Justia California Supreme Court Opinion Summaries

Jayde Downey was on the phone with her daughter, Malyah Jane Vance, giving driving directions when Vance was severely injured in a car crash. Downey heard the collision and its immediate aftermath but could not see what caused it. She claims the crash was partly due to the condition of the roadway and sued the City of Riverside and the owners of adjacent private property for negligent infliction of emotional distress.The Riverside County Superior Court sustained the defendants' demurrers without leave to amend, agreeing that Downey could not claim emotional distress damages because she was not aware of the defendants' role in causing the crash at the time it occurred. The Court of Appeal affirmed, holding that Downey needed to show contemporaneous awareness of the causal connection between the defendants' negligence and her daughter's injuries.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that for purposes of emotional distress recovery, it is sufficient for a plaintiff to be aware of an event that is injuring the victim, not necessarily the defendant’s role in causing the injury. The court emphasized that the requirement is awareness of the injury-producing event, not the specific negligent conduct of the defendant. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings. View "Downey v. City of Riverside" on Justia Law

This case involves a dispute over the interpretation of the "learned intermediary doctrine" in a product liability case involving a medical device. The plaintiff, Michelle Himes, sued the defendant, Somatics, LLC, alleging that the company failed to provide adequate warning about the risks associated with electroconvulsive therapy (ECT), a treatment she underwent for severe depression. Himes claimed that she was only warned about the possibility of short-term memory loss, and not about the potential for permanent brain damage, severe permanent retrograde and anterograde amnesia, and acute and/or chronic organic brain syndrome, which she alleges she suffered as a result of the treatment.The district court granted summary judgment in favor of Somatics, finding that Himes failed to present evidence showing that a more detailed warning would have changed her physician's decision to administer ECT. The Ninth Circuit Court of Appeals agreed with the district court's finding but noted a genuine dispute of material fact as to whether the physician would have communicated a stronger warning to Himes.The Supreme Court of California was asked to clarify the causation standard under the learned intermediary doctrine. The court held that a plaintiff is not required to show that a stronger warning would have altered the physician’s decision to prescribe the product to establish causation. Instead, a plaintiff may establish causation by showing that the physician would have communicated the stronger warning to the patient and an objectively prudent person in the patient’s position would have thereafter declined the treatment. The court emphasized that the causation analysis must take into consideration whether the physician would still recommend the prescription drug or medical device for the patient, even in the face of a more adequate warning. View "Himes v. Somatics, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeal finding evidence of Plaintiff's subsequent molestation was admissible into evidence in a trial claiming emotional distress damages from the conduct of a teacher at the Mountain View School District, holding that remand was required for the trial court to undertake proper proceedings under Cal. Evid. Code 1106 and 783.Plaintiff sued the District seeking to recover for sexual abuse committed when she was eight years old by her fourth-grade teacher. The District sought to introduce evidence that Plaintiff was subsequently molested a few years later by another person and that this subsequent molestation caused at least some of Plaintiff's emotional distress injuries and related damages. The appellate court found the evidence regarding the subsequent molestation admissible. The Supreme Court reversed and remanded the case, holding (1) section 1106 subdivision (e) may permit admission of evidence that would otherwise be excluded under subdivision (a), but such admissibility is subject to the procedures set out in section 783 and scrutiny under section 352; and (2) section 352, as applied under the circumstances, required special informed review and scrutiny defined to protect Plaintiff's privacy rights, which appear not to have been applied in this case. View "Doe v. Superior Court" on Justia Law

The Supreme Court held that under California's Motor Carriers of Property Permit Act, Cal. Veh. Code 34600 et seq., a commercial automobile insurance policy does not continue in full force and effect until the insurer cancels a corresponding certificate of insurance on file with the Department of Motor Vehicles (DMV).Insured was driving a truck covered by his policy with Insurer when he collided with a car, killing its driver. The driver's parents sued Insured for wrongful death, and Insured tendered his defense to Insurer. Insurer settled the claim for its policy limits and then sued Insured's former insurer (Defendant) for declaratory relief, equitable contribution, and equitable subrogation. The trial court held that Defendant's policy remained in effect on the date of the collision because one of Defendant's cancellation notices was rejected by the DMV as incomplete. The Court of Appeals for the Ninth Circuit certified a question of law to the Supreme Court, which answered that the Act does not require a commercial auto insurance policy to remain in effective indefinitely until the insurer cancels the certificate of insurance on file with the DMV. View "Allied Premier Insurance v. United Financial Casualty Co." on Justia Law

The Supreme Court held that because Plaintiff's state-law claims were based on allegations that his father's health maintenance organization (HMO) plan and healthcare services administrator that managed his father's benefits (collectively, Defendants) breached state-law duties that incorporated and duplicated standards established under Medicare Part C, Part C's preemption provision preempted them.Plaintiff brought this action alleging a state statutory claim under the Elder Abuse Act and common law claims of negligence and wrongful death for the alleged maltreatment of his father, a Medicare Advantage (MA) enrollee who died after being discharged from a skilled nursing facility. Plaintiff alleged that the MA HMO and healthcare services administrator breached a duty to ensure his father received skilled nursing benefits to which he was entitled under his MA plan. Defendants demurred, arguing that the claims were preempted by Part C's preemption provision. The trial court sustained the demurrers, and the court of appeal affirmed. The Supreme Court affirmed, holding that because Plaintiff's state-law claims were based on allegations that Defendants breached state-law duties that incorporate and duplicate standards established under Part C, the claims were expressly preempted. View "Quishenberry v. UnitedHealthcare, Inc." on Justia Law

The Supreme Court held that the exclusivity provisions of the California Workers' Compensation Act (WCA), Cal. Lab. Code 3200 et seq., do not bar an employee's spouse's negligence claim against the employer when the spouse is injured by transmission of the COVID-19 virus but that an employer does not owe a duty of care under California law to prevent the spread of COVID-19 to employees' household members.The Supreme Court answered two questions of California law certified from the United States Court of Appeals for the Ninth Circuit regarding the scope of an employer's liability when an employee's spouse is injured by transmission of the COVID-19 virus as follows: (1) the exclusivity provisions of the WCA do not bar a non-employee's recovery for injuries that are not legally dependent upon an injury suffered by the employee; and (2) employers do not owe a tort-based duty to non-employees to prevent the spread of COVID-19. View "Kuciemba v. Victory Woodworks, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the trial court's judgment in favor of the County of Riverside in this action asserting negligent distress, holding that a provision of the Government Claims Act, Cal. Gov. Code 821.6, does not immunize public employees from claims based on certain injuries inflicted in the course of law enforcement investigations.Plaintiff's husband was shot and killed. When deputies with the Riverside County Sheriff office dragged his body in an attempt to revive him, the movement exposed his naked body. Plaintiff brought this action alleging that the officers and County failed to exercise reasonable care when they left her husband's body exposed for several hours in view of both Plaintiff and the general public. The trial court granted judgment for the County, concluding that Defendants were immune under section 821.6 for "all conduct related to the investigation and filing of charges." The court of appeal affirmed. The Supreme Court reversed, holding that the court of appeals erred in upholding the application of section 321.6 to confer absolute immunity on the County for negligent infliction of emotional distress arising out of the alleged mishandling of Plaintiff's husband's body because the claims did not concern alleged harms from the institution or prosecution of judicial or administrative proceedings. View "Leon v. County of Riverside" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal determining that Cal. Gov. Code 818, a provision within the Government Claims Act, shields public entities from liability for enhanced damages under Cal. Code Civ. Proc. 340.1(b)(1), holding that the court of appeal did not err.At issue was whether enhanced damages could be awarded under section 340.1(b)(1) against a public entity named as a defendant in a lawsuit for childhood sexual assault or whether such awards were prohibited under section 818, which specifies that a public entity may not be held liable in tort for "damages imposed primarily for the sake of example and by way of punishing the defendant." The court of appeal concluded that the treble damages provision in section 340.1 does not have a compensatory function and that its primary purpose is to punish past childhood sexual abuse coverups and deter future abuse. The Supreme Court affirmed, holding that section 818 prohibits an award of enhanced damages under section 340.1(b)(1) against a public entity. View "L.A. Unified School District v. Superior Court" on Justia Law

Relying on its holding in Cameron v. State of California, 7.Cal.3d 318 (1972), the Supreme Court held that design immunity does not categorically preclude failure to warn claims that involve a discretionarily-approved element of a roadway and declined to overrule its prior precedent.At issue was whether design immunity is limited to claims alleging that a public entity created a dangerous roadway condition through a defective design or whether the statutory defense of design immunity also extends to claims alleging that a public entity failed to warn of a design element that resulted in a dangerous roadway condition. The Supreme Court held (1) the effect of Cameron is that, while Cal. Gov. Code 830.6 shields public entities from liability for injuries stemming from the design of a roadway's physical features, they nonetheless have a duty to warn of known dangers the roadway presents to the public; and (2) this Court declines the invitation of City of Rancho Palo Verdes to overrule Cameron. View "Tansavatdi v. City of Rancho Palos Verdes" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court ruling that the exception to landowners' negation of their statutory duty of care to keep their property safe for others who may enter or use it for recreational purposes does not apply when the landowners' live-at-home child invites someone onto the property without the owners' knowledge or permission, holding that the court of appeals erred.The trial court ruled that the exception did not apply in this case because the landowners had not issued the invitation. The court of appeals reversed, holding that the exception to the landowners' statutory negation of duty when a landowner expressly invites someone onto the property applied unless the child had been prohibited to make the invitation. The Supreme Court reversed, holding (1) a plaintiff may rely on the exception and impose liability if there is a showing that a landowner extended an express invitation to come onto the property; and (2) the plaintiff in this case did not meet her burden. View "Hoffmann v. Young" on Justia Law