Justia California Supreme Court Opinion Summaries

Defendant was convicted of petty theft with a prior-theft related conviction. Before Defendant was released from prison, the Board of Parole Hearings found that Defendant met the criteria for commitment as a Mentally Disordered Offender (MDO) under Cal. Penal Code 2969(d)(1) and (e)(2)(Q). Defendant petitioned for a hearing to challenge the Board’s determination. The court eventually concluded that Defendant met all the necessary MDO Act criteria specified in section 2962. The Court of Appeal affirmed. The Supreme Court reversed, holding (1) a mental health expert’s opinion testimony in support of a defendant’s commitment under the MDO Act may not be used to prove the defendant committed a qualifying offense for commitment involving one of the offenses specified in section 2962(e)(2)(A) through (O) or involved behavior described in subdivision (e)(2)(P) or (Q); (2) mental health experts may not testify about a topic that is not sufficiently beyond common experience; and (3) the prosecution failed to present evidence other than its mental health expert’s opinion testimony and supporting foundational facts, and that expert improperly opined on a topic that is not beyond common experience, and therefore, substantial evidence did not support the trial court’s finding on the MDO commitment. Remanded. View "People v. Stevens" on Justia Law

At issue in this case was the adequacy of an environment impact report certified by the California Department of Fish and Wildlife (DFW) for a land development in northwest Los Angeles County. Plaintiffs challenged DFW’s actions by a petition for writ of mandate, raising several claims under the California Environmental Quality Act. The superior court granted the petition. The Court of Appeal reversed. The Supreme Court reversed, holding (1) the environmental impact report did not validly determine that the development would not significantly impact the environment by its discharge of greenhouse gases; (2) the report’s mitigation measures adopted for protection of a freshwater fish, a fully protected species under the Fish and Game Code, constituted a prohibited taking of the fish under the Code; and (3) Plaintiffs exhausted their administrative remedies regarding certain claims of deficiency. Remanded. View "Ctr. for Biological Diversity v. Cal. Dep’t of Fish & Wildlife" on Justia Law

A private citizen called a 911 operator to report an incident of suspected child abuse during the child’s visit with his father. A deputy sheriff, who was dispatched to investigate the report, determined that the child was not a victim of child abuse. Neither the officer nor the Sheriff’s Department cross-reported the initial 911 report to the child welfare agency. Less than four weeks later, the child suffered extensive head injuries during a visit with his father. The child, through a guardian ad litem, sued the county and the deputy sheriff for failing to cross-report the initial child abuse allegations to the county child welfare agency, in violation of the Child Abuse and Neglect Reporting Act. The trial court granted summary judgment for Defendants. The Court of Appeal affirmed. The Supreme Court reversed in part and affirmed in part, holding (1) the Sheriff’s Department had a mandatory and ministerial duty to cross-report the child abuse allegations made to the 911 operator to the child welfare agency, and the failure to cross-report can support a finding of breach of a mandatory duty; but (2) the officer had no duty to report the child abuse allegations and her investigative findings to the child welfare agency. View "B.H. v. County of San Bernardino" on Justia Law

At issue in this case was whether Cal. Labor Code 4458.2, which provides workers’ compensation benefits to certain peace officers injured in the line of duty, applies to both volunteer peace officers and to regularly sworn, salaried officers. While employed as a police officer by the City of Marysville, John Larkin sustained injuries in the course of duty. A workers’ compensation judge determined that Larkin was entitled to workers’ compensation benefits but not to the maximum indemnity levels available under section 4458.2 because section 4458.2 did not apply to regularly sworn, salaried officers like Larkin. The Workers’ Compensation Appeals Board denied Larkin’s petition for reconsideration. The Court of Appeal affirmed. The Supreme Court affirmed, holding that a review of the legislative history governing the relevant statutory provisions of section 4458.2 leads to the conclusion that the statute does not extend maximum disability indemnity levels to regularly sworn, salaried peace officers. View "Larkin v. Workers’ Comp. Appeals Bd." on Justia Law

In 2008, Brandon Clark fell ten feet while working as a carpenter for Employer. Clark’s workers’ compensation doctor prescribed various drugs to treat Clark’s injuries, and Clark’s personal doctor prescribed additional drugs. In 2009, Clark died from the “combined toxic effects of the four sedating drugs detected in his blood with associated early pneumonia.” Clark’s family sought workers’ compensation death benefits, arguing that the medications Clark was prescribed for his work-related injuries caused his death. The workers’ compensation judge awarded death benefits to the family. The Court of appeal reversed, concluding that there was insufficient evidence that the drugs Clark was prescribed for his work injuries contributed to his death. The Supreme Court reversed, holding (1) the Court of Appeal wrongly applied a higher proximate cause standard to this wrongful death case than the Legislature intended; and (2) substantial evidence supported the WCJ’s finding that two drugs, prescribed by the workers’ compensation doctor for Clark’s industrial injury, contributed to his death. View "South Coast Framing v. Workers’ Comp. Appeals Bd." on Justia Law

The City of Berkeley approved a permit application to build a 6,478-square-foot house with an attached 3,394-square-foot garage. In approving the permit, the City relied on two class exemptions making the project exempt from the restrictions set forth in the California Environmental Quality Act (CEQA). The Court of Appeal invalidated the permit approval, concluding that the proposed project may have a significant environmental impact, and therefore, the exemptions the City invoked did not apply under the Guidelines for Implementation of CEQA section 15300.2(c). Section 15300.2(c) provides: “A categorical exemption shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances.” The Supreme Court reversed, holding (1) a proposed project’s potential significant effect on the environment is not alone sufficient to trigger the unusual circumstances exception; and (2) remand for application of the standards the Court announced today was necessary. View "Berkeley Hillside Preservation v. City of Berkeley" on Justia Law

Under the Freeway Service Patrol (FSP) Act, motorists receive emergency roadside assistance on California’s highways. The FSP program is administered by, among other agencies, the Department of the California Highway Patrol (CHP). Local agencies then contract with privately owned tow services, which provide trucks dedicated to the FSP program. One local agency contracted with California Coach Orange, Inc. for FSP tow services and also contracted with CHP for field supervision and program management. Joshua Guzman, a California Coach FSP tow truck driver, hit a car on an interstate highway, injuring Plaintiff. Plaintiff sued CHP, among other defendants, seeking recovery on the theory that CHP was Guzman’s “special employer.” The trial court denied CHP’s motion for summary judgment. The Court of Appeal reversed, ruling that CHP cannot be the special employer of an FSP tow truck driver as a matter of law. The Supreme Court reversed, holding (1) the Court of Appeal erred by ruling that FSP statutes categorically bar CHP from acting as a special employer; and (2) the language of the statutory scheme does not support a finding that CHP is the special employer of FSP tow truck drivers, but this conclusion does not eliminate the possibility that CHP might act as a special employer in particular circumstances. View "State ex rel. Dep’t of Cal. Highway Patrol v. Superior Court" on Justia Law

The Center for Investigative Reporting filed a Public Records Act request for copies of all citations issued by the Department of Public Health (DPH) to the long-term health care facilities the Center was investigating. The DPH disclosed heavily redacted copies of the citations it had issued to the facilities, asserting that Cal. Welf. & Inst. Code 5328 obligated it not to release confidential information obtained in the course of providing services to mentally ill and developmentally disabled individuals. The trial court determined that the Long-Term Care, Health, Safety, and Security Act's mandate that DPH citations be made public with minimal redaction trumped section 5328’s confidentiality provisions. The Court of Appeal vacated the judgment of the trial court and ordered DPH to disclose such information as the Court of Appeal deemed consistent with the common purpose of both statutes while permitting DPH to redact such information as the court deemed inconsistent with that common purpose. The Supreme Court reversed and remanded with instructions for the Court of Appeal to deny the petition, holding that DPH citations issued under the Act are public records and must be disclosed to the Center subject only to the specific redactions mandated by the Act. View "State Dep’t of Pub. Health v. Superior Court" on Justia Law

The Riverside County Sheriff’s Department fired Deputy Kristy Drinkwater for falsifying her payroll forms. On administrative appeal, Drinkwater sought discovery of redacted records from personnel investigations of eleven other Department employees who were disciplined, but not fired, for similar acts of misconduct. The administrative hearing officer granted the motion. The Department sought a writ of administrative mandate, arguing that only judicial officers could grant Pitchess motions, which are discovery motions for officer personnel records. The superior court agreed and granted mandate. The Court of Appeal reversed. The Supreme Court affirmed, holding that when hearing an administrative appeal from discipline imposed on a correction officer, an arbitrator may rule upon a Pitchess motion. View "Riverside County Sheriff's Dep’t v. Stiglitz" on Justia Law

Wal-Mart Stores, Inc. sought to expand its store in the City of Sonora. The City Council postponed its vote on the project while a voter-sponsored initiative was circulated, which proposed to adopt a plan for the contemplated expansion. The Council subsequently adopted the ordinance. The Tuoloumne Jobs & Small Business Alliance sought a writ of mandate based on four causes of action, the first of which asserted that the Council violated the California Environmental Quality Act (CEQA) by adopting the ordinance without first conducting a complete environmental review. The Court of Appeals granted the writ as to the first cause of action, concluding that when a land use ordinance is proposed in a voter initiative petition, full CEQA review is required if the city adopts the ordinance rather than submitting it to an election. The Supreme Court reversed, holding that CEQA review is not required before direct adoption of an initiative, just as it is not required before voters adopt an initiative at an election. View "Tuolumne Jobs & Small Bus. Alliance v. Superior Court" on Justia Law