Justia California Supreme Court Opinion Summaries

The case involves Taylor Capito, who filed a class action lawsuit against San Jose Healthcare System, LP, also known as Regional Medical Center San Jose, challenging the assessment of Evaluation and Management Services (EMS) fees for two emergency room visits. Capito argued that Regional had a duty to notify emergency room patients about EMS fees beyond listing them in the chargemaster, such as through posted signage or during the patient registration process. She claimed that Regional's failure to do so constituted an unlawful, unfair, or fraudulent business practice under the Unfair Competition Law (UCL) and violated the Consumers Legal Remedies Act (CLRA).The trial court sustained Regional's demurrer without leave to amend, and the Court of Appeal affirmed. The appellate court reasoned that hospitals do not have a duty to disclose EMS fees beyond what is required by the relevant statutory and regulatory framework, following the reasoning in similar cases like Gray v. Dignity Health and Saini v. Sutter Health. The Court of Appeal also affirmed the trial court's order striking the class allegations in Capito's first amended complaint.The Supreme Court of California reviewed the case and affirmed the Court of Appeal's judgment. The court held that hospitals do not have a duty under the UCL or CLRA, beyond their obligations under the relevant statutory and regulatory scheme, to disclose EMS fees prior to treating emergency room patients. The court emphasized that requiring such disclosure would alter the balance of competing interests, including price transparency and the provision of emergency care without regard to cost, as reflected in the multifaceted scheme developed by state and federal authorities. The court also dismissed Capito's appeal from the trial court's order striking her class allegations as moot. View "Capito v. San Jose Healthcare System, LP" on Justia Law

Plaintiffs Everardo Rodriguez and Judith Arellano purchased a two-year-old car with over 55,000 miles on it, which still had an unexpired manufacturer’s powertrain warranty. Despite numerous repair attempts by the defendant, FCA US, LLC (FCA), the car continued to experience engine problems. Plaintiffs sued FCA under the Song-Beverly Consumer Warranty Act, seeking to enforce the refund-or-replace provision, arguing that their car qualified as a “new motor vehicle” because it was sold with a manufacturer’s new car warranty.The Riverside County Superior Court granted FCA’s motion for summary judgment, concluding that the plaintiffs’ car did not qualify as a “new motor vehicle” under the Act. The Fourth Appellate District, Division Two, affirmed the trial court’s decision, holding that the phrase “other motor vehicle sold with a manufacturer’s new car warranty” does not include previously owned vehicles with some balance remaining on the manufacturer’s express warranty.The Supreme Court of California reviewed the case and affirmed the judgment of the Court of Appeal. The Court held that a motor vehicle purchased with an unexpired manufacturer’s new car warranty does not qualify as a “motor vehicle sold with a manufacturer’s new car warranty” under section 1793.22, subdivision (e)(2) of the Song-Beverly Act unless the new car warranty was issued with the sale. The Court emphasized that the statutory language and the broader context of the Song-Beverly Act support this interpretation, maintaining the distinction between new and used vehicles and their respective warranty protections. View "Rodriguez v. FCA US, LLC" on Justia Law

Plaintiff Katherine Rosenberg-Wohl procured a homeowners insurance policy from State Farm Fire and Casualty Company, which covered various risks including fire. After her neighbor fell on her staircase, she discovered the stairs needed replacement and filed a claim with State Farm. The insurer denied her claim, citing policy exclusions. Rosenberg-Wohl then filed two lawsuits: one for breach of contract and another under the Unfair Competition Law (UCL), seeking declaratory and injunctive relief regarding State Farm’s general claims-handling practices.The San Francisco City and County Superior Court sustained State Farm’s demurrer, concluding that the one-year limitations period in the insurance policy applied to all of Rosenberg-Wohl’s claims, including her UCL claim. The court reasoned that her claims were essentially “on the policy” because they were grounded in the denial of her insurance claim. The Court of Appeal affirmed this decision, with a majority agreeing that the one-year limitations period applied, while a dissenting justice argued that the UCL’s four-year limitations period should govern.The Supreme Court of California reviewed the case and concluded that the one-year limitations period in section 2071 of the Insurance Code and the insurance policy did not apply to Rosenberg-Wohl’s UCL cause of action. The court determined that her lawsuit was not a “suit or action on [the] policy for the recovery of any claim” because she sought only declaratory and injunctive relief, not a financial recovery under the policy. The court emphasized that the UCL’s four-year statute of limitations governed her claim. Consequently, the Supreme Court reversed the judgment of the Court of Appeal and remanded the matter for further proceedings consistent with its opinion. View "Rosenberg-Wohl v. State Farm Fire & Casualty Co." on Justia Law

The Supreme Court of California, in a case involving a dispute over California's lemon law, ruled in favor of the plaintiff, Lisa Niedermeier. Niedermeier had purchased a new Jeep Wrangler from FCA US LLC, which was defective. Despite numerous attempts to repair the vehicle, the issues persisted. Niedermeier requested FCA buy back the vehicle, but FCA declined. Eventually, she traded in the defective vehicle for a new one, receiving a trade-in credit.Niedermeier later sued FCA for breach of warranty under the Song-Beverly Consumer Warranty Act. A jury found in her favor and awarded her a significant sum. FCA appealed, arguing the award should be reduced by the trade-in amount. The Court of Appeal agreed with FCA, but the Supreme Court reversed this decision.The Supreme Court held that in an action under the Song-Beverly Act, neither a trade-in credit nor sale proceeds reduce the statutory restitution remedy. The court reasoned that the Act's plain language does not permit such a reduction. Additionally, the court found that this interpretation is supported by the legislative history and consumer-protective purpose of the Act. The court further noted that allowing such a reduction would incentivize manufacturers to delay compliance with the Act.The court concluded that the statutory restitution remedy should not be reduced by a trade-in credit or sale proceeds, at least in cases where a consumer is forced to trade in or sell a defective vehicle due to the manufacturer's failure to comply with the Act. Therefore, the court reversed the judgment of the Court of Appeal. View "Niedermeier v. FCA US LLC" on Justia Law

In this dispute over whether Plaintiff's claims premised on the packaging and video of Michael, an album of music billed as Michael Jackson's first posthumous release, were subject to the album marketers' motion to strike under California's anti-SLAPP statute the Supreme Court held that Plaintiff sufficiently demonstrated that some of her claims had sufficient merit.In her complaint against Sony Music Entertainment, Plaintiff asserted that Michael's marketers misled her and violated two California consumer protection laws, the unfair competition law, and the Consumers Legal Remedies Act, by misrepresenting a vocalist on certain tracks through the album's packaging and in a promotional video. The court of appeal granted Defendants' motion to strike under the anti-SLAPP statute, concluding that the First Amendment required classifying the disputed statements as noncommercial speech. The Supreme Court reversed, holding that Plaintiff's claims related to Michael's packaging and promotional video had sufficient merit. View "Serova v. Sony Music Entertainment" on Justia Law

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

In this case where Plaintiff selected the remedy of restitution under the Song-Beverly Consumer Warranty Act, Cal. Civ. Code 1790 et seq. after Mercedes-Benz USA LLC (Mercedes) was unable to repair defects in the vehicle Plaintiff leased from Mercedes the Supreme Court held that Mercedes was required to reimburse vehicle registration renewal and nonoperation fees Plaintiff paid if the fees were incurred as a result of Mercedes' breach of its duty to promptly provide a replacement vehicle or restitution.At issue was whether the Act required Mercedes to reimburse the vehicle registration renewal and nonoperation fees Plaintiff paid after the initial lease of his vehicle either as collateral charges or as incidental damages. The trial court excluded the vehicle registration renewal fees and the nonoperation fee from the restitution award. The court of appeals affirmed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the fees at issue were not recoverable as collateral charges because they were not auxiliary to and did not supplement the price paid for the vehicle; but (2) the fees were recoverable as incidental damages if they were incurred as a result of the manufacturer's breach of its duty to promptly provide a replacement vehicle or restitution under the Act. View "Kirzhner v. Mercedes-Benz USA, LLC" on Justia Law

The Supreme Court held that the unfair competition law (UCL), Cal. Bus. & Prof. Code 17200 et seq., is not limited to the geographic boundaries of Orange County and therefore does not preclude a district attorney from including allegations of violations occurring outside as well as within the borders of her or his county.The Orange County District Attorney brought this action against several pharmaceutical companies, alleging that Defendants had intentionally delayed the sale of a generic version of a popular pharmaceutical drug to maximize their profits. The District Attorney sought statewide monetary relief. Defendants moved to strike references to "California" in their complaint, arguing that the district attorney's authority to enforce California's consumer protection laws is limited to Orange County's borders. The trial court denied the motion to strike. The court of appeals directed the trial court to vacate its order and granted the motion to strike. The Supreme Court reversed, holding that the trial court did not err in denying the motion to strike because the UCL did not preclude the District Attorney from including allegations of violations occurring outside the borders of Orange County. View "Abbott Laboratories v. Superior Court of Orange County" on Justia Law

The Supreme Court decided in this case that when the government seeks civil penalties as well as an injunction or other equitable remedies under the unfair competition law (UCL), Cal. Bus. & Prof. Code 17200 et seq., or the false advertising law (FAL), Cal. Bus. & Prof. Code 17500 et seq., the causes of action are to be tried by the court rather than a jury.In the current writ proceeding in this case, the court of appeal concluded that the jury trial provision of the California Constitution should be interpreted to require a jury trial in any action brought under the UCL or FAL in which the government seeks civil penalties in addition to injunctive or other equitable relief. The Supreme Court disagreed, holding (1) the causes of action established by the UCL and FAL at issue in this case are equitable in nature and are properly tried by the court rather than by a jury; and (2) the United States Supreme Court decision in Tull v. United States, 481 U.S. 412 (1987), relied upon by the court of appeal below, does not govern this case. View "Nationwide Biweekly Administration, Inc. v. Superior Court of Alameda County" on Justia Law

In this putative class action brought on behalf of retail purchasers of an inflatable outdoor pool the Supreme Court reversed the judgment of the court of appeal upholding the ruling of the trial court denying the representative plaintiff's motion for class certification, holding that the trial court erred in determining that the class proposed by the plaintiff was not ascertainable.The claims in this case arose out of the plaintiff's purchase out of an inflatable pool sold in packaging that allegedly misled buyers about the pool's size. The trial court denied the plaintiff's motion for class certification in its entirety on ascertainability grounds. The court of appeal found no abuse of discretion in the denial of class certification. The Supreme Court reversed, holding that the trial court erred in demanding that the plaintiff offer evidence showing how class members might be individually identified when that identification became necessary. Specifically, the Court held (1) an ascertainable class is one defined in objective terms that make the eventual identification of class members possible; and (2) the trial court abused its discretion when it found no ascertainable class existed. View "Noel v. Thrifty Payless, Inc." on Justia Law