Justia California Supreme Court Opinion Summaries

Following the passage of Proposition 50, which revised congressional district maps in California, a community group in Riverside County alleged a discrepancy in the number of ballots counted versus ballots cast during the 2025 special election. Acting on the group’s report, the county sheriff’s department obtained search warrants from the Riverside County Superior Court and seized large quantities of ballots and election materials. The county registrar defended the official tally and explained the discrepancy at a public meeting. Despite the Attorney General’s request for a pause to review the investigation, the sheriff’s department advanced their search and began counting ballots, only halting after direct communication from the Attorney General.The Attorney General issued formal directives to the sheriff, instructing him to pause the investigation, preserve all seized materials, and provide case records for review. The sheriff initially did not respond, began counting ballots, then paused the count and secured the materials. Subsequent communications from the Attorney General reiterated these directives and requested records. After further seizures by the sheriff’s department, the Attorney General initiated litigation, seeking a writ of mandate in the California Court of Appeal, which denied relief on procedural grounds. The Attorney General then sought review in the Supreme Court of California.The Supreme Court of California held that the Attorney General, under the state Constitution and Government Code section 12560, possesses the authority to give binding directions to sheriffs regarding specific investigations when necessary to ensure uniform and adequate enforcement of state laws. The court concluded the directives issued in this case were within the Attorney General’s lawful authority and sufficiently specific. It granted writ relief, ordering the sheriff and department to comply with the Attorney General’s instructions to pause investigative actions, retain seized records (with certain exceptions), and provide requested materials. Each party was directed to bear its own costs. View "Bonta v. Bianco" on Justia Law

The plaintiff leased a new vehicle from the defendant, but soon experienced persistent defects that could not be repaired despite multiple attempts. After the defendant failed to promptly replace the vehicle or provide restitution under the Song-Beverly Consumer Warranty Act, the plaintiff filed suit for breach of warranty, seeking damages and attorney fees. During litigation, the defendant made a statutory settlement offer pursuant to Code of Civil Procedure section 998, presenting two alternative sets of terms: a lump-sum payment or a reimbursement option requiring proof of damages, both accompanied by provisions for attorney fees and costs.In the Los Angeles County Superior Court, the jury awarded the plaintiff damages totaling $76,155.27, less than the lump-sum alternative in the defendant’s 998 offer. The trial court found the offer valid, imposed section 998’s cost-shifting penalty, limited plaintiff’s postoffer costs and attorney fees, and awarded defendant its postoffer costs. The plaintiff appealed, contesting the validity of the alternative-choice offer. The California Court of Appeal upheld the trial court’s awards, finding the lump-sum alternative sufficiently certain but deemed alternative-choice offers categorically invalid for cost-shifting purposes.The Supreme Court of California reviewed whether an offer under section 998 that presents two independent, alternative sets of terms for acceptance is categorically invalid due to uncertainty. The Court held that such an alternative-choice offer can be valid if it clearly presents the alternatives and at least one alternative is sufficiently certain to permit accurate valuation at the time the offer is made. If the judgment or award does not exceed the highest valued, valid alternative, cost-shifting under section 998 is permitted. The Court affirmed the trial court’s award, but rejected the Court of Appeal’s categorical prohibition of alternative-choice offers under section 998. View "Gorobets v. Jaguar Land Rover North America, LLC" 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 conservatee challenged the practice of the San Joaquin County Public Conservator, represented by County Counsel, of filing a large number of judicial disqualification motions under Code of Civil Procedure section 170.6 against a specific judge in conservatorship proceedings. The challenge came after the judge admonished County Counsel for improper conduct, and, according to the petitioner, County Counsel responded by disqualifying the judge in over 300 cases within a few months, effectively forcing her reassignment. The petitioner argued that this pattern of “blanket” challenges was being used to control judicial assignments and undermine judicial independence, rather than based on a good faith belief in prejudice.The San Joaquin County Superior Court denied the petitioner’s opposition, citing the California Supreme Court’s earlier decision in Solberg v. Superior Court, which held that such blanket challenges did not violate separation of powers. The Court of Appeal summarily denied writ relief without addressing the substance of the petitioner’s claims. The petitioner then sought review from the Supreme Court of California, asking it to reconsider the continued validity of Solberg given changed conditions in California’s courts.The Supreme Court of California granted review and held that while section 170.6 remains facially constitutional, Solberg is overruled to the extent it bars as-applied, separation of powers challenges to blanket abuses of section 170.6. The Court held that if a party timely objects to a section 170.6 motion and makes a prima facie showing of bad faith blanket challenges, the court may inquire into the legitimacy of the asserted prejudice. The Court remanded the matter to the Court of Appeal to determine if further proceedings are necessary in light of this new standard. View "J.O. v. Super. Ct." on Justia Law

A group of homeowners, all over the age of 65, entered into contracts for energy efficiency improvements to their homes under California's Property Assessed Clean Energy (PACE) program. This program allows local governments to offer financing for such improvements, with repayment made through voluntary special assessments added to the homeowners’ property tax bills. Most local governments contracted private companies to administer these PACE loans. The homeowners alleged that these private administrators failed to comply with consumer protection and lending laws applicable to consumer lenders, such as providing required warnings and avoiding prohibited security interests. They filed suit under the Unfair Competition Law, seeking injunctive relief and restitution, including the return of assessment monies paid and prohibitions on future collection of delinquent assessments unless the assessments were removed from their properties.The San Diego County Superior Court sustained the defendants’ demurrers, concluding that the plaintiffs were required to exhaust administrative tax remedies before pursuing their claims in court. The California Court of Appeal affirmed, reasoning that because PACE assessments are collected as part of property taxes and the relief sought would invalidate those assessments, plaintiffs first needed to pay the assessments and seek administrative relief through the established tax refund procedures.The Supreme Court of California reviewed the case to determine whether plaintiffs were required to follow statutory procedures for challenging taxes. The court held that when plaintiffs’ claims effectively seek to invalidate PACE assessments or prevent their future collection, they must first pay the assessments and pursue administrative tax remedies. However, the court also held that plaintiffs are not required to use tax challenge procedures for claims that do not directly or indirectly challenge a tax, such as those solely addressing the administration of the PACE program. The judgment was affirmed in part, reversed in part, and the case remanded to consider whether plaintiffs should be allowed to amend their complaints to state only non-tax-related claims. View "Morgan v. Ygrene Energy Fund, Inc." on Justia Law

William Cannon was convicted of assault with intent to commit rape and dissuading a witness, after attacking a 16-year-old girl and confessing to other attempted sexual assaults. Near the end of his prison sentence, the district attorney petitioned to commit him under the Sexually Violent Predator Act (SVPA), which allows for the civil commitment of certain sex offenders after their sentences if they are found to be sexually violent predators. During pretrial proceedings, Cannon’s attorney, without Cannon’s personal attendance or express waiver, waived his right to a jury trial. The trial court did not advise Cannon of his jury trial rights or seek his personal waiver, as the SVPA does not require these steps. Following a bench trial, Cannon was found to be a sexually violent predator and was committed.On appeal, Cannon argued for the first time that the SVPA’s procedures violated his state and federal equal protection rights because, unlike other civil commitment schemes for individuals found not guilty by reason of insanity (NGI) or those with mental health disorders (OMHD), the SVPA does not require a judicial advisement of the right to a jury trial or a personal waiver from the defendant. The Court of Appeal considered the equal protection claim despite it not being raised below, found that rational basis review was the appropriate standard, and remanded the case to the trial court to allow the parties to develop a fuller record and litigate the equal protection issue.The Supreme Court of California reviewed the case to determine the appropriate standard of scrutiny for Cannon’s equal protection challenge. The court held that rational basis review, not strict scrutiny, applies to the SVPA’s jury trial demand and waiver procedures. The court affirmed the Court of Appeal’s remand order, directing the trial court to determine whether the legislative choice of procedures is constitutionally justified under rational basis review and whether Cannon knowingly waived his right to a jury trial. The order of commitment is conditionally affirmed pending the outcome of those proceedings. View "P. v. Cannon" on Justia Law

The case concerns the death of Skyler A. Womack, a dependent adult with disabilities who resided at a 24-hour skilled nursing facility operated by Silverscreen Healthcare, Inc. After Skyler’s death, his parents filed suit against the facility, alleging that neglect—including understaffing, failure to maintain the facility, and inadequate provision of basic needs—led to his injuries and death. The claims included survivor actions and a wrongful death claim. Notably, Skyler had signed an arbitration agreement upon admission, which stated that any medical malpractice disputes would be subject to arbitration and purported to bind his heirs.In the Los Angeles County Superior Court, Silverscreen moved to compel arbitration of all claims based on the arbitration agreement and the California Supreme Court’s decision in Ruiz v. Podolsky. The trial court compelled arbitration of the survivor claims but denied arbitration for the parents’ wrongful death claim, reasoning that the claim was based on neglect under the Elder Abuse Act, not professional negligence. The California Court of Appeal reversed, holding that the wrongful death claim was subject to arbitration because it was based on professional negligence as defined by the agreement and relevant statutes.The Supreme Court of California reviewed the case and reversed the Court of Appeal’s decision. The Court held that the exception recognized in Ruiz v. Podolsky applies only to wrongful death claims that are based on medical malpractice as defined by the Medical Injury Compensation Reform Act (MICRA), specifically disputes about whether medical services were improperly rendered. The Court clarified that not all wrongful death claims against health care providers fall within this exception—claims based on custodial neglect, as opposed to professional negligence in medical care, are not subject to arbitration under section 1295 and Ruiz. The Court remanded the case to allow plaintiffs to amend their complaint to clarify the basis of their wrongful death claim. View "Holland v. Silverscreen Healthcare, Inc." on Justia Law

Ty Whitehead suffered a serious head injury during a bicycle training ride for a charity fundraiser due to a large pothole on Skyline Boulevard in Oakland. Whitehead alleged that the City of Oakland breached its statutory duty to maintain a safe roadway. Prior to the ride, Whitehead signed a release and waiver of liability, which included a provision discharging the City from any liability for negligence.The Alameda County Superior Court granted summary judgment in favor of the City, holding that the release was valid and enforceable, thus barring Whitehead’s claim. The court reasoned that the release did not affect the public interest, relying on the multifactor test from Tunkl v. Regents of University of California. The Court of Appeal affirmed the trial court’s decision, also relying on the Tunkl framework.The Supreme Court of California reviewed the case and concluded that the release was against public policy under Civil Code section 1668, which prohibits contracts that exempt a party from responsibility for their own fraud, willful injury, or violation of law. The court held that an agreement to exculpate a party for future violations of a statutory duty designed to protect public safety is unenforceable. The court reversed the judgment of the Court of Appeal and remanded the case for further proceedings, allowing the City to argue the doctrine of primary assumption of risk on remand. View "Whitehead v. City of Oakland" on Justia Law

Daniel Escamilla, a certified fugitive recovery agent, searched the home of Lan Ting Wu and Andy Yu Feng Yang in 2012, looking for Yang’s brother, who was wanted on felony drug trafficking charges. Yang, Wu, and their minor son sued Escamilla for assault, battery, trespass, false imprisonment, and emotional distress. Their lawyer, John Vannucci, represented them. Escamilla defended the search as supported by probable cause and cross-complained against Yang for abuse of process. In 2019, a jury found in favor of Escamilla on all claims and awarded him $20,000 in damages. On August 30, 2021, Escamilla filed a malicious prosecution action against Yang, Wu, and Vannucci.The Alameda County Superior Court granted Vannucci’s motion to strike Escamilla’s complaint as a strategic lawsuit against public participation (SLAPP), agreeing that the one-year statute of limitations for claims against attorneys under section 340.6 applied, making the suit time-barred. The Court of Appeal affirmed this decision.The Supreme Court of California reviewed the case to determine the appropriate statute of limitations for a malicious prosecution action against an attorney. The court held that section 340.6, which provides a one-year limitations period for certain suits against attorneys, does not apply to claims brought by parties who were never their clients or the intended beneficiaries of their clients. Instead, the two-year statute of limitations under section 335.1 applies to malicious prosecution claims brought by formerly adverse parties. The court reversed the judgment and remanded the case to the Court of Appeal to consider any unaddressed arguments in the anti-SLAPP motion. View "Escamilla v. Vannucci" on Justia Law

Oscar and Audrey Madrigal purchased a car from Hyundai Motor America in 2011 for $24,172.73. The car allegedly did not function as warranted, and repeated repair attempts failed. The Madrigals requested Hyundai to repurchase the car under the Song-Beverly Consumer Warranty Act, but Hyundai refused, leading the Madrigals to sue for violations of the Act. Hyundai made two settlement offers under California Code of Civil Procedure section 998, which the Madrigals did not accept. On the first day of trial, after the court tentatively ruled against the Madrigals on pretrial motions, the parties settled for $39,000, with the Madrigals retaining the right to seek costs and attorney fees by motion.The Placer County Superior Court ruled that section 998 did not apply because the case settled before trial, and awarded the Madrigals $84,742.50 in attorney fees and $17,681.05 in other costs. Hyundai appealed, arguing that the Madrigals should not recover any postoffer costs because they settled for less than the second 998 offer. The Court of Appeal reversed, holding that section 998’s cost-shifting provisions applied and remanded for further proceedings.The Supreme Court of California affirmed the Court of Appeal’s decision. The Court held that section 998’s cost-shifting provisions apply even when a case settles before trial but after a section 998 offer is rejected or deemed withdrawn. The Court reasoned that the statute’s language and purpose—to encourage the settlement of lawsuits before trial—support this interpretation. The Court clarified that parties are free to agree on their own allocation of costs and fees as part of a settlement agreement, but absent such an agreement, section 998’s default cost-shifting rules apply. View "Madrigal v. Hyundai Motor America" on Justia Law