Justia California Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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This case involved serious allegations against Robert E. Stark, the auditor-controller of Sutter County where the Sutter County District Attorney's Office claimed that Stark violated statutes, county rules, and Sutter County Board of Supervisors (Board) resolutions detailing the requirements of his office. At issue were four provisions of Penal Code section 424, all of which proscribe general intent offenses. Three of those provisions criminalize acting without authority or failing to act as required by law or legal duty. The court held that those offenses additionally required that defendant knew, or was criminally negligent in failing to know, the legal requirements that governed the act or omission. The court also held that a claim of misinstruction on the mens rea of a crime could be challenged under Penal Code section 995, subdivision (a)(1)(B) where it raised the possibility that, as instructed, the grand jury could have indicted on less than reasonable or probable cause. The court further held that based on the record, the court need not decide the question of whether willful misconduct under Government Code section 3060 required a knowing and purposeful refusal to follow the law. Stark did not disagree with the instruction on mental state given by the district attorney and accompanying PowerPoint slides invalidated the instruction on mental state, requiring that the accusation be set aside. The court addressed these claims as to the district attorney's argument and PowerPoint slides and concluded that it was without merit. The court finally held that, in a motion to set aside an indictment or accusation, a defendant claiming that the district attorney suffered from a conflict of interest during the grand jury proceeding must establish that his right to due process was violated. Accordingly, the judgment of the district court was affirmed. View "Stark v. Superior Court of Sutter County" on Justia Law

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Plaintiff, a resident of Los Angeles, filed a class action lawsuit on behalf of himself and similarly situated individuals challenging the city's telephone users tax (TUT) and seeking refund of funds collected under the TUT over the previous two years. At issue was whether the Government Code section 910 allowed taxpayers to file a class action claim against a municipal government entity for the refund of local taxes. The court held that neither Woosley v. State of California, which concerned the interpretation of statutes other than section 910, nor article XIII, section 32 of the California Constitution, applied to the court's determination of whether section 910 permitted class claims that sought the refund of local taxes. Therefore, the court held that the reasoning in City of San Jose v. Superior Court, which permitted a class claim against a municipal government in the context of an action for nuisance under section 910, also permitted taxpayers to file a class claim seeking the refund of local taxes under the same statute. Accordingly, the court reversed and remanded the judgment of the Court of Appeals. View "Ardon v. City of Los Angeles" on Justia Law

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Plaintiff filed a complaint against the City seeking to enjoin enforcement of the Grocery Worker Retention Ordinance, L.A. Ord. No. 177, 231, adding ch. XVIII, 181.00 et seq. to L.A. Mun. Code. The ordinance vested current grocery store employees with certain individual rights during a 90-day transition period. At issue was whether the worker retention ordinance was preempted as intruding upon either matters of health and safety already regulated by the state or matters of employee organization and collective bargaining fully occupied by federal law. The court held that the challenged ordinance was fully consistent with both the state and federal equal protection clauses and reversed the court of appeal's judgment. View "California Grocers Assoc. v. City of Los Angeles" on Justia Law

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This case stemmed from the City of Manhattan Beach's adoption of an ordinance banning the use of "point-of-sale plastic carry-out bags" in the city. Plaintiff, a coalition of plastic bag manufacturers and distributors, claimed standing to maintain a citizen suit to vindicate the public interest in environmental quality. At issue was what were the standing requirements for a corporate entity to challenge a determination on the preparation of an environmental impact report (EIR) and whether the city was required to prepare an EIR on the effects of the ordinance. The court held that plaintiff would qualify for public interest standing here and disapproved Waste Management of Alameda County, Inc. v. County of Alameda's holding that corporations were subject to heightened scrutiny when they filed citizen suits. The court also held that plaintiff, which represented businesses directly affected by the ordinance, had standing in its own right to challenge the city's analysis of environmental impacts. On the merits, the court held that substantial evidence and common sense support the city's determination that its ordinance would have no significant environmental effect. Therefore, a negative declaration was sufficient to comply with the requirements of the California Environmental Quality Act (CEQA), Pub. Resources Code, section 21000 et seq. Accordingly, the judgment was reversed. View "Save the Plastic Bag Coalition v. City of Manhattan Beach" on Justia Law

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The Los Angeles Diocese and certain individuals sued persons connected with St. James Parish claiming that the national church owned certain church property in dispute. At issue was whether the court's decision in Episcopal Church Cases, supra, was merely affirming th previous judgment of the Court of Appeals or resolved the dispute on the merits. The court held that that it merely affirmed the previous judgment and therefore, remanded the matter for further proceedings without deciding the case on the merits.