Justia California Supreme Court Opinion Summaries

Several plaintiffs alleged that they suffered injuries, such as renal, bone, or tooth damage, from taking a drug manufactured by Gilead Sciences, Inc. known as tenofovir disoproxil fumarate (TDF). Plaintiffs conceded that TDF was not defective but claimed that Gilead had developed an alternative drug, tenofovir alafenamide fumarate (TAF), which was equally effective and less toxic. Plaintiffs argued that Gilead unreasonably delayed bringing TAF to market, allegedly to maximize profits, and that this delay deprived them of a safer drug option, causing their injuries.In the San Francisco City and County Superior Court, Gilead moved for summary judgment, asserting that negligence liability could not attach for injuries caused by a nondefective product. The trial court denied Gilead’s motion. Gilead then petitioned the Court of Appeal, First Appellate District, Division Four, which partially granted the petition. The Court of Appeal directed summary adjudication on the fraudulent concealment claim but allowed the negligence claim to proceed. It held that drug manufacturers may owe a duty of reasonable care to users of a nondefective drug in deciding whether and when to commercialize a safer alternative.The Supreme Court of California reviewed the case and reversed the Court of Appeal’s judgment. The court held that, even assuming drug manufacturers might owe a broader duty of care beyond marketing nondefective drugs, the factors set forth in Rowland v. Christian justify an exception in this context. Specifically, the court determined that a manufacturer’s decision to delay commercialization of a safer drug during early development stages is too remote and unforeseeable to establish a duty of care, and imposing such liability would unduly burden innovation and public health. The Supreme Court directed the trial court to grant summary judgment for Gilead on all claims. View "Tenofovir Cases" on Justia Law

A county retirement system operating under the County Employees Retirement Law (CERL) sought a court order compelling the county to implement its decisions regarding job classifications and salary levels for certain system employees. Historically, the retirement system and county had cooperated, with the county including the retirement board’s requested positions and salaries in its salary ordinance. However, disputes arose when the county declined to approve some of the retirement system’s proposed classifications and salary adjustments, citing concerns about alignment with countywide standards and comparable positions elsewhere.The Los Angeles County Superior Court denied the retirement system’s request for relief, holding that the county retained final authority over classification and salary matters. The court relied on a prior appellate decision, Westly v. Board of Administration, which interpreted the California Constitution’s provision granting “plenary authority” to retirement boards as not extending to unilateral control over employee classifications and salaries. The trial court found that, while the retirement board had the power to recommend appointments and associated compensation, the board of supervisors was not required to adopt these recommendations without independent review or discretion.The California Court of Appeal, Second Appellate District, Division Seven, reversed, concluding that the retirement board possessed final authority over such employment matters. The court reasoned that Proposition 162, which amended the state constitution, gave retirement boards plenary authority over system administration, including personnel decisions.The Supreme Court of California reviewed the case and reversed the Court of Appeal. The Supreme Court held that the retirement board’s constitutional and statutory authority does not extend to unilaterally determining classifications and salaries for system staff who are county employees. Instead, these decisions remain under the county’s authority, though subject to judicial review for abuse of discretion. The Supreme Court clarified that counties must not unreasonably withhold approval of retirement board recommendations, but the final say rests with the county. View "L.A. County Employees Retirement Association v. County of L.A." on Justia Law

The defendant was tried for attempted murder and assault with a deadly weapon. During jury selection, the prosecutor used a peremptory challenge to excuse a prospective juror identified as Latino, prompting the defense to object under California Code of Civil Procedure section 231.7, which prohibits discrimination based on race or other protected status. The prosecutor gave multiple reasons for the strike, including that the juror was less attentive and engaged than others. The trial court confirmed the prosecutor’s observations and overruled the defense’s objection, without requiring a further explanation of why the juror’s behavior mattered to the case.The Court of Appeal, Second Appellate District, affirmed the trial court’s decision. The majority held that the prosecutor’s and court’s observations about the juror’s attentiveness were sufficient to overcome the statutory presumption that behavior-based reasons for a peremptory challenge are invalid, and independently sufficient to justify the strike. A dissenting justice argued that the prosecutor failed to explain why the juror’s behavior was relevant to the case, and thus the presumption of invalidity was not overcome.The Supreme Court of California reviewed the case. It clarified that section 231.7 requires both confirmation of the observed behavior and an explanation of its relevance to rebut the presumption of invalidity for behavior-based reasons. The court held that failing to rebut this presumption means the reason cannot justify the strike, but does not necessarily establish that the strike was unlawful; courts must still consider all reasons and circumstances to determine if there is a substantial likelihood that an objective observer would view race or other protected status as a factor. The Court reversed the judgment of the Court of Appeal and remanded for further proceedings. View "People v. Sanmiguel" on Justia Law

Several employee associations and a retired county employee challenged a resolution adopted by the Ventura County Employees’ Retirement Association (VCERA). The resolution limited the amount of cashed out leave that could be included in the calculation of “compensation earnable”—a key figure used to determine retirement benefits for so-called legacy members (employees hired before 2013) under the County Employees Retirement Law of 1937. The dispute centered on the California Public Employees’ Pension Reform Act of 2013 (PEPRA), which amended the law to exclude from pension calculations any leave cashout payments exceeding what may be “earned and payable in each 12-month period during the final average salary period,” regardless of when the payment is made. The controversy arose when a retired employee sought to have all 240 hours of his cashed out leave included in his final compensation period, even though county rules allowed only 200 hours to be cashed out per calendar year.The Santa Barbara County Superior Court granted summary adjudication in favor of VCERA, concluding that PEPRA’s section 31461(b)(2) was ambiguous but, as explained in the California Supreme Court’s earlier decision in Alameda County Deputy Sheriff’s Assn. v. Alameda County Employees’ Retirement Assn., the Legislature intended to curb “pension spiking” by imposing annual limits. The Second Appellate District, Division Six, affirmed this decision, interpreting the statute to mean that only leave cashouts within the annual limitation set by employment terms could be counted.The Supreme Court of California affirmed the Court of Appeal’s judgment. It held that section 31461(b)(2) of PEPRA excludes from pension calculations any cashed out leave that exceeds the applicable annual limit during the final compensation period, even if the period straddles two calendar years. This construction aligns with the statute’s purpose to prevent pension spiking and maintain the integrity and predictability of public pension systems. View "Ventura Cty Emp Ret Assn v. Crim J Atty Ret Assn Ventura Cty" on Justia Law

A dispute arose between former colleagues at an investment firm, resulting in costly litigation. Plaintiffs, representing one side of the conflict, alleged that three excess insurers improperly allowed their rivals to pursue insurance claims for litigation expenses that should have benefited plaintiffs. The insurance tower comprised a primary policy and several excess policies, each requiring exhaustion of underlying coverage before attachment. Plaintiffs claimed they had submitted invoices for covered losses but had not received reimbursement from any excess insurer. They sought damages and declaratory relief regarding coverage and liability under the excess policies, as well as claims for breach of the implied covenant of good faith and fair dealing.The San Francisco City and County Superior Court determined that plaintiffs had sufficiently alleged exhaustion of the primary insurance policy but not of the excess layers. As a result, claims against the first excess insurer proceeded, while demurrers by two higher-layer excess insurers were sustained. The California Court of Appeal affirmed the dismissal, reasoning that plaintiffs had not alleged an actual controversy regarding coverage for the higher excess policies because exhaustion had not occurred. The appellate court also found the absence of exhaustion fatal to plaintiffs’ claims for tortious breach of the implied covenant of good faith and fair dealing.The Supreme Court of California reviewed the case and held that plaintiffs may pursue claims for declaratory relief and tortious breach of the implied covenant of good faith and fair dealing against excess insurers even if all underlying insurance has not been exhausted. It is sufficient at the pleading stage to allege facts showing that coverage under an excess policy will attach and that insurer misconduct has impaired recovery. The Court reversed the judgment of the Court of Appeal and remanded for further proceedings. View "Fox Paine & Co, LLC v. Twin City Fire Ins Co" on Justia Law

A county public guardian filed a petition in 2020 seeking to place E.A., a 23-year-old woman with severe mental illness, under an involuntary conservatorship after she was found disoriented and unable to care for herself. E.A. accepted the initial conservatorship and its renewal in 2021, with findings by the Contra Costa County Superior Court that she was gravely disabled due to her mental disorder. In 2022, when the conservator petitioned for another renewal, E.A. requested a jury trial on the issue of grave disability. However, her trial was delayed by almost a year, mainly due to court congestion and resource constraints, despite her repeated objections and motions to dismiss the proceedings for violating her right to a timely trial. Ultimately, when the trial was finally set, E.A. agreed to another conservatorship in exchange for placement in a less restrictive setting.E.A. appealed the conservatorship order, arguing that the prolonged pretrial delays violated her constitutional right to due process. The California Court of Appeal affirmed the order, holding that while statutory deadlines for trial were directory, not mandatory, E.A. had not established a due process violation under the four-factor test from Barker v. Wingo, and had not shown prejudice from the delay.The Supreme Court of California reviewed the case and held that the Barker test is the appropriate framework for assessing due process violations based on pretrial delay in LPS conservatorship proceedings. The Court found that E.A.’s due process rights were violated by the nearly year-long delay. However, the violation was harmless beyond a reasonable doubt because there was no indication that the outcome—finding E.A. gravely disabled—would have been different absent the delay. The Court reversed the Court of Appeal’s judgment and remanded with instructions to dismiss the appeal as moot, as E.A.’s conservatorship had since been terminated. View "In re Conservatorship of E.A." on Justia Law

A husband and wife brought a lawsuit against a physician and his employer after the husband, working as a surgical technologist, was exposed to HIV-positive blood during a cardiac procedure. The exposure occurred when the physician discharged blood onto a sterile drape rather than into a splash bin, causing blood to splash into the husband’s eye. Following this incident, the husband underwent antiviral treatment with significant side effects and endured months of anxiety and medical testing, which also affected his marriage.The plaintiffs filed five claims, including negligence, assault, battery, unfair business practices, and loss of consortium (the latter on behalf of the wife only), in the Riverside County Superior Court. The defendants demurred to four of the claims and moved to strike several forms of relief. The trial court overruled the demurrer as to negligence but sustained it with leave to amend for the other challenged claims, and struck certain relief such as punitive damages. Before the amendment period expired, the plaintiffs voluntarily dismissed all their claims with prejudice, expressly to expedite an appeal of the trial court’s orders. After the clerk entered the dismissal, plaintiffs filed a notice of appeal. The Fourth Appellate District, Division One, dismissed the appeal for lack of jurisdiction, concluding that a voluntary dismissal is not an appealable judgment.The Supreme Court of California reviewed the matter and held that when a plaintiff voluntarily dismisses an action before the court has issued a final resolution as to any pleaded claim, the dismissal terminates the action and forfeits the right to appeal. The Court clarified that such a dismissal is a ministerial act, not a judgment that confers appellate jurisdiction. The Supreme Court affirmed the Court of Appeal’s dismissal of the appeal for lack of jurisdiction. View "Maniago v. Desert Cardiology Consultants' Medical Group" on Justia Law

The defendant was charged with several robberies and related offenses, and the prosecution alleged that he had previously served a prison term under former Penal Code section 667.5(b). The defendant pleaded no contest, admitting the prior prison term allegation. At sentencing in 2017, the Santa Clara County Superior Court found the prior prison term allegation true but exercised its discretion to strike the punishment for the enhancement in the interest of justice, without striking the allegation itself. The abstract of judgment reflected the true finding. After the Legislature enacted Penal Code section 1172.75, which retroactively invalidated most prior prison term enhancements imposed before January 1, 2020, the defendant petitioned for resentencing.The Santa Clara County Superior Court denied the petition, concluding that section 1172.75 applied only to persons for whom a section 667.5(b) enhancement was imposed and executed, not to those for whom the enhancement was stayed, stricken, or dismissed. On appeal, the Sixth District Court of Appeal reversed the superior court’s decision, holding that section 1172.75 applies whenever a prior prison term enhancement was imposed, regardless of whether the punishment was executed, stayed, or struck. A dissenting opinion argued that a punishment-stricken enhancement is not “imposed” under section 1172.75(a) because it does not lengthen a defendant’s sentence.The Supreme Court of California granted review and addressed whether section 1172.75(a) invalidates a prior prison term enhancement for which punishment was stricken. The Court held that an enhancement is “imposed” when it is made part of a legally effective sentencing order, even if the punishment is stricken. Consequently, the defendant is entitled to resentencing under section 1172.75. The Supreme Court of California affirmed the judgment of the Court of Appeal. View "People v. Espino" on Justia Law

Several individuals who were former students at an elementary school within a California school district alleged that a school counselor sexually assaulted them between 1993 and 2001. These plaintiffs initially filed lawsuits regarding the alleged abuse in California state court, then voluntarily dismissed those actions without prejudice. On the same day as those state court dismissals, they filed a similar action in the United States District Court for the Eastern District of California, alleging both state and federal claims. Before the federal court ruled on the defendant school district’s motion to dismiss, the plaintiffs again voluntarily dismissed the case, this time under Federal Rule of Civil Procedure 41(a)(1)(A)(i), designating the dismissal as without prejudice.Subsequently, the plaintiffs filed a new action in California state court based on the same underlying facts. The school district demurred, arguing that the so-called two-dismissal rule in Federal Rule 41(a)(1)(B)—which states that a plaintiff who twice voluntarily dismisses claims is subject to an adjudication on the merits—operated as a bar to the new state court action. The Yuba County Superior Court agreed, sustaining the district’s demurrer without leave to amend, and entered a judgment of dismissal. The California Court of Appeal, Third Appellate District, affirmed in a split decision, holding that the federal procedural rule precluded the state court claims.The Supreme Court of California reversed. The court held that Federal Rule 41(a)(1)(B) is a procedural rule that limits a plaintiff’s ability to refile the same claim in federal court but does not itself create a rule of claim preclusion applicable in state courts. Therefore, a second voluntary dismissal under Rule 41(a)(1)(B) does not bar a subsequent suit on the same state law claims in California state court. The matter was remanded for further proceedings. View "Doe v. Marysville Joint Unified School Dist." on Justia Law

A defendant faced five separate criminal cases, each involving different charges of burglary, theft, and related offenses. The defendant was arrested and held in custody for varying periods in each case, sometimes being out on bail or released on his own recognizance in one or more cases while remaining in custody for others. Ultimately, all five cases were resolved together through a plea agreement, and the defendant was sentenced at a single hearing, receiving concurrent sentences in each matter.After sentencing, the defendant requested that the trial court award presentence custody credits in each case for all time served in custody on any of the cases, not just the time specifically attributable to each individual case. The Monterey County Superior Court declined, awarding presentence credits in each case only for custody time attributable to that particular case. The defendant appealed, and the California Court of Appeal, Sixth Appellate District, reversed. The appellate court concluded that, because all five cases were resolved and sentenced at one hearing, the defendant should receive custody credits in each case for all time spent in custody on any of the cases, except for time that preceded the arrest in a specific case.The Supreme Court of California reviewed the case. It held that, under Penal Code section 2900.5, subdivision (b), the term “proceedings” refers to a single criminal case, not all cases resolved at one sentencing hearing. Therefore, custody credits must be awarded in each case only for the time the defendant was actually in custody in that case, not time served in other cases, even if the cases were resolved and sentenced together. The Supreme Court of California reversed the judgment of the Court of Appeal. View "P. v. Cofer" on Justia Law