Justia California Supreme Court Opinion Summaries
Pulliam v. HNL Automotive, Inc.
The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the trial court granting Plaintiff's postural motion seeking attorney's fees in the amount of $169,602 under the Song-Beverly Consumer Warranty Act, Cal. Civ. Code 1795, subd. (d), after awarding her $21,957.25 in damages on her claim for breach of the implied warranty of merchantability, holding that there was no error.Plaintiff purchased a used vehicle from a dealership pursuant to an installment sales contract that was later assigned to TD Auto Finance (TDAF). Plaintiff filed suit against the dealership and TDAF, alleging misconduct in the sale of the car. A jury found that Defendants breached the implied warranty of merchantability under the Song-Beverly Act and awarded damages and attorney's fees under the Song-Beverly Act. The court of appeal affirmed. The Supreme Court affirmed, holding that recovery under the Federal Trade Commission's Holder Rule does not limit the award of attorney's fees where, as a here, a buyer seeks fees from a holder under a state prevailing party statute. View "Pulliam v. HNL Automotive, Inc." on Justia Law
People v. Padilla
The Supreme Court held that Proposition 57, a measure that amended the law governing the punishment of juvenile offenses in adult criminal court by requiring hearings to determine whether the offenses should instead by hearing in juvenile court, applied during resentencing where the criminal court sentence imposed on Defendant, a juvenile offender, was issued before the initiative's passage but was since vacated.Defendant was originally sentenced before Proposition 57 was enacted, but his sentence was later vacated on habeas corpus, and the case was returned to the trial court for imposition of a new sentence. At issue was whether Proposition 57 applied to Defendant's resentencing. The Supreme Court affirmed the judgment of the court of appeal, holding that Proposition 57 applied to Defendant's resentencing because the judgment in his case became nonfinal when his sentence was vacated on habeas corpus. View "People v. Padilla" on Justia Law
Naranjo v. Spectrum Security Services, Inc.
The Supreme Court held that the additional hour of pay an employer must pay an employee if the employer unlawfully makes the employee work during all or part of a meal or rest period constitutes "wages" that must be reported on statutorily-required wage statements during employment and paid within statutory deadlines when an employee leaves the job.Plaintiff, who was suspended from his job as a guard after leaving his post to take a meal break. Plaintiff filed a putative class action on behalf of employees of Defendant seeking an additional hour of pay, so-called "premium pay," for each day on which Defendant failed to provide employees a legally-compliant meal break. The trial court determined that Defendant had violated the meal break laws for a certain period and that a failure to pay meal break premiums could support claims under the wage statement and timely payment statutes. The court of appeal reversed in part. The Supreme Court remanded the case, holding (1) the court of appeal erred in concluding that extra pay for missed breaks does not constitute "wages" to be reported on wage statements during employment; and (2) the seven percent default rate of prejudgment interest set by the state Constitution applies to amounts due for failure to provide meal and rest breaks. View "Naranjo v. Spectrum Security Services, Inc." on Justia Law
People v. Parker
The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of first degree murder and the jury's findings of the lying-in-wait special circumstance and the special circumstance allegations that Defendant intentionally killed the victim for financial gain while engaged in the commission or attempted commission of rape, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion by failing to initiate competency proceedings; (2) there was no error in the trial court's evidentiary rulings; (3) sufficient evidence supported the jury's true findings of the special circumstances, and the special circumstances, as applied, are not unconstitutional; (4) there was no instructional error; (5) Defendant's claims of prosecutorial misconduct were without merit; and (6) Defendant's remaining claims of error were unavailing. View "People v. Parker" on Justia Law
In re Conservatorship of Eric B.
In this case regarding conservatorships authorized by the Lanterman-Petris-Short (LPS) Act for persons gravely disabled by a mental disorder or chronic alcoholism the Supreme Court held that, for purposes of the right against compelled testimony, those facing an LPS conservatorship due to an inability to care for themselves are sufficiently similar to persons found not guilty of crimes by reason of insanity (NGIs) that equal protection principles require the government to justify its disparate treatment of these proposed conservatees.The Contra Costa County Public Guardian petitioned for an LPS conservatorship on the ground that Appellant was gravely disabled. Appellant requested a jury trial and objected to giving compelled testimony.The court overruled the petition. Appellant was called to testify during trial. The jury found Appellant gravely disabled, and the court appointed the Public Guardian as conservator. On appeal, Appellant challenged the order compelling his testimony. The court of appeals held that LPS conservatives and similarly situated with NGIs for the purposes of NGI extension proceedings but that the error in compelling Appellant's testimony was harmless. The Supreme Court affirmed, holding (1) traditional LPS conservatees are similarly situated with NGI’s for purposes of the right against compelled testimony; but (2) a remand was not appropriate in this case. View "In re Conservatorship of Eric B." on Justia Law
In re Christopher L.
The Supreme Court affirmed the judgment of the juvenile court, holding that the juvenile court committed serious errors by proceeding with a hearing to determine its jurisdiction over a child and disposition of a wardship petition without an incarcerated parent's presence and without appointing counsel for the parent, but the rule of automatic reversal was unwarranted in this case.The Los Angeles Department of Children and Family Services filed a dependency petition alleging that two children were at risk due to Mother's ongoing substance abuse and Father's criminal history. Neither Father, who was incarcerated, nor counsel for Father appeared at the ensuing combined jurisdiction and disposition hearing. The court sustained the petition as to both Father and Mother. Thereafter, the court terminated Father's parental rights. The court of appeal affirmed. The Supreme Court affirmed, holding that it was not structural error for the juvenile court to proceed with the jurisdiction and disposition hearing without Father's presence and without appointing Father an attorney. View "In re Christopher L." on Justia Law
Posted in: Family Law
People v. Bloom
The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of the first-degree murder of his father and the second-degree murders of his stepmother and stepsister and sentencing him to death, holding that Defendant's second-degree murder convictions must be reversed.A federal court vacated Defendant's initial conviction and sentence. After a retrial, Defendant was convicted of first- and second-degree murder, and the jury found true a multiple-murder special-circumstance finding and various firearm- and weapon-use findings. Defendant was sentenced to death. At trial, Defendant's counsel conceded his responsibility for the deaths of all three victims, but Defendant was willing to accept responsibility only for the killing of his father and objected to admitting responsibility for the other two deaths. The Supreme Court held (1) defense counsel violated Defendant's Sixth Amendment rights to choose the fundamental objectives of his defense; and (2) while the error did not affect Defendant's first-degree murder conviction or the associated firearm-use finding, the error requires reversal of the remainder of the judgment and the judgment of death. View "People v. Bloom" on Justia Law
People v. Bracamontes
The Supreme Court affirmed Defendant's conviction of first-degree murder and death sentence, holding that there was no prejudicial error.After a jury trial, Defendant was convicted of the first-degree murder of a nine-year-old girl, with special circumstances for committing the murder while engaged in kidnapping, lewd act on a child under fourteen, and oral copulation. A death sentence was imposed. The Supreme Court affirmed, holding (1) there was no prejudicial prefiling delay; (2) Defendant was not prejudiced by the trial court's order that he wear leg chains during trial; (3) the trial court did not err in excluding third party culpability evidence; (4) the trial court did not improperly allow certain victim impact testimony; and (5) Defendant's challenges to the constitutionality of the death penalty were unavailing. View "People v. Bracamontes" on Justia Law
Posted in: Criminal Law
People v. Lopez
The Supreme Court reversed the judgment of the court of appeal affirming Defendant's life sentence for his conviction of conspiracy to commit home invasion robbery under Cal. Penal Code 186.22(b)(4), holding that the superior court erred in sentencing Defendant to an indeterminate life term under that provision.Section 186.22(b)(4) prescribes indeterminate life terms for specified felonies, including home invasion robbery. At issue was whether Defendant was properly sentenced to an indeterminate life term even though he was convicted of the crime of conspiracy and not yet completed home invasion robbery. The Supreme Court answered the question in the negative, holding that section 186.22(b)(4) does not apply to conspiracy convictions. View "People v. Lopez" on Justia Law
Posted in: Criminal Law
Berroteran v. Superior Court
The Supreme Court reversed the judgment of the appellate court granting a writ of mandate directing the trial court to issue a new order denying Ford Motor Company's motion to exclude all of Plaintiff's proffered deposition testimony, holding that the court of appeal erroneously construed Wahlgren as establishing a categorical bar to admitted deposition testimony under Cal. Evid. Code 1291(a)(2).Plaintiff, a putative member of a federal multidistrict class action suit against Ford arising from the diesel engine used in some of Ford's vehicles, opted out of a federal suit in order to pursue his own lawsuit. Plaintiff filed ten designations of deposition testimony listing the depositions of nine out-of-state Ford employees or former employees had given deposition testimony in the federal action or in subsequent related California opt-out litigation that Plaintiff proposed to introduce at trial. Ford moved to exclude the proffered testimony, which the trial court granted. The Supreme Court reversed, holding that the appellate court’s analysis was incompatible with (1) the established principle that the party proposing to introduce evidence under section 1291(a)(2)’s former testimony exception to the hearsay rule bears the burden of establishing the requirements for admission; and (2) the Legislature’s official comment reflecting its understanding when it enacted the provision at issue as part of the Evidence Code in 1965. View "Berroteran v. Superior Court" on Justia Law