Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the trial court sustaining Well Fargo Bank, N.A.'s demurrer to Plaintiff's negligence claim, holding that Plaintiff was not entitled to relief on his claims of error.At issue on appeal was whether a lender owes the borrower a tort duty sounding in general negligence principles to process and respond carefully to a borrower's loan modification application such that, upon a breach of this duty, the lender may be liable for the borrower's pecuniary losses unaccompanied by property damage or personal injury. The Supreme Court held that there was no such duty, holding that neither Plaintiff's assertion of a "special relationship" between himself and Wells Fargo nor his invocation of the factors articulated in Biakanja v. Irving, 49 Cal.2d 647 (1958), provided a compelling basis to recognize such a duty. View "Sheen v. Wells Fargo Bank, N.A." on Justia Law

The Supreme Court held that Cal. Civ. Code 3333.2 applies to a physician assistant who has a legally enforceable agency relationship with a supervising physician and provides services within the scope of that agency relationship, even if the physician violates his obligation to provide adequate supervision.Under a provision of the Medical Injury Compensation Reform Act (MICRA), damages for noneconomic losses shall not exceed $250,000 in any action for injury against a healthcare provider based on "professional negligence." At issue before the Supreme Court was whether section 3333.2 applies to actions against physician assistants who are nominally supervised by a doctor but receive minimal or no supervision when performing medical services. The Supreme Court held that a physician assistant practices within the scope of her license for purposes of MICRA’s cap on noneconomic damages when the physician assistant acts as the agent of a licensed physician, performs the type of services authorized by that agency relationship, and does not engage in an area of practice prohibited by the Physician Assistant's Practice Act. See Cal. Bus. & Prof. Code, former 3502, subd. (d). View "Lopez v. Ledesma" on Justia Law

The Supreme Court affirmed the judgment of the the trial court convicting defendants Karl Holmes, Herbert McClain, and Lorenzo Newborn of three counts of murder, five counts of attempted murder, and one count of conspiracy to commit murder and sentencing each defendant to death, holding that no prejudicial error occurred at either stage of the proceedings.After the jury failed to reach a penalty verdict, a new penalty phase was held, and death verdicts were returned against all defendants. On appeal, Defendants asserted several allegations of error argued that the cumulative prejudicial errors in both the guilt and penalty phases of the trials required the reversal of their convictions and sentences. The Supreme Court affirmed, holding (1) in the few instances in which this Court found or assumed error, no prejudice resulted; and (2) whether the claims are considered separately or cumulatively, no prejudicial error occurred. View "People v. Holmes" on Justia Law

The Supreme Court held that Cal. Labor Code 1102.6 governs whistleblower retaliation claims brought pursuant to Cal. Labor Code 1102.5.Since 2003, section 1102.6 has prescribed a framework for presenting and evaluating retaliation claims brought under section 1102.5. Since 2003, some courts continued to apply the burden-shifting framework borrowed from the decision in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). The trial court granted summary judgment for Defendant on Plaintiff's whistleblower retaliation claim in this case, concluding that Plaintiff could not satisfy the third step of the McDonnell Douglas test. The Ninth Circuit Court of Appeal certified a question regarding the correct standard to the Supreme Court. The Supreme Court answered that section 1102.6 provides the governing framework for the presentation and evaluation of whistleblower retaliation claims brought under section 1102.5. View "Lawson v. PPG Architectural Finishes, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the decision of the trial court to sentence Defendant to three years for robbery with a twenty-five-years-to-life enhancement under Cal. Penal Code 12022.53(d), holding that the the trial court erred in denying Defendant's motion to strike.A jury convicted Defendant of second degree robbery, assault with a semiautomatic firearm, and driving under the influence. The jury found true the firearm use enhancements on the robbery and assault counts. Before sentencing, Defendant moved under Cal. Penal Code 12022.53(h) to strike the firearm enhancement under section 12022.53(d). The court denied Defendant's motion. On appeal, Defendant argued that the trial court abused its discretion because it was unaware that it could strike the enhancement at issue and then impose a lesser enhancement under either section 12022.53(b) or (c). The court of appeal affirmed, concluding that the trial court could not strike the enhancement and substitute a different unalleged enhancement. The Supreme Court reversed, holding that the Legislature has permitted courts to impose a section 12022.53(b) or (c) penalty when only a section 12022.53(d) enhancement is charged and found true. View "People v. Tirado" on Justia Law

The Supreme Court held that Curtis Olson failed to show the requisite "minimal merit" on a critical element of his breach of contract claim and thus could not defeat Jane Doe's anti-SLAPP motion.Doe and Olson each owned units in the same condominium building. Doe brought a civil harassment restraining order against Olson, and as a result of court-ordered mediation, the parties agreed if they encountered each other in a public or common place "not to disparage one another." Doe later filed a civil lawsuit against Olson seeking damages. Olson cross-complained for breach of contract and specific performance, and Doe moved to strike Olson's cross-complaint under the anti-SLAPP statute. The Supreme Court reversed the court of appeal's judgment insofar as it reversed the trial court's order granting Doe's special motion to strike the breach of contract clause of action with respect to statements in Doe's civil complaint, holding that Doe had no obligation under the contract to refrain from making disparaging statements in litigation, and therefore, Olson could not defeat Doe's anti-SLAPP motion. View "Olson v. Doe" on Justia Law

The Supreme Court affirmed Defendant's convictions for first degree murder and other crimes and Defendant's death sentence, holding that any found or assumed errors were individually harmless and that there was no cumulation of error that merited reversal.Specifically, the Supreme Court found or assumed errors in the admission of prior crimes evidence, a prosecutorial misconduct claim concerning a jury argument that Defendant signed a parole form advising him of a possible life sentence, a claim that the defense was prevented from responding to the prosecutor's argument, a claim that certain expert testimony usurped the trial court's role to instruct the jury about the law, and four additional prosecutorial misconduct claims. The Court held (1) any assumed or actual error in each of these claims was individually harmless; and (2) there was no cumulative error warranting reversal. View "People v. Johnson" on Justia Law

The Supreme Court held that the Department of Corrections and Rehabilitation acted within the authority provided by Cal. Const. art. I, 32(b) when it adopted regulations prohibiting early parole consideration under the scheme set forth in Proposition 57, The Public Safety and Rehabilitation Act of 2016, for inmates "currently serving a term of incarceration for a 'violent felony.'"After Petitioner was convicted of nine violent felony counts and six nonviolent felony counts voters approved Proposition 57. The Department subsequently adopted regulations implementing early parole considerations, including the regulations at issue here. Consistent with these regulations, the Department determined that Petitioner was ineligible for nonviolent offender early parole consideration because he was serving a term of incarceration for a violent felony. The court of appeal granted relief, concluding that the language of article I, section 32(a) requires early parole consideration for any inmate convicted of a nonviolent felony even when that inmate was also convicted of a violent felony. The Supreme Court reversed, holding that the Department acted within its authority provided by article I, section 32(b) when it adopted the regulation at issue. View "In re Mohammad" on Justia Law

The Supreme Court held that Cal. Health & Safety Code 13009 and 13009.1 incorporate the common law theory of respondent superior, and therefore, a corporation cannot be held vicariously liable for the cost of suppressing fires that its agents or employees negligently or unlawfully set or allowed to escape.After a 2016 wildfire burned nearly 7,500 acres of land in California, the California Department of Forestry and Fire Protection (CalFire) determined that the fire had started on the property of Defendant, Presbyterian Camp and Conference Centers, Inc., when an employee of Defendant removed a smoldering log from a fireplace in one of Defendant's cabins. CalFire brought suit, seeking recovery of its expenses from Defendant. Defendant demurred, contending that sections 13009 and 13009.1 do not contemplate vicarious liability. The trial court overruled the demurrer. Thereafter, Defendant brought a writ petition challenging the trial court's order. The court of appeals denied the writ. The Supreme Court affirmed, holding that sections 13009 and 13009.1 incorporate the common law theory of respondent superior. View "Presbyterian Camp & Conference Centers v. Superior Court" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that Petitioners' failure to present their objections to business improvement districts (BIDs) assessment schemes at appropriate public hearings meant that they had not exhausted their extrajudicial remedies, holding that Petitioners need not have raised their specific objections to the BIDs at the public hearings to later advance those arguments in court.Petitioners initiated two actions challenging arguing that two BIDs' assessment schemes violated certain provisions of Proposition 218 and seeking relief that would remove any obligation that they pay assessments for the BIDs. The superior court reached the merits of Petitioners' claims, ultimately denying them in full. The court of appeal declined to address Petitioners' claims on the merits, concluding that Petitioners had failed to exhaust their extrajudicial remedies because they did not first present their objections at the appropriate public hearing. The Supreme Court reversed, holding that Petitioners were not required to articulate their objections to the BID assessment schemes at public hearings before presenting their arguments in these proceedings. View "Hill RHF Housing Partners, L.P. v. City of Los Angeles" on Justia Law