Justia California Supreme Court Opinion Summaries

Plaintiffs filed a complaint for personal injuries and loss of consortium against Defendant corporation and other entities, alleging injuries from exposure to asbestos. Defendant demurred, alleging that more than three years before Plaintiffs filed their complaint, it had obtained a corporate dissolution pursuant to the laws of Delaware, Defendant's state of incorporation. Accordingly, Defendant argued, it lacked the capacity to be sued pursuant to Delaware's three-year survival statute. In opposition, Plaintiffs argued their action was permitted under California's own survival statute, which they asserted took precedence over Delaware law in this situation. The trial court sustained the demurrer and dismissed Plaintiffs' complaint, ruling that California's survival statute did not apply to foreign corporations, and hence Delaware's corresponding statute applied to Defendant. The court of appeal affirmed. The Supreme Court affirmed, holding (1) California's survival statute does not apply to foreign corporations; and (2) North American Asbestos Corp. v. Superior Court was disapproved of to the extent it held otherwise. View "Greb v. Diamond Int'l Corp." on Justia Law

Defendant was convicted of two counts of first degree murder. Defendant was sentenced to death. The Supreme Court affirmed the judgment, holding (1) the trial court's excusal of a prospective juror for cause was not prejudicial error; (2) the trial court did not prejudicially err in the guilt phase of the proceedings; (3) the trial court did not prejudicially err in the penalty phase of the proceedings; (4) no error, either alone or in conjunction with others, prejudiced Defendant; and (5) California's death penalty does not violate the Eighth Amendment or international law, including the International Covenant on Civil and Political Rights. View "People v. Williams" on Justia Law

The City fired Plaintiff, a bus driver, for allegedly poor job performance. Plaintiff brought this action against the City, alleging she was fired because of her pregnancy in violation of the Fair Employment and Housing Act (FEHA). During trial, the City requested the court to instruct the jury that if it found a mix of discriminatory and legitimate motives, the City could avoid liability by proving that a legitimate motive alone would have led it to make the same decision to fire Plaintiff. The trial court refused the instruction, and the jury returned a verdict for Plaintiff. The court of appeal reversed, concluding that the refusal to give the requested instruction was prejudicial error. The Supreme Court affirmed the court of appeal's judgment overturning the damages verdict in this case and remanded, holding (1) under the FEHA, when a jury finds that unlawful discrimination was a substantial factor motivating a termination of employment, and when the employer proves it would have made the same decision absent such discrimination, a court may not award damages, backpay, or an order of reinstatement; but (2) Plaintiff in this circumstance could still be awarded, where appropriate, declaratory relief or injunctive relief to stop discriminatory practices. View "Harris v. City of Santa Monica" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and first degree robbery. After a penalty trial, the trial court imposed the death sentence for the murder and a prison term for the robbery and enhancements. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not commit reversible error in selecting the jury; (2) the trial court did not commit reversible error in the guilt phase or the penalty phase proceedings; (3) the prosecutor did not engage in impermissible misconduct; and (4) the imposition of the death penalty does not violate the Eighth Amendment. View "People v. Whalen" on Justia Law

The Song-Beverly Credit Card Act governs the issuance and use of credit cards. One of its provisions, Cal. Civ. Code 1747.08, prohibits retailers from recording or requesting personal information from a credit card holder as a condition to accepting a credit card as payment. In this case, Plaintiff alleged that Defendant Apple Inc. required him to provide him his address and telephone number as a condition of accepting his credit card as payment in violation of section 1747.08. The trial court overruled Apple's demurrer in which Apple argued that the Act does not apply to online transactions and that deciding otherwise would undermine the prevention of identity theft and fraud. The court of appeal summarily denied Apple's petition for writ of mandate seeking review. After analyzing the statute's text, structure, and purpose, the Supreme Court reversed and remanded with directions to issue the writ, holding that section 1747.08 does not apply to online purchases in which the product is downloaded electronically. View "Apple Inc. v. Superior Court" on Justia Law

Defendant leased copiers to Plaintiff pursuant to a lease agreements entered into in 2001 and 2002. In 2008, Plaintiff sued Defendant for violation of the unfair competition law (UCL), Cal. Bus. & Prof. Code, 17200, alleging that Defendant charged for excess copies during its regular servicing of the copiers and that Defendant's practice of charging for test copies was unfair and fraudulent. The trial court sustained Defendant's demurrer and dismissed the action, concluding that because the complaint established a first violation in 2002, the claim was barred by the four-year statute of limitations. At issue on appeal was whether the continuing violation doctrine could be applied to extend the statute of limitations for UCL claims. A divided court of appeal affirmed, finding Plaintiff's claim untimely. The Supreme Court reversed, holding (1) the text and legislative history of the UCL leave UCL claims as subject to the common law rules of accrual as any other cause of action; and (2) continuous accrual principles prevented Plaintiff's complaint from being dismissed at the demurrer stage on statute of limitations grounds. View "Aryeh v. Canon Bus. Solutions, Inc." on Justia Law

At issue in this case was the Pendergrass rule, which establishes a limitation on the fraud exception to the parol evidence rule. Plaintiffs restructured their debt with a Credit Association in an agreement. Plaintiffs did not make the required payments, and the Credit Association recorded a notice of default. Eventually, Plaintiffs repaid the loan, and the Association dismissed its foreclosure proceedings. Plaintiffs then filed this action seeking damages for fraud and negligent misrepresentation and including causes of action for rescission and reformation of the restructuring agreement. Relying on the Pendergrass rule, the trial court granted summary judgment to the Credit Association, ruling that the fraud exception did not allow parol evidence of promises at odds with the terms of the written agreement. The court of appeal reversed, holding that the Pendergrass rule did not apply in this case. The Supreme Court affirmed, holding that Bank of America Ass'n v. Pendergrass was ill-considered, and should be overruled. View "Riverisland Cold Storage, Inc. v. Fresno-Madera Prod. Ass'n" on Justia Law

At issue in this case was the scope of the primary assumption of risk doctrine, under which participants in, and operators of, certain activities have no duty of ordinary care to protect other participants from risks inherent in the activity. Here, Plaintiff fractured her wrist on a bumper car ride at an amusement park. Plaintiff sued the park owner for negligence. The superior court granted summary judgment for Defendant on the basis of the primary assumption of risk doctrine. The court of appeal reversed, concluding the doctrine did not apply to bumper car rides. The Supreme Court reversed, holding (1) the primary assumption of risk doctrine applies to recreational activities such as bumper car rides; (2) the doctrine applied to the ride here; and (3) Defendant's limited duty of care under the doctrine, the duty not to unreasonably increase the risk of injury over and above that inherent in the low-speed collisions essential to bumper car rides, did not extend to preventing head-on collisions between the cars. View "Nalwa v. Cedar Fair, L.P." on Justia Law

After a labor union began picketing on a supermarket's privately owned walkway in front of the store's customer entrance, the supermarket owner sought a court injunction to prevent the picketing. The owner argued that because the union was using the walkway for expressive activity without complying with the supermarket's regulations, the union was trespassing on its property. The trial court denied relief, concluding that the supermarket owner had failed to satisfy Cal. Lab. Code 1138.1's requirements for obtaining an injunction against labor picketing. The court of appeal reversed, holding (1) the walkway was not a public forum, and therefore, the store owner could regulate speech in that area; and (2) both the Moscone Act and section 1138.1 violate free speech and equal protection because they give speech regarding a labor dispute greater protection that speech on other subjects. The Supreme Court reversed and remanded, holding (1) a union's picketing activities in the supermarket's privately owned entrance area do not have state constitutional protection; (2) however, those picketing activities do have statutory protection under the Moscone Act and section 1138.1; and (3) these statutory provisions do not violate the federal constitutional prohibition on content discrimination in speech regulations. View "Ralphs Grocery Co. v. United Food & Commercial Workers Union Local 8" on Justia Law

This case involved a revocable trust. After the settlor died, the beneficiaries sued the trustee for breach of the fiduciary duty committed while the settlor was still alive and the trust was still revocable rather than irrevocable. The trial court ruled in favor of the beneficiaries, finding that the trustee had violated his duty in various respects. The court of appeal reversed, holding that the beneficiaries did not have standing to maintain claims for breach of fiduciary duty against the trustee, as the trustee's duties were owed solely to the settlor during the settlor's lifetime and not to the trust beneficiaries. The Supreme Court reversed, holding that because a trustee's breach of the fiduciary duty owed to the settlor can substantially harm the beneficiaries by reducing the trust's value against the settlor's wishes, the beneficiaries do have standing to sue for a breach of that duty after the settlor has died. View "Giraldin v. Giraldin" on Justia Law