Justia California Supreme Court Opinion Summaries

In this case, a fire destroyed the building where Cory Michael Hoehn and his roommate lived. The building’s insurer, California Capital Insurance Company, determined that careless smoking caused the fire and sued Hoehn and his roommate for negligence, seeking damages. The company attempted to serve Hoehn with the complaint and summons, but the service was allegedly improper. A default judgment was entered against Hoehn in April 2011. In January 2020, Hoehn learned of the default judgment when his wages were garnished and promptly moved to set aside the judgment, claiming he was never properly served.The Placer County Superior Court denied Hoehn’s motion, ruling it was time-barred because it was filed more than two years after the default judgment. The court also found no extrinsic fraud or mistake. The Court of Appeal affirmed, relying on precedent that a motion to vacate a judgment for improper service must be made within two years if the judgment is not void on its face.The Supreme Court of California reviewed the case to determine the validity of the two-year time limit for such motions. The court held that the judicially created rule imposing a two-year limit on motions to vacate void judgments for improper service is not supported by the statute’s text, legislative intent, or sound justification. The court concluded that a motion to vacate a judgment void for lack of proper service under section 473(d) is not subject to a two-year limitation. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Cal. Capital Ins. Co. v. Hoehn" on Justia Law

In this case, the petitioners sought to disqualify a trial court judge based on alleged bias and prejudice. The key facts revolve around a wage-and-hour class action lawsuit initiated by the real parties in interest against the petitioners, their employer. During the litigation, the trial judge made comments suggesting the petitioners were attempting to evade liability through corporate restructuring. These comments were cited by the petitioners as evidence of bias.The Fresno County Superior Court judge struck the petitioners' statement of disqualification as untimely. The petitioners then sought writ review in the Court of Appeal, which held that the nonwaiver provision of section 170.3(b)(2) precluded the application of the timeliness requirement in section 170.3(c)(1) when a party alleges judicial bias or prejudice. The Court of Appeal reasoned that the nonwaiver provision should be interpreted to prohibit all forms of waiver, including implied waiver due to untimeliness.The Supreme Court of California reviewed the case and disagreed with the Court of Appeal's interpretation. The Supreme Court held that the nonwaiver provision of section 170.3(b)(2) applies only to judicial self-disqualification and does not affect the timeliness requirement for party-initiated disqualification attempts under section 170.3(c)(1). The Court emphasized that the statutory text, structure, legislative history, and case law support this interpretation. Consequently, the Supreme Court reversed the Court of Appeal's judgment and remanded the case for the lower court to determine whether the petitioners' statement of disqualification was filed in a timely manner. View "North Am. Title Co. v. Superior Court" on Justia Law

David Meinhardt, a police officer, was suspended for 44 hours by the City of Sunnyvale Department of Public Safety, a decision upheld by the City of Sunnyvale Personnel Board. Meinhardt filed a petition for a writ of administrative mandate in the Santa Clara County Superior Court, challenging the suspension. On August 6, 2020, the court issued an order denying the petition. The City served Meinhardt with a notice of entry of this order on August 14, 2020. Subsequently, on September 25, 2020, the court entered a formal judgment, which Meinhardt served on the City on September 22, 2020.The Fourth Appellate District, Division One, dismissed Meinhardt's appeal as untimely, holding that the August 6 order was the final judgment from which the appeal should have been taken. The court reasoned that the order was sufficiently final to constitute the judgment, thus starting the 60-day period for filing an appeal.The Supreme Court of California reviewed the case to resolve the issue of when the time to appeal begins in administrative mandate proceedings. The court held that the time to appeal starts with the entry of a formal judgment or the service of notice of entry of judgment, not with the filing of an order or other ruling. The court emphasized the importance of clear, bright-line rules to avoid confusion and ensure that parties do not inadvertently forfeit their right to appeal. Consequently, the Supreme Court reversed the judgment of the Court of Appeal, finding that Meinhardt's appeal, filed within 60 days of the entry of the formal judgment, was timely. View "Meinhardt v. City of Sunnyvale" on Justia Law

The City of Los Angeles contracted with PricewaterhouseCoopers (PwC) to modernize the billing system for the Department of Water and Power (LADWP). The rollout in 2013 resulted in billing errors, leading the City to sue PwC in 2015, alleging fraudulent misrepresentation. Concurrently, a class action was filed against the City by Antwon Jones, represented by attorney Jack Landskroner, for overbilling. Discovery revealed that the City’s special counsel had orchestrated the class action to settle claims favorably for the City while planning to recover costs from PwC.The Los Angeles County Superior Court found the City engaged in extensive discovery abuse to conceal its misconduct, including withholding documents and providing false testimony. The court imposed $2.5 million in monetary sanctions against the City under the Civil Discovery Act, specifically sections 2023.010 and 2023.030, which allow sanctions for discovery misuse.The California Court of Appeal reversed the sanctions, interpreting the Civil Discovery Act as not granting general authority to impose sanctions for discovery misconduct beyond specific discovery methods. The appellate court held that sections 2023.010 and 2023.030 do not independently authorize sanctions but must be read in conjunction with other provisions of the Act.The Supreme Court of California reversed the Court of Appeal’s decision, holding that the trial court did have the authority to impose monetary sanctions under sections 2023.010 and 2023.030 for the City’s pattern of discovery abuse. The Supreme Court clarified that these sections provide general authority to sanction discovery misuse, including systemic abuses not covered by specific discovery method provisions. View "City of Los Angeles v. Pricewaterhousecoopers, LLP" on Justia Law

The case involves three Lyft drivers, Tina Turrieta, Brandon Olson, and Million Seifu, who each filed separate lawsuits under the California Labor Code Private Attorneys General Act of 2004 (PAGA) against Lyft, Inc. for alleged labor violations. Turrieta settled her case with Lyft, but before the settlement was approved, Olson and Seifu sought to intervene and object to the settlement, arguing it was unfair and that they had overlapping claims. The trial court denied their motions to intervene, approved the settlement, and later denied their motions to vacate the judgment.Olson and Seifu appealed the trial court's decisions. The Court of Appeal affirmed the trial court's rulings, holding that Olson and Seifu lacked standing to intervene or to challenge the settlement because they were not aggrieved by the judgment. The appellate court reasoned that PAGA actions are representative actions on behalf of the state, and thus, Olson and Seifu did not have a personal interest in the settlement of Turrieta’s PAGA claim.The California Supreme Court reviewed the case and agreed with the Court of Appeal. The Supreme Court held that PAGA does not authorize one aggrieved employee to intervene in another employee’s PAGA action asserting overlapping claims. The Court reasoned that allowing such intervention would be inconsistent with the statutory scheme of PAGA, which provides for oversight of settlements by the Labor and Workforce Development Agency (LWDA) and the courts, but does not mention intervention by other PAGA plaintiffs. The Court emphasized that the statutory language and legislative history indicate that the Legislature intended for the LWDA and the courts to ensure the fairness of PAGA settlements, not other PAGA plaintiffs.The Supreme Court affirmed the judgment of the Court of Appeal, concluding that Olson and Seifu did not have the right to intervene, object to, or move to vacate the judgment in Turrieta’s PAGA action. View "Turrieta v. Lyft, Inc." on Justia Law

In May 2019, the City of Sunnyvale Department of Public Safety imposed a 44-hour suspension on Officer David Meinhardt, which was upheld by the City of Sunnyvale Personnel Board. Meinhardt challenged the suspension by filing a petition for writ of administrative mandate in the Santa Clara County Superior Court. On August 6, 2020, the court issued an order denying the petition. Subsequently, on September 25, 2020, a formal judgment was entered, and Meinhardt filed a notice of appeal on October 15, 2020.The Fourth Appellate District, Division One, dismissed the appeal as untimely, concluding that the August 6 order was the final judgment from which Meinhardt should have appealed. The court reasoned that the order denied the petition in its entirety and did not contemplate further action, thus starting the 60-day period for filing an appeal.The Supreme Court of California reviewed the case to resolve the uncertainty about when the time to appeal starts in writ of administrative mandate proceedings. The court held that the time to appeal begins with the entry of a "judgment" or the service of notice of entry of "judgment," rather than with the filing of an "order" or other ruling. This decision was based on the plain language of relevant statutes and rules, which contemplate the entry of a "judgment," and the policy of providing clear jurisdictional deadlines to avoid inadvertent forfeiture of the right to appeal. The court reversed the judgment of the Court of Appeal, concluding that Meinhardt's notice of appeal was timely filed within 60 days of the entry of the September 25 judgment. View "Meinhardt v. City of Sunnyvale" on Justia Law

Peter Quach filed a lawsuit against California Commerce Club (Commerce Club) after being terminated from his job at the casino where he had worked for nearly 30 years. Quach's complaint included claims of wrongful termination, age discrimination, retaliation, and harassment, and he demanded a jury trial. Commerce Club had previously provided Quach with a signed arbitration agreement from 2015, which mandated binding arbitration for employment-related disputes. Instead of moving to compel arbitration, Commerce Club answered the complaint and engaged in extensive discovery, including propounding interrogatories and taking Quach’s deposition.The Los Angeles County Superior Court denied Commerce Club’s motion to compel arbitration, finding that Commerce Club had waived its right to arbitrate by engaging in litigation for 13 months. The court noted that Commerce Club had actively participated in discovery and requested a jury trial, actions inconsistent with an intent to arbitrate. Commerce Club appealed, and the Second Appellate District, Division One, reversed the trial court’s decision, holding that Quach had not shown sufficient prejudice from Commerce Club’s delay in seeking arbitration.The Supreme Court of California reviewed the case and abrogated the state’s arbitration-specific prejudice requirement, aligning with the U.S. Supreme Court’s decision in Morgan v. Sundance, Inc. The court held that under California law, as under federal law, courts should apply the same principles to determine waiver of the right to compel arbitration as they do for other contracts. The court concluded that Commerce Club had waived its right to compel arbitration by engaging in litigation conduct inconsistent with an intent to arbitrate. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings consistent with this decision. View "Quach v. Cal. Commerce Club, Inc." on Justia Law

This case involves a dispute over insurance coverage for continuous injury claims. The plaintiff, Truck Insurance Exchange, was a primary insurer for Kaiser Cement and Gypsum Corporation. Truck filed an equitable contribution claim against several insurers that had issued first-level excess policies to Kaiser for policy years where the directly underlying primary policy had been exhausted. Truck argued that the excess insurers’ indemnity obligations were triggered immediately upon exhaustion of the directly underlying primary policies. The excess insurers, however, argued that they had no duty to indemnify Kaiser until it had exhausted every primary policy issued during the period of continuous damage. The trial court and the Court of Appeal agreed with the excess insurers, interpreting the excess policies as requiring horizontal exhaustion of all primary insurance.The Supreme Court of California disagreed, concluding that the language of the first-level excess policies at issue in this case is essentially identical to the policy language in the higher-level excess policies that it considered in a previous case, Montrose III. The Court held that the first-level excess policies are most reasonably construed as requiring only vertical exhaustion. However, the Court also noted that its conclusion does not fully resolve the questions presented in this appeal, which involves a contribution claim between coinsurers. The Court remanded the matter to allow the Court of Appeal to address these alternative arguments in the first instance. View "Truck Ins. Exchange v. Kaiser Cement & Gypsum Corp." on Justia Law

The case involves Gustavo Naranjo and other plaintiffs who worked as guards for Spectrum Security Services, Inc. The plaintiffs alleged that Spectrum violated state regulations governing meal breaks by not providing legally compliant meal breaks and failing to pay an additional hour of pay, known as "premium pay," for each day on which this occurred. The plaintiffs also claimed that Spectrum violated Labor Code sections 201, 202, 203, and 226 by not timely paying owed meal break premiums as wages to employees once they were discharged or resigned, and by not reporting the premium pay it owed as wages on employees’ wage statements.The case has been through multiple stages of litigation. Initially, the trial court granted summary judgment for Spectrum, but this was reversed by the Court of Appeal. On remand, the trial court certified a class for the meal break and related timely payment and wage statement claims and held a trial in three phases. The trial court found that Spectrum had violated sections 203 and 226 by failing to pay and report the missed-break premium pay as wages. However, it issued a split decision on the question of penalties. It ruled in Spectrum’s favor regarding section 203 penalties, finding that Spectrum’s defenses were presented in good faith and were not unreasonable or unsupported by the evidence. But it ruled against Spectrum regarding section 226 penalties, finding that Spectrum was liable for penalties because its failure to report premium pay for missed meal breaks in employees’ wage statements was “knowing and intentional and not inadvertent.”Both sides appealed the trial court’s ruling. The Court of Appeal affirmed the trial court’s holding that Spectrum had violated meal break laws between June 2004 and September 2007. But it reversed the trial court’s holding that Spectrum had violated section 203 and section 226 by failing to timely pay and report the meal break premium pay owed as “wages,” reasoning that the premium pay was instead in the nature of a penalty rather than compensation for work performed.The Supreme Court of California held that if an employer reasonably and in good faith believed it was providing a complete and accurate wage statement in compliance with the requirements of section 226, then it has not knowingly and intentionally failed to comply with the wage statement law. The court affirmed the judgment of the Court of Appeal, which reached the same conclusion. View "Naranjo v. Spectrum Security Services, Inc." on Justia Law

In this case, the Supreme Court of California held that a trial court has discretion to grant or deny relief from a jury trial waiver under section 631(g) of the Code of Civil Procedure. The court is not required to grant relief just because proceeding with a jury would not cause hardship to other parties or the court. The court should consider various factors, including the timeliness of the request and the reasons supporting the request. The court further held that a litigant who challenges the denial of relief from a jury waiver for the first time on appeal must show actual prejudice to obtain reversal.The case involved TriCoast Builders, Inc. and Nathaniel Fonnegra. Fonnegra hired TriCoast to repair his house after a fire, but he was unhappy with the quality of the work and terminated the contract. TriCoast sued Fonnegra for damages. Fonnegra initially demanded a jury trial, but waived this right on the day of the trial. TriCoast, which had not demanded a jury trial or paid the jury fee, requested a jury trial after Fonnegra’s waiver. The trial court denied their request and a bench trial was held. TriCoast appealed the judgment, arguing that the trial court erred in denying their request for a jury trial. The Supreme Court affirmed the judgment of the Court of Appeal, concluding that TriCoast had not established the prejudice necessary to justify reversing the trial court's judgment. View "TriCoast Builders, Inc. v. Fonnegra" on Justia Law