Justia California Supreme Court Opinion Summaries

After Plaintiff was injured, he sought benefits from Defendant-insurer under an indemnity benefit policy. Plaintiff subsequently filed suit alleging that Defendant breached the insurance contract and the implied covenant of good faith and fair dealing. The jury awarded Plaintiff $31,500 in unpaid policy benefits, $35,000 in damages for emotional distress, and $19 million in punitive damages. The parties stipulated that the amount of attorney fees to which Plaintiff was entitled under Brandt v. Superior Court was $12,500, and the court awarded that amount. Defendant moved for a new trial seeking a reduction in the punitive damages award on the grounds that it was unconstitutionally excessive. The trial court granted the motion and reduced the jury’s award to a 10-to-1 ratio of punitive to compensatory damages. In so doing, the court considered only the $35,000 damages award but did not include the $12,500 in Brandt fees. The court of appeal affirmed. The Supreme Court reversed, holding that, in determining whether a punitive damages award is unconstitutionally excessive, Brandt fees may be included in the calculation of the ratio of punitive to compensatory damages, regardless of whether the fees are awarded by the trier of fact as part of its verdict or are determined after the verdict has been rendered. Remanded. View "Nickerson v. Stonebridge Life Ins. Co." on Justia Law

As a condition of her employment with Defendants, Plaintiff signed an agreement to resolve any employment-related disputes through arbitration. After Plaintiff resigned, she filed a complaint against Defendants, alleging that she suffered harassment, discrimination, and retaliation during the course of her employment. Defendants filed a motion to compel arbitration. Plaintiff opposed the motion, asserting that it was unconscionable. The trial court agreed with Plaintiff and denied the motion to compel arbitration. The court of appeal reversed. The primary issue before the Supreme Court was whether the arbitration agreement was unconscionable because of a clause in the agreement providing that, in the event a claim proceeds to arbitration, the parties are authorized to seek preliminary injunctive relief in the superior court. The Supreme Court affirmed, holding that the arbitration agreement was not unconscionable because the clause did no more that restate existing law. View "Baltazar v. Forever 21, Inc." on Justia Law

As a condition of her employment with Defendants, Plaintiff signed an agreement to resolve any employment-related disputes through arbitration. After Plaintiff resigned, she filed a complaint against Defendants, alleging that she suffered harassment, discrimination, and retaliation during the course of her employment. Defendants filed a motion to compel arbitration. Plaintiff opposed the motion, asserting that it was unconscionable. The trial court agreed with Plaintiff and denied the motion to compel arbitration. The court of appeal reversed. The primary issue before the Supreme Court was whether the arbitration agreement was unconscionable because of a clause in the agreement providing that, in the event a claim proceeds to arbitration, the parties are authorized to seek preliminary injunctive relief in the superior court. The Supreme Court affirmed, holding that the arbitration agreement was not unconscionable because the clause did no more that restate existing law. View "Baltazar v. Forever 21, Inc." on Justia Law

This case arose from Plaintiff’s sale of property to Defendants. In November 2006, Plaintiff filed a complaint against Defendants alleging negligence, fraud, intentional infliction of emotional distress, and failure to follow home equity sales contract requirements. In May 2012, Fidelity National Title Insurance Company moved to dismiss the complaint for failure to bring the action to trial within the five-year time frame required by Cal. Code Civ. Proc. 583.310. The trial court dismissed the case in its entirety. In so doing, the trial court concluded that the time during which the court had vacated the trial date and ordered a 120-day stay of proceedings to permit the parties to engage in mediation did not support tolling. The court of appeal affirmed. The Supreme Court affirmed, holding that the trial court’s order did not effect a complete stay of the prosecute of the action, nor did it create a circumstance of impracticability, and therefore, the period of the “mediation stay” did not toll the five-year period. View "Gaines v. Fidelity Nat’l Title Ins. Co." on Justia Law

Client advanced Attorney funds to cover attorney’s fees in litigation. After Client terminated the representation, Attorney refused to return the unearned attorney’s fees. Attorney demurred on the ground that the lawsuit was barred by Cal. Civ. Proc. Code 340.6(a), which sets forth a one-year limitations period for actions against an attorney for a “wrongful act or omission” arising in the performance of “professional services.” The trial court sustained the demurrer, concluding that section 340.6(a) applied to Client’s claims and that she filed her complaint more than one year after Attorney informed her that he would not return her money. The Court of Appeals reversed the trial court’s order sustaining Attorney’s demurrer. The Supreme Court affirmed, holding (1) section 340.6(a) applies to a claim when the merits of the claim will necessarily depend on proof that an attorney violated a professional obligation in the course of providing professional services; and (2) in this case, Client’s complaint could be construed to allege a claim for conversion whose ultimate proof at trial may not depend on the assertion that Attorney violated a professional obligation. View "Lee v. Hanley" on Justia Law

Plaintiff sued Defendants for breach of contract and related claims. Defendants failed to file a responsive pleading, and the clerk entered Defendants’ default. The court then entered a default judgment. Defendants filed an application for relief from default under Cal. Civ. Proc. Code 473(b) based on their attorney’s “sworn affidavit attesting to his or her mistake, inadvertence, surprise, or neglect.” The superior court denied the motion. Thereafter, Defendants filed a renewed application for relief from default. Accompaying both applications were affidavits submitted by Defendants’ attorney explaining his reasons for the default. Although Defendants had not satisfied the requirements of Cal. Civ. Proc. Code 1008, the superior court granted their renewed application for relief from default, concluding that section Cal. Code Civ. P. 473(b) takes precedence over section 1008, and relief under section 473(b) based on an attorney’s affidavit of fault is mandatory where no part of the fault is shown to be attributable to the attorney’s clients. The court of appeal reversed, concluding that Defendants’ failure to comply with section 1008 required the trial court to reject their renewed application for relief from default. The Supreme Court affirmed, holding (1) section 1008 governs renewed applications under section 473(b) for relief from default; and (2) Defendants’ renewed application did not satisfy section 1008. View "Even Zohar Constr. & Remodeling v. Bellaire Townhouses" on Justia Law

Roy Caputo, Wade Faerber, and Matthew Neel leased commercial space from DKN Holdings LLC and were each jointly and severally liable on this contract. Caputo later sued DKN for, inter alia, breach of contract. DKN cross-complained for monies due. The court rejected Caputo’s claims and awarded $2.8 million in DKN’s cross-complaint. Before the statement of decision in the Caputo action was filed, DKN sued Faerber and Neel for breach of the lease. Faerber demurred, arguing that suit against him was barred by the rule against splitting a cause of action because DKN’s rights under the lease had been adjudicated in the Caputo action. The trial court sustained the demurrer and entered judgment for Faerber. The Court of Appeal affirmed, concluding that a second suit is barred after entry of judgment against one of the contracting parties. The Supreme Court reversed, holding (1) joint and several liability does not implicate the “primary rights” doctrine wherein a cause of action arises from the invasion of a primary right and gives rise to only one cause of action; (2) the facts of this case do not support preclusion; and (3) Plaintiff has separate breach of contract claims against each defendant alleged to be jointly and severally liable. View "DKN Holdings LLC v. Faerber" on Justia Law

Plaintiff entered into a plea agreement under which he pled nolo contendere to one count of lewd and lascivious acts upon a child. Plaintiff filed a plea form stating that Plaintiff must register as a sex offender under Cal. Penal Code 290. Plaintiff registered as required by section 290. The Legislature later amended the law and provided a means by which the public can obtain personal information of the State's registered sex offenders. The legislature made the public notification provisions retroactive and thus applicable to Plaintiff's conviction. Plaintiff filed a civil complaint, contending that requiring him to comply with the amended law's public notification provisions would violate his plea agreement. The district court concluded that publicly disclosing any of Plaintiff's previously confidential sex offender registration information would violate the terms of Plaintiff's plea agreement. On appeal, the Ninth Circuit Court of Appeals asked a question of the California Supreme Court, which responded by answering that under California law of contract interpretation as applicable to the interpretation of plea agreements, the fact that parties enter into a plea agreement does not have the effect of insulating them from changes in the law that the legislature intended to apply to them. View "Doe v. Harris" 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