Justia California Supreme Court Opinion Summaries

Before Gilton Pitre was paroled from state prison the State Department of Mental Health (DMH) assessed whether he should be civilly committed under the Sexually Violent Predators Act (SVPA). The DMH ultimately did not request a petition for commitment. Four days after Pitre was paroled, he raped and murdered Plaintiff’s fifteen-year-old sister. Plaintiff sued DMH and two of its acting directors (collectively, Defendants) claiming that her sister’s death was caused by Defendants’ failure to discharge a mandatory duty imposed by the SVPA. Defendants demurred, arguing that Plaintiff failed to state a cause of action and that they were immune from liability. The demurrer was overruled, and Defendants petitioned for a writ of mandate. The Court of Appeal directed the superior court to sustain the demurrer, concluding that the SVPA imposed a mandatory duty on Defendants but that Plaintiff could not establish that the breach of that duty was the proximate cause of her sister’s death. The Supreme Court affirmed, holding that the Court of Appeal did not err in its conclusions. View "State Dep’t of State Hosps. v. Superior Court" 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

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

A male supervisor employed by a franchisee allegedly subjected a female subordinate to sexual harassment while working together at the franchisee’s pizza store. Plaintiff, the victim, sued the franchisor, the franchisee, and the harasser, arguing that the franchisor could be held vicariously liable for the harasser’s misconduct. The trial court granted summary judgment in favor of the franchisor, concluding that the requisite employment and agency relationship did not exist between the franchisor and franchisee in this case. The court of appeals reversed. The Supreme Court reversed and granted summary judgment in the franchisor’s favor, holding that, under the circumstances of this case, the franchisor did not stand in an employment or agency relationship with the franchisee and its employees for purposes of holding it vicariously liable for workplace injuries allegedly inflicted by the victim's supervisor. View "Patterson v. Domino’’s Pizza, LLC " on Justia Law

Plaintiff filed suit against defendants for negligence and premises liability, as well as battery. At issue was whether patients suffering from Alzheimer's disease are liable for injuries they inflict on health care workers hired to care for them at home. California and other jurisdictions have established the rule that Alzheimer's patients are not liable for injuries to caregivers in institutional settings. The court concluded that the same rule applies to in-home caregivers who, like their institutional counterparts, are employed specifically to assist these disabled persons; it is a settled principle that those hired to manage a hazardous condition may not sue their clients for injuries caused by the very risks they were retained to confront; the court's opinion is consistent with the strong public policy against confining the disabled in institutions; and the court encouraged the Legislature to focus its attention on the problems associated with Alzheimer's caregiving. View "Gregory v. Cott" on Justia Law

Defendants, two architectural firms, were the sole entities that provided architectural services for a collection of condominium units in San Francisco. The homeowners association sued several parties involving in the construction of the condominiums, including Defendants, alleging that negligent architectural design work performed by Defendants resulted in several defects. The trial court sustained a demurrer in favor of Defendants, determining that because the final decision regarding how the homes would be built rested with the owner, Defendants owed no duty to the future condominium owners. The court of appeal reversed, concluding that, under both the common law and the Right to Repair Act, Defendants owed a duty of care to the homeowners in this case. The Supreme Court affirmed, holding (1) an architect owes a duty of care to future homeowners in the design of a residential building where the architect is a principal architect on the project, and the duty of care extends to such architects even when they do not actually build the project or exercise ultimate control over construction; and (2) the complaint int his case sufficiently alleged the causal link between Defendants’ negligence and the condominium association’s injury. View "Beacon Residential Cmty. Ass’n. v. Skidmore, Owings & Merrill" on Justia Law

Mary Ann Verdugo died after suffering a sudden cardiac arrest while shopping at a Target department store. Target did not have an automated external defibrillator (AED) in its store. Plaintiffs, Verdugo’s mother and brother, filed suit against Target Corporation, alleging that Target breached its duty of care to Verdugo by failing to have within its store an AED for use in a medical emergency. A federal district court dismissed the complaint for failure to state a cause of action, concluding that Target had no duty to have in its stores an AED for the use of its customers. When the matter came before the court of appeals, the court asked the California Supreme Court for guidance on the question of California tort law presented by this case. The Supreme Court answered that, under California law, Target’s common law duty of care to its patrons does not include an obligation to acquire and make available an AED for the use of its customers in a medical emergency. View "Verdugo v. Target Corp." on Justia Law

Hartford Casualty Insurance Company issued a commercial general liability policy to Ultimate Support Systems, a company that sold the Ulti-Cart. The policy covered “personal and advertising injury,” which included claims arising out of publication of material that "disparages a person’s or organization’s goods, products or services.” Gary-Michael Dahl, the manufacturer of the Multi-Cart, sued Ultimate for patent and trademark infringement, false designation of origin, and damage to business, reputation, and goodwill. Hartford denied coverage on the ground that the suit did not allege that Ultimate had disparaged the Multi-Cart or Dahl. The Supreme Court affirmed, holding (1) a claim of disparagement requires a plaintiff to show a false or misleading statement that specifically refers to the plaintiff’s product or business and clearly derogates that product or business; and (2) because Dahl’s suit did not allege that Ultimate clearly derogated the Multi-Cart, there was no claim of disparagement triggering Harford’s duty to defend. View "Hartford Cas. Ins. v. Swift Distrib., Inc." on Justia Law

Defendant hosted a party at a residence owned by her parents without their consent. Alcohol was available for consumption at the party. Some of the guests, most of whom were under twenty-one, were charged an admission fee. The money collected in entrance fees was used to buy additional alcohol. During the party, an intoxicated guest who was charged a fee to enter, consumed alcohol beverages supplied by Defendant and subsequently, while intoxicated, killed someone in an automobile accident. Plaintiffs, the victim’s parents, filed a wrongful death action against Defendant and her parents. Defendants filed a motion for summary judgment, claiming Plaintiffs could not show Defendants were liable under Cal Bus. & Prof. Code 25602.1, which permits liability for persons who serve alcohol to obviously intoxicated minors, and that they were entitled to civil immunity under Cal Bus. & Prof. Code 25602(b) and Cal. Civ. Code 1714(c). The trial court granted summary judgment for Defendants. The Supreme Court reversed, holding that there was a triable issue of fact whether Defendant sold alcoholic beverages, or caused them to be sold, within the meaning of section 25602.1, rendering Defendant potentially liable as a person who sold alcohol to an obviously intoxicated minor. Remanded. View "Ennabe v. Manosa" on Justia Law

Plaintiff filed an action against Defendant for breach of fiduciary duty and defamation, among other claims. Defendant cross-complained for defamation. Plaintiff later conceded he could not proceed on his cause of action for breach of fiduciary duty. The parties agreed to dismiss as well their respective defamation claims without prejudice and to waive operation of the statute of limitations on the defamation claims. The trial court ordered Plaintiff's action dismissed with prejudice with the exception of the defamation cause of action, which, together with Defendant's cross-complaint, the court dismissed without prejudice. The court then entered judgment in favor of Defendant. The court of appeal held the judgment final and appealable, reasoning that because the defamation counts had been dismissed, they were no longer pending between the parties and the trial court lacked jurisdiction to proceed further on any cause of action. The Supreme Court reversed, holding that, under Don Jose's Restaurant, Inc. v. Truck Ins. Exchange, the trial court's judgment was interlocutory, and therefore, not appealable. View "Kurwa v. Kislinger" on Justia Law