case for a diversion eligibility hearing. Defendant was found guilty of two counts of second degree robbery and of throwing a substance at a motor vehicle without intent to cause injury. While Defendant's appeal was pending, the Legislature enacted sections 1001.35 and 100.36, which created a pretrial diversion program for certain defendants with mental health disorders. The court of appeal conditionally reversed Defendant's conviction and sentence, concluding that section 1001.36 applies retroactively to all nonfinal judgments and that Defendant was entitled to a limited remand because he appeared to satisfy at least one of the statute's threshold eligibility requirements. The Supreme Court affirmed, holding (1) section 1001.36 applies retroactively; and (2) a conditional limited remand was appropriate in this case. View "People v. Frahs" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to modify the jury's verdicts of burglary and first degree murder, first degree forcible rape, second degree robbery and false imprisonment by violence and sentencing Defendant to death, holding that considering assumed errors altogether, reversal was not warranted. Defendant, an African-American, was charged with raping and murdering a White woman. On appeal, Defendant argued, among other things, that the prosecutor improperly exercise peremptory challenges to excuse two prospective jurors, who were African-American, in violation of Batson v. Kentucky, 476 U.S. 79, and People v. Wheeler, 22 Cal.3d 258, 276-277. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) substantial evidence supported the trial court's conclusion that the prosecutor struck the potential jurors for reasons other than his race; (2) there was no error in the trial court's decision to excuse two jurors for cause; (3) there was no merit to Defendant's allegations of error during the guilt phase; and (4) any assumed errors during the competency phase and penalty phase were not prejudicial and, considered cumulatively, did not require reversal. View "People v. Miles" on Justia Law

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The Supreme Court reversed the decision of the court of appeal reversing the judgment of the trial court granting a petition for writ of mandate directing the City of Hayward to refund to a records requester the charges for approximately forty hours its staff spent editing out exempt material from digital police body camera footage, holding that the trial court was correct to disallow the City's charge for time its staff spent responding to the requests. The City claimed that its costs for time its employees spent responding to Plaintiff's requests were chargeable as costs of data extraction under Cal. Gov't Code 6253.9, subdivision (b)(2). The Supreme Court held that the City must bear its own redaction costs because the term "data extraction" does not cover the process of redacting exempt material from otherwise disclosable electronic records. View "National Lawyers Guild v. City of Hayward" on Justia Law

Posted in: Communications Law
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The Supreme Court reversed the judgment of the court of appeal, holding that, under the facts of this case, a witness's observation of a company's name and logo appearing on an invoice was circumstantial evidence of identity, not proof of matters asserted in the document, and therefore, Defendant's hearsay objection was properly rejected. Plaintiffs sued Defendants, entities involved in the distribution and use of pipes containing asbestos, claiming that Defendants were liable for his mesothelioma. Only Keenan Properties, Inc.'s liability was at issue in this appeal, and the question turned on whether Keenan was the source of the pipes. The jury returned a verdict in favor of Plaintiffs, and a judgment of $1,626,517 was entered against Keenan. The court of appeal reversed, concluding that descriptions of Keenan sales invoices were hearsay. The Supreme Court reversed, holding that the trial court was correct in admitting testimony describing the invoices because the testimony did not convey hearsay. View "Hart v. Keenan Properties, Inc." on Justia Law

Posted in: Personal Injury