Justia California Supreme Court Opinion Summaries

The Supreme Court held that a landowner may not be liable for injuries to an independent contractor or its workers that result from a known hazard on the premises where there were no reasonable safety precautions the landowner could have adopted to minimize or avoid the hazard.Plaintiff's company was hired by Defendant to clean his home's skylight. While Plaintiff was walking on the edge of the roof he slipped and fell, sustaining serious injuries. Plaintiff brought this action, contending that his accident was caused by certain dangerous conditions on Defendant's roof. The trial court granted summary judgment for Defendant, finding that Defendant owed no duty to Plaintiff pursuant to the Privette doctrine, or the presumption that the hirer of an independent contractor delegates to the contractor all responsibility for workplace safety. The court of appeal reversed, concluding that a landowner may be liable to an independent contractor for injuries resulting from known hazards. The Supreme Court reversed, holding that, unless a landowner retains control over any part of the contractor's work and negligently exercises that retained control in a manner that affirmatively contributes to the injury, it is not liable to an independent contractor or its workers for an injury resulting from a known hazard on the premises. View "Gonzalez v. Mathis" on Justia Law

In this case involving the In-Home Supportive Services (IHSS) program the Supreme Court affirmed the judgment of the court of appeal concluding that sections 631 and 683 of the Unemployment Insurance Code exclude from coverage a provider who is the recipient's minor child, parent, or spouse under the state's unemployment insurance program, holding that the court of appeal did not err.The IHSS program authorized certain Californias, who were disabled or elderly, to receive in-home services from third parties or family members paid for with public funds. Under one program option, service recipients hire their own providers and the providers are paid either by a public entity or by the recipients with funds they have received from a public entity. At issue was whether such a provider qualified for unemployment benefits. The Supreme Court answered the question in the negative, holding that provider who is the recipient's minor child, parent, or spouse is not covered by the state's unemployment insurance program. View "Skidgel v. California Unemployment Insurance Appeals Board" on Justia Law

The Supreme Court answered two questions certified by the Ninth Circuit Court of Appeals by holding that publicly funded work on rolling stock, like train cars, does not fall under the statutory definition of "public works" and that the work on rolling rock in this case did not qualify as "public work."At issue were two aspects of a project to design and install a comprehensive communications network to prevent train collections and other dangerous movements called field work and onboard work. Field work included building and outfitting radio towers on land adjacent to train tracks, and onboard work involved installing electronic components on train cars and locomotives. Plaintiff was an employee of Defendant, which subcontracted to install system components on trains and rail cars. Plaintiff sued Defendant for failing to pay prevailing wages. The district court granted summary judgment for Defendant, concluding that onboard work did not fall within the scope of the prevailing wage law. On appeal, the Ninth Circuit asked whether the onboard work for the project fell within the definition of "public works" under Cal. Labor Code 1720(a)(1). The Supreme Court answered that the onboard work performed in this case was not itself "public work." View "Busker v. Wabtec" on Justia Law

The Supreme Court answered a question certified to it by the United States Court of Appeals for the Ninth Circuit by holding that Cal. Labor Code 1772 does not expand the categories of public work that trigger the obligation to pay at least the prevailing wage under Cal. Labor Code 1771.Plaintiffs, unionized engineers who operated milling equipment to break up existing roadbeds, brought a suit in federal court alleging, inter alia, failure to pay the prevailing wage for loading an equipment from an offsite location onto trailers and bringing it to the job site - known as mobilization - done in connection with public works projects. The district court granted summary judgment for Defendants, ruling that mobilization was not covered by prevailing wage protection. Plaintiffs appealed the mobilization decision, and the Ninth Circuit certified the question of whether the mobilization activity was covered by section 1772. The Supreme Court held that, where there was no contention that mobilization qualified as "public work," section 1772 did not provide a basis for requiring Plaintiffs to be paid the prevailing wage for that work. View "Mendoza v. Fonseca McElroy Grinding Co." on Justia Law

The Supreme Court affirmed the judgment of the court of appeal rejecting Appellant's challenge to the denial of his motion to disqualify A. Robert Singer as a hearing officer in a peer review proceeding, holding that the record did not establish that Singer should be disqualified for financial bias under Cal. Bus. & Prof. Code 809.2, subdivision (b).A medical executive committee adopted a recommendation to terminate Appellant's medical staff membership and hospital privileges. Appellant requested a peer review hearing to review the recommendation, and the hospital president exercised authority delegated by the medical staff to select Singer to serve as the hearing officer. Appellant challenged Singer's appointment on grounds of financial bias, but Singer denied the challenge. The peer review panel upheld the revocation of Appellant's staff membership and privileges. The superior court denied Appellant's petition for a writ of administrative mandate, and the court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances surrounding Singer's appointment did not create an intolerable risk of bias that would require disqualification under section 809.2(b). View "Natarajan v. Dignity Health" on Justia Law

The Supreme Court held that possession of cannabis in prison remains a violation of Cal. Penal Code 4573.6 and that Proposition 64 - the Control, Regulate and Tax Adult Use of Marijuana Act - did not invalidate cannabis-related convictions under section 4573.6, which makes it a felony to possess a controlled substance in a state correctional facility.The five defendants in this case were each found in possession of cannabis in a state prison and were convicted of violating section 4573.6. After voters passed Proposition 64 in 2016, Defendants filed petitions arguing that their sentences for violating section 4573.6 should be dismissed because adult possession of less than one ounce of cannabis in prison no longer qualified as a crime. The trial court denied the petitions. The court of appeal reversed, holding that the conduct underlying Defendants' convictions was no longer criminal under section 4573.6. The Supreme Court reversed, holding that Cal. Health & Saf. Code 11362.5(d) - containing an exception providing that the Act does not amend or affect certain laws - is most reasonably construed as encompassing laws that prohibit the possession of cannabis in prison. View "People v. Raybon" on Justia Law

The Supreme Court reversed the order of the court of appeals denying a petition for a writ of supersedeas to stay the effect of an order of the superior court requiring the San Bernardino County Board of Supervisors to remove and replace one of its members, holding that the order should be stayed until the appellate court has determined whether the trial court was correct.The superior court's order was based on the court's ruling that the Board had violated statutory open-meeting requirements in making an appointment to a vacant board seat. The order required the Board to rescind the appointment and to seat a replacement board member to be named by the Governor. The Board petitioned the court of appeal for a writ of supersedeas and requested an immediate stay. The court of appeal denied the stay. The Supreme Court reversed and remanded the case, holding that the order should have been automatically stayed as a mandatory injunction. View "Daly v. San Bernardino County Board of Supervisors" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal striking as unreasonable a condition of supervised release requiring Defendant to "submit to search of any electronic device either in his possession[,] including cell phone[,] and/or any device in his place of residence," holding that there was no error.At issue was how to assess the validity of a challenged condition of a period of mandatory supervision following service of a county jail sentence. The Supreme Court held (1) such discretionary conditions are to be evaluated for reasonableness on a case-by-case basis under the test set forth in People v. Lent, 15 Cal.3d 481 (1975); (2) a mandatory supervision condition that allows for a search of an individual's electronic devices is not per se reasonable in all cases; and (3) because the People did not review the court of appeal's case-specific outcome in this case, this Court accepts that concession and does not review the court of appeal's determination as to the condition imposed on Defendant. View "People v. Bryant" on Justia Law

In this action brought by a physician alleging that the defendant hospitals and medical staff members unlawfully retaliated against him for raising concerns about patient care the Supreme Court held that Defendants were not entitled to wholesale dismissal of Plaintiff's claims under the anti-SLAPP law.Defendants sought to strike Plaintiff's retaliation claims under the anti-SLAPP statute, arguing that any claim arising from the peer review process targets protected speech or petitioning activity and therefore must be afforded anti-SLAPP protection. The trial court granted Defendants' motion. The court of appeal reversed, concluding that the anti-SLAPP statute does not protect actions taken with a retaliatory motive. The Supreme Court reversed in part, holding that Defendants demonstrated that some, but not all, of the claims collected was unlawful acts of retaliation in Plaintiff's first cause of action arose from protected speech or petitioning activity. View "Bonni v. St. Joseph Health System" on Justia Law

The Supreme Court vacated the judgment of the court of appeal and its award of costs on appeal, holding that a claim for failure to promote brought under the harassment provision of the Fair Employment and Housing Act (FEHA), Cal. Gov. Code 12940, subd. (j), 12960, accrues, and thus the statute of limitations begins to run, at the point when an employee knows or reasonably should know of the employer's allegedly unlawful refusal to promote the employee.Plaintiff alleged that her employer passed her over for promotions because she refused to have sex with the company's executive vice-president, Michael Kelso. The trial court granted summary judgment for Kelso, finding no triable issue of fact as to Kelso's statute of limitations defense. The court of appeal affirmed the trial court's grant of summary judgment for Kelso and two other defendants and awarded costs on appeal to all three defendants. The Supreme Court reversed, holding (1) the court of appeals erred in concluding that the statute of limitations began to run when Plaintiff's employer offered a promotion to someone else and she accepted it; and (2) the court of appeal erred in awarding costs on appeal to Defendants without first finding that Plaintiff's underlying claim was objectively groundless. View "Pollock v. Tri-Modal Distribution Services, Inc." on Justia Law