Justia California Supreme Court Opinion Summaries

The Supreme Court of California reviewed a case involving the University of California, Berkeley's (UC Berkeley) plan to build a housing project on a site called People's Park. The plaintiffs, Make UC a Good Neighbor and People’s Park Historic District Advocacy Group, challenged the certification of an environmental impact report (EIR) for the project, arguing that it failed to consider the environmental impacts of "student-generated noise" and did not adequately consider alternatives to the People’s Park location. The Court of Appeal agreed with the plaintiffs.The Supreme Court of California granted review of the Court of Appeal’s decision. During the review, the Legislature passed Assembly Bill No. 1307, which added sections to the Public Resources Code stating that noise generated by project occupants and their guests is not a significant environmental effect for residential projects, and that public higher education institutions are not required to consider alternatives to the location of a proposed residential or mixed-use housing project if certain requirements are met. The plaintiffs conceded that this new law applied to the case and made clear that the EIR was not required to examine "social noise" or potential alternative locations to People’s Park.The Supreme Court of California concluded that none of the plaintiffs' claims had merit in light of the new law. The court held that the new law applied to both the People’s Park housing project and the development plan, and the EIR was not inadequate for having failed to study the potential noisiness of future students at UC Berkeley in connection with this project. The court declined to consider the plaintiffs' alternative locations argument with respect to potential future housing projects. The court reversed the Court of Appeal’s judgment. View "Make UC a Good Neighbor v. The Regents of the University of California" on Justia Law

The Supreme Court held that, in disciplinary proceedings, private universities are not required to provide accused students the opportunity to directly or indirectly cross-examine the accuser and other witnesses at a live hearing with the accused student in attendance, either in person or virtually.The University of Southern California and its vice president of student affairs (collectively, USC) expelled Appellant after conducting an investigation and determining that Appellant violated USC's policy against engaging in intimate partner violence. Appellant filed a petition for a writ of administrative mandate, arguing that he was deprived of a fair trial under Cal. Code Civ. Proc. 1094.5. The court of appeals agreed, determining that USC's disciplinary procedures were unfair because they denied Appellant a meaningful opportunity to cross-examine critical witnesses at an in-person hearing. The Supreme Court reversed, holding that requiring private universities to conduct the hearing envisioned by the court of appeals was contrary to fair procedure caselaw. View "Boermeester v. Carry" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court affirming the findings of the Commission on State Mandates rejecting the claims brought by Plaintiffs, several community college districts seeking reimbursement for regulations they must satisfy to avoid the possibility of having their state aid withheld, holding that the court of appeals erred.Plaintiffs filed a claim arguing that reimbursement was required under Cal. Const. art. XIII B because (1) the regulations imposed a legal duty to satisfy the conditions described (legal compulsion), or (2) the regulations compelled compliance as a practical matter (practical compulsion). The Commission rejected the claims, and the trial court affirmed. The court of appeals reversed. The Supreme Court reversed, holding that because the court of appeal chose not to address whether the districts established practical compulsion, remand was required to allow the court to evaluate that issue. View "Coast Community College District v. Commission on State Mandates" on Justia Law

The Supreme Court held that liability under the Unruh Civil Rights Act, Cal. Civ. Code 51, was not available in this case, where Plaintiff alleged that he was sexually assaulted by fellow students and a school district staff member at his high school.Plaintiff, through his guardian, sued the West Contra Costa Unified School District asserting various claims arising out of his high school experiences, including allegations that the District had violated the Act. The District demurred to the Act cause of action on the ground that the District was not a "business establishment" within the meaning of the Act. The trial court sustained the demurrer. Thereafter, Plaintiff filed an original petition for writ of mandate, which the court of appeal denied. The Supreme Court affirmed, holding that the Act, as currently written, cannot reasonably be interpreted to encompass public school districts in situations such as the one this case presented. View "Brennon B. v. Superior Court" on Justia Law

The Supreme Court held that the juvenile court may exercise jurisdiction in a formal wardship proceeding on the basis of the minor having four or more truancies within one school year under Cal. Welf & Inst. Code 601(b) if a fourth truancy report has been issued to the appropriate school official, even if the minor has not been previously referred to a school attendance review board (SARB) or a similar truancy mediation program.The district court filed a wardship petition against A.N., a high school student, in the juvenile court, alleging that A.N. was a habitual truant and that she was within the jurisdiction of the juvenile court. After a hearing, the juvenile court sustained the wardship petition. A.N. appealed, arguing that the juvenile court lacked jurisdiction because, at the time the petition was filed, she had not yet appeared before a SARB and because she and her parents had not received a fourth truancy report. The court of appeals affirmed. The Supreme Court affirmed, holding that because A.N.’s school had sent at least four truancy reports to the superintendent of the school district before the wardship petition was filed, the juvenile court possessed jurisdiction over A.N. View "In re A.N." on Justia Law

In deciding whether the Legislature's enactment of two statutes requiring a portion of state funding provided annually to local education agencies to be used prospectively as "offsetting revenues" under Cal. Gov't Code 17557(d)(2)(B) was constitutional the Supreme Court held that the method chosen by the Legislature to pay for two existing state reimbursement mandates did not on its face violate the state Constitution.In 2010, during a period of economic recession, the Legislature enacted the two statutes at issue in this case to satisfy the two mandates. The statutes designated previously non-mandate education funding as restricted funding at the beginning of the next fiscal year to satisfy the state's obligation to reimburse school districts for the two mandates. Petitioner filed a petition for writ of mandate and complaint for injunctive and declaratory relief alleging that the two statutes violate the Constitution. The superior court denied the petition, and the court of appeal affirmed. The Supreme Court affirmed, holding that mandate reimbursement as provided by the statutes does not violate the Constitution. View "California School Boards Ass'n v. State" on Justia Law

Universities have a special relationship with their students and a duty to protect them from foreseeable violence during curricular activities.Damon Thompson, a student at the University of California at Los Angeles (UCLA), stabbed fellow student Katherine Rosen during a chemistry lab. Thompson was experiencing auditory hallucinations, and school administrators had attempted to provide him with mental health treatment. Rosen sued UCLA and several of its employees (collectively, UCLA), alleging negligence for UCLA’s failure to protect her from Thompson’s foreseeable violent conduct. UCLA moved for summary judgment, arguing that colleges have no duty to protect their adult students from criminal acts. The trial court denied the motion. The Court of Appeal granted UCLA’s petition for writ of mandate, ruling that UCLA owed no duty to protect Rosen. The Supreme Court reversed, holding that universities owe a duty to protect students from foreseeable violence during curricular activities. View "Regents of University of California v. Superior Court of Los Angeles County" on Justia Law

In 2000, California voters enacted Proposition 39, which provides that school districts must share their facilities with charter schools so that charter school students have access to facilities “reasonably equivalent” to facilities available to other public school students. Two years later, the State Board of Education issued regulations on how to implement this requirement. This action concerned the meaning of a Board regulation that governs the allocation of classrooms to charter schools. In allocating classrooms to charter schools, the Los Angeles Unified School District used “norming ratios,” which purported to establish throughout the District a uniform student/teacher ratio in a given grade level. The California Charter Schools Association (CCSA) sought declaratory relief, contending that the District violated the regulation governing the allocation of classrooms to charter schools by, inter alia, using these norming ratios rather than counting classrooms in comparison group schools to determine the allocation of classroom facilities. The Supreme Court agreed with CCSA and held that the District’s use of norming ratios, rather than counting classrooms in comparison group schools, violated the applicable regulation. In responding to future facilities requests, the District must count classrooms in a manner that conforms to the regulation. View "Cal. Charter Schs. Ass’n v. L.A. Unified Sch. Dist." on Justia Law

Public school students with diabetes who cannot self-administer insulin are entitled under federal law to have it administered to them during the school day at no cost. In 2007, the State Department of Education (Department) issued a legal advisory authorizing unlicensed school personnel to administer insulin. The American Nurses Association and other trade organizations representing registered and school nurses (collectively, Nurses) challenged the document by filing this action seeking declaratory relief and a writ of mandate, asserting that the Department's advice condoned the unauthorized practice of nursing. The superior court declared the advisory invalid to the extent it authorized unlicensed school personnel to administer insulin. The Supreme Court reversed, holding that California law expressly permits trained, unlicensed school personnel to administer prescription medications such as insulin in accordance with the written statements of a student's treating physician and parents and expressly exempts persons who thus carry out physicians' medical orders from laws prohibiting the unauthorized practice of nursing.View "Am. Nurses Ass'n v. Torlakson" on Justia Law

Michael Garcia received special education services during his school years. Before Garcia turned sixteen, he was arrested on felony charges and transferred to the Los Angeles County Jail to await trial. At that point, Garcia stopped receiving special education services. The issue of whether Garcia was entitled to special education services in the county jail was raised in several proceedings, including an action before the Office of Administrative Hearings, Special Education Division (OAH). The OAH concluded that Cal. Educ. Code 56041 applied, and because Garcia's mother resided within the boundaries of the Los Angeles Unified School District (L.A. Unified), L.A. Unified was responsible for Garcia's special education while he was incarcerated in county jail. L.A. Unified sought relief from the OAH's decision with the federal district court, which affirmed. On appeal, the court of appeals asked the California Supreme Court to decide a question of state law. The Supreme Court answered that Cal. Educ. Code 56041 - which provides generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for special education services - affixes responsibility for providing special education to a qualifying individual who is incarcerated in a county jail. View "Los Angeles Unified Sch. Dist. v. Garcia" on Justia Law