Justia California Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeal affirming the judgment of the court of appeal granting summary judgment for the defense in this lawsuit brought by the California Medical Association (CMA), holding that the evidence was sufficient to create triable issues of fact precluding summary judgment.CMA, a nonprofit professional association representing California physicians, sued Aetna Health of California Inc. alleging that Aetna violated the unfair competition law (UCL), Cal. Bus. & Prof. Code 17200 et seq., by engaging in unlawful business practices. At issue was whether Aetna satisifed the UCL's standing requirements by diverting its resources to combat allegedly unfair competition. The Supreme Court held (1) the UCL’s standing requirements are satisfied when an organization, in furtherance of a bona fide, preexisting mission, incurs costs to respond to perceived unfair competition that threatens that mission, so long as those expenditures are independent of costs incurred in UCL litigation or preparations for such litigation; and (2) the trial court erred in granting summary judgment for Aetna on the ground that CMA lacked standing. View "Cal. Medical Assn. v. Aetna Health of Cal., Inc." 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 a claim for reimbursement of emergency medical services may be maintained against a health care service plan when the plan is operated by a public entity and that the Government Claims Act, Cal. Gov. Code 810 et seq., did not immunize the County of Santa Clara from such a claim in this case.Two hospitals submitted reimbursement claims for the emergency medical services they provided to three individuals enrolled in a County-operated health care service plan. The hospitals sued for the remaining amounts based on the reimbursement provision of the Knox-Keene Act, and the trial court concluded that the hospitals could state a quantum merit claim against the County. The court of appeal reversed, determining that the County was immune from suit under the Government Claims Act. The Supreme Court reversed, holding that the County was not immune from suit under the circumstances of this case and that the hospitals' claims may proceed. View "County of Santa Clara v. Superior Court" 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 with instructions to remand this case to the trial court for further proceedings on Defendant's petition for resentencing, holding that the trial court erred in denying the petition.Defendant was convicted of second-degree murder and street terrorism, as well as gang and firearm enhancements. Two years after Defendant was sentenced, the legislature enacted Senate Bill No. 1437 to amend section 188 to provide that, except in cases of felony murder, "in order to be convicted of murder, a principal in a crime shall act with malice aforethought." Thereafter, Defendant petitioned the trial court for resentencing under what is now Cal. Penal Code1172.6, arguing that his murder conviction was based on the now-invalid natural and probable consequences theory. The trial court denied the petition. The Supreme Court reversed and remanded the case, holding that the trial court erred in sustaining Defendant's second-degree murder conviction, and to the extent the petition was rejected under a direct aiding and abetting theory, the trial court reversibly erred by misunderstanding the legal requirements of direct aiding and abetting implied malice murder. View "People v. Reyes" on Justia Law

The Supreme Court affirmed as modified the judgment of the appellate court reducing the length of Defendant's probation from three years to two, holding that Assembly Bill No. 1950 (2019-2020 Reg. Sess.) applies retroactively to cases not yet final on appeal.On January 1, 2021, Assembly Bill 1950 became effective and reduced the maximum length of probation for most felonies to two years. While Defendant's appeal from his conviction and sentence was pending, the legislature enacted Assembly Bill 1950. The court of appeal agreed with Defendant that the probation limit applied to Defendant retroactively and that the proper remedy was remand to allow the trial court to allow the parties to renegotiate a resolution. The Supreme Court affirmed as modified, holding (1) Assembly Bill 1950 applies retroactively to all nonfinal cases; and (2) the proper remedy in this case is to modify the judgment to reflect a new probationary term of two years. View "People v. Prudholme" on Justia Law

The Supreme Court remanded this case to the court of appeal to determine in the first instance whether Sarah Plott Key was entitled to equitable relief from the 100-day deadline prescribed by Cal. Code Civ. P. 1288.2, holding that the section 1288.2 deadline is not jurisdictional and does not otherwise prelude equitable tolling or estoppel.Plaintiff prevailed in an arbitration against Defendant and petitioned to confirm the award. Defendant moved to vacate the award. The trial court vacated the award despite the fact that Defendant filed her motion to vacate outside the 100-day deadline. The court of appeal reversed, concluding that the 100-day deadline was jurisdictional and that the parties could not extend the deadline by agreement. The Supreme Court reversed, holding (1) Plaintiff's requests were filed outside the applicable statutory period; and (2) section 1288.2's deadline for seeking vacatur of an arbitral award is a nonjurisdictional statute of limitations that is subject to equitable tolling and equitable estoppel. View "Law Finance Group, LLC v. Key" on Justia Law

The Supreme Court reversed the court of the court of appeal reversing Defendant's conviction of rape and kidnapping to commit rape, holding that the court of appeals incorrectly found prejudicial instructional error.On appeal, the court of appeal concluded that the trial court erred in instructing the jury that Defendant could be convicted of kidnapping to commit rape based on the theory that he accomplished the kidnapping by deception rather than by force or fear. The Supreme Court reversed, holding that because any rational juror who made the findings reflected in the verdict would necessarily have found that Defendant used some quantum of physical force to move the victim in this case, any error did not contribute to the verdict. View "People v. Lewis" 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 Defendant's sentence of death, following resentencing, in connection with his convictions of first degree murder, two counts of forcible rape, and enhancements for personal use of a firearm, holding that any error in the resentencing was harmless beyond a reasonable doubt.When Defendant was convicted in 2000 the jury found true special circumstances for committing murder during a kidnapping and intentional infliction of torture and set the penalty at death. The Supreme Court upheld the guilt judgment but reversed the penalty verdict on the grounds that the trial court erroneously dismissed a juror during penalty phase deliberations. After a retrial, Defendant was again sentenced to death. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar Defendant's penalty retrial; (2) the penalty retrial did not violate due process; (3) Defendant's challenges to the constitutionality of California's death penalty statute were unavailing; and (4) any error brought about by retroactive application of Senate Bill 1437 was harmless beyond a reasonable doubt. View "People v. Wilson" on Justia Law