Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeal rejecting Appellant's challenge to the denial of his motion to disqualify A. Robert Singer as a hearing officer in a peer review proceeding, holding that the record did not establish that Singer should be disqualified for financial bias under Cal. Bus. & Prof. Code 809.2, subdivision (b).A medical executive committee adopted a recommendation to terminate Appellant's medical staff membership and hospital privileges. Appellant requested a peer review hearing to review the recommendation, and the hospital president exercised authority delegated by the medical staff to select Singer to serve as the hearing officer. Appellant challenged Singer's appointment on grounds of financial bias, but Singer denied the challenge. The peer review panel upheld the revocation of Appellant's staff membership and privileges. The superior court denied Appellant's petition for a writ of administrative mandate, and the court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances surrounding Singer's appointment did not create an intolerable risk of bias that would require disqualification under section 809.2(b). View "Natarajan v. Dignity Health" on Justia Law

The Supreme Court reversed the order of the court of appeals denying a petition for a writ of supersedeas to stay the effect of an order of the superior court requiring the San Bernardino County Board of Supervisors to remove and replace one of its members, holding that the order should be stayed until the appellate court has determined whether the trial court was correct.The superior court's order was based on the court's ruling that the Board had violated statutory open-meeting requirements in making an appointment to a vacant board seat. The order required the Board to rescind the appointment and to seat a replacement board member to be named by the Governor. The Board petitioned the court of appeal for a writ of supersedeas and requested an immediate stay. The court of appeal denied the stay. The Supreme Court reversed and remanded the case, holding that the order should have been automatically stayed as a mandatory injunction. View "Daly v. San Bernardino County Board of Supervisors" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that William Palmer was entitled to release from all forms of custody, including parole supervision, holding that to the extent Palmer's continued incarceration at some point became constitutionally excessive, that alone did not justify ending his parole under the current statutory scheme.Palmer first sought release on parole in 1995. The Board of Parole Hearings denied parole. Palmer continued to seek release. After the Board's tenth denial, Palmer filed a petition for writ of habeas corpus alleging that the thirty years he had served on a life sentence for an aggravated kidnapping committed when he was a juvenile was constitutionally excessive. The Board subsequently ordered Palmer released on parole. Ruling on Palmer's writ, the court of appeals concluded that Palmer's now-completed term of imprisonment had become unconstitutional and ended his parole. The Supreme Court reversed, holding that, in the absence of any persuasive argument from Palmer that his parole term had become constitutionally excessive, his parole remained valid. View "In re Palmer" on Justia Law

The Supreme Court granted the emergency petition filed by the Legislature for a peremptory writ of mandate seeking relief from redistricting deadlines set by California law in light of the delay of census data collection and processing, holding the Legislature was entitled to a one-time adjustment to the deadlines.Under California law, the Citizens Redistricting Commission has the task of redistricting and draws new maps based on the federal census data. As a result of the COVID-19 pandemic, the federal Census Bureau delayed census data collection and processing. Consequently, the data required to draw new district maps would not be released to states in time for the Commission to meet the redistricting deadlines. The Supreme Court issued a peremptory writ of mandate directing the Commission to release the first preliminary statewide maps for public display and comment no later than November 1, 2021, notwithstanding Cal. Gov't Code 8253, subdivision (a)(7), and directing the Commission to approve and certify the final statewide maps by no later than December 15, 2021. View "Legislature of State of California v. Padilla" on Justia Law

The Supreme Court held that equitable tolling can lessen the otherwise strict time limit on the availability of writs of administrative mandate under Cal. Gov't Code 11523.The State Department of Public Health (the Department) imposed a fine on Saint Francis Memorial Hospital when it learned that doctors left a surgical sponge in a patient during a surgery. The Department later denied Saint Francis's request for reconsideration. Eleven days after the Department denied reconsideration but forty-one days after being served with the Department's final decision Saint Francis filed a petition for a writ of administrative mandate.The Department demurred on the ground that the petition was untimely under section 11523. The superior court sustained the Department's demurrer, reasoning that Saint Francis's petition was time-barred and that Saint Francis's mistake about the availability of reconsideration was not a sufficient basis to excuse a late filing. The court of appeal affirmed. The Supreme Court vacated the court of appeal's judgment, holding (1) equitable tolling may apply to petitions filed under section 11523; and (2) because the court of appeal didn't address equitable tolling's third element, the case is remanded for further proceedings. View "Saint Francis Memorial Hospital v. State Department of Public Health" on Justia Law

The Supreme Court held that a definitive resolution of the question of whether an arbitral scheme resembling civil litigation can constitute a sufficiently accessible and affordable process was unnecessary in this case because the facts involved an unusually high degree of procedural unconscionability, rendering the arbitration agreement in this case unenforceable.During his employment Employee signed an arbitration clause grafted onto an acknowledgment of at-will employment. After his employment ended Employee filed a complaint with the Labor Commissioner for unpaid wages. Employer filed a petition to compel arbitration. The Labor Commissioner proceeded to the hearing without Employer and awarded Employee unpaid wages and liquidated damages. The trial court vacated the award, concluding that the hearing should not have proceeded in Employer's absence. The court, however, did not compel arbitration, finding that the agreement was both procedurally and substantively unconscionable. The court of appeal reversed. The Supreme Court reversed, holding (1) even if a litigation-like arbitration procedure may be an acceptable substitute for the Berman process, an employee may not be coerced or misled into accepting this trade; and (2) under the oppressive circumstances of this case, the agreement was unconscionable, rendering it unenforceable. View "OTO, L.L.C. v. Kho" on Justia Law

The Supreme Court held that when an agency considers increasing a property-related fee, the fee payor challenging the method of fee allocation need not exhaust administrative remedies by participating in a Proposition 218 hearing that addresses only a proposed rate increase.Cal. Const. art. XIII D, 6, which was added in 1996 by Proposition 218, requires that before a local governmental agency may impose or increase property-related fees and charges it must notify affected property owners and hold a public hearing. The representative plaintiffs in this class action sought to invalidate a wastewater service charge imposed by a water district, claiming that the district's method for calculating the charge violated one of the substantive requirements of Proposition 218. The trial court concluded that the suit was barred because the plaintiffs failed to exhaust administrative remedies by raising their challenge at public hearings on proposed increases to the rate charged for services. The court of appeal reversed. The Supreme Court affirmed, holding that a Proposition 218 rate hearing was not an administrative remedy that the plaintiffs were required to exhaust under these particular circumstances. View "Plantier v. Ramona Municipal Water District" on Justia Law

The Supreme Court affirmed the judgment of the Court of Appeal affirming the denial of Defendant’s special motion to strike, holding that the evidence produced by Plaintiff was properly considered by the trial court in ruling on a pretrial anti-SLAPP motion in determining Plaintiff’s probability of success.Plaintiff, Sweetwater Union High School District, sued to void contracts it approved with Defendants to manage certain projects after a criminal bribery investigation into the awarding of the contracts resulted in a number of guilty or no contest pleas. Plaintiff also sought to secure disgorgement of funds already paid. Defendants brought a special motion to strike under the Anti-SLAPP Statute, Cal. Code Civ. Proc. 425.16. Plaintiff’s response relied on evidence of the various guilty and no contest pleas. The court overruled Defendants’ evidentiary objects and denied their special motion to strike. The Court of Appeal affirmed. The Supreme Court affirmed, holding that, at the second stage of an anti-SLAPP hearing, the court may consider affidavits, declarations, and their equivalents if its reasonably possible the proffered evidence set out in those statements will be admissible at trial. View "Sweetwater Union High School District v. Gilbane Building Co." on Justia Law

At issue was what standards of review apply to the Public Employment Relations Board’s (PERB) legal interpretations and findings of fact when a final decision by PERB under the Meyers-Milias-Brown Act (MMBA), Cal. Gov’t Code 3500 et seq., is appealed.The Supreme Court held (1) PERB’s legal findings are entitled to deferential review, and PERB’s factual findings are “conclusive” “if supported by substantial evidence”; and (2) governing bodies or representatives properly designated are required to engage with unions on matters within the scope of representation prior to arriving at a determination of policy or course of action, even if that action is not a formal one taken by the governing body itself.Here, unions filed unfair practice claims after San Diego’s mayor sponsored a citizen’s initiative to eliminate pensions for new municipal employees and denied union demands to meet and confer over the measure. The Court of Appeal annulled PERB’s finding that the failure to meet and confer constituted an unfair labor practice. The Supreme Court reversed, holding (1) the MMBA applied to the mayor’s official pursuit of pension reform as a matter of policy; and (2) the Court of Appeals improperly reviewed PERB’s interpretation of the governing statutes de novo and took an unduly constricted view of the duty to meet and confer. View "Boling v. Public Employment Relations Board" on Justia Law

The California Table Grape Commission’s advertisements and related messaging represent government speech, as opposed to private speech, and the Ketchum Act’s (Cal. Food & Agric. Code 65500) scheme providing that the Commission’s activities are funded by assessments on shipments of California table grapes does not violate Plaintiffs’ rights under Cal. Const. art. I, 2.Plaintiffs, five growers and shippers of California table grapes, brought suit arguing that the collection of assessments under the Act to subsidize promotional speech on behalf of California table grapes as a generic category violates their right to free speech under Cal. Const. art. I, 2(a). Plaintiffs claimed specifically that the table grapes they grow and ship are exceptional and that the assessment scheme requires them to sponsor a viewpoint that they disagree with. The Supreme Court held that Plaintiffs failed to advance a viable claim under article I, section 2. Specifically, the Court held that there was sufficient government responsibility for and control over the messaging at issue for the communications to represent government speech that Plaintiffs can be required to subsidize without implicating their article I, section 2 rights. View "Delano Farms Co. v. California Table Grape Commission" on Justia Law