Justia California Supreme Court Opinion Summaries

A group of family members was attacked after being mistaken for rival gang members by individuals associated with the Dragon Family/Dragon Family Junior gang in Orange County. After being followed from a restaurant, their car was cornered in a cul-de-sac, and a shooter fired multiple shots into the vehicle, killing a 13-year-old and injuring two others. Several gang members were apprehended soon after, while the defendant was arrested months later in Arizona. At trial, accomplice testimony, forensic evidence, and writings attributed to the defendant were presented to establish his identity as the shooter and his gang affiliation.The Orange County Superior Court jury convicted the defendant of murder, two counts of attempted murder, and active participation in a criminal street gang, with various firearm and gang-related enhancements. The jury found true a special circumstance that the murder was committed to further gang activities and returned a death verdict. The trial court denied the defendant’s motion to modify the verdict. The defendant raised several claims on appeal, including challenges to jury selection under Batson and Wheeler, the sufficiency of accomplice corroboration, the handling of third-party culpability evidence, the admission of creative writings, the denial of a continuance, and alleged prosecutorial misconduct.The Supreme Court of California reviewed the case. It held that retroactive changes to the law under Assembly Bill 333, which heightened the requirements for proving a “pattern of criminal gang activity,” applied to the defendant’s case. The Court found that the jury had not been instructed under the new, stricter standard, and the Attorney General conceded this error was prejudicial. As a result, the conviction for active gang participation, all gang enhancements, and the gang-murder special circumstance were reversed, requiring reversal of the death judgment. The Court otherwise affirmed the judgment, finding no merit in the defendant’s other claims. The case was remanded for further proceedings. View "P. v. Aguirre" on Justia Law

A hotel property owner challenged the Los Angeles County Assessor’s valuation of its property for tax purposes, arguing that two specific revenue streams should have been excluded from the income-based assessment. The first was a 14 percent nightly occupancy tax assigned by the City of Los Angeles to the original developer as an incentive to construct the hotel, and the second was a one-time “key money” payment made by Marriott International to the owner for the right to manage and brand the hotel for 50 years. The owner claimed these revenues derived from nontaxable intangible assets—contractual rights—and thus should not be included in the property’s taxable value.The Los Angeles County Assessment Appeals Board ruled in favor of the County, finding both the occupancy tax and key money payments were properly included as income from the property itself. The Board also found insufficient evidence to isolate the value of certain enterprise assets (customer goodwill, food and beverage operations, and workforce) from the real estate value. The Los Angeles County Superior Court affirmed the Board’s decision on the occupancy tax and key money, but remanded for further proceedings on the valuation of the enterprise assets. The California Court of Appeal reversed the trial court on the first two issues, holding that the occupancy tax and key money should be excluded, but affirmed the remand for valuation of the enterprise assets.The Supreme Court of California reviewed the case and held that the Assessor was permitted to include both the occupancy tax and key money payments in the hotel’s assessed value, as these revenues represent income from the use of the property itself rather than from enterprise activity. The Court affirmed the lower courts’ decision to remand for further proceedings regarding the valuation and deduction of the three identified enterprise assets. The judgment was reversed in part and affirmed in part. View "Olympic and Ga. Partners, LLC v. County of L.A." on Justia Law

Two defendants, both members of a criminal street gang, were involved in a shooting incident outside a liquor store in Hemet, California, in December 2020. They were convicted by a jury of attempted murder, active participation in a criminal street gang, unlawful possession of a firearm, assault with a semiautomatic firearm, and willful discharge of a firearm at an occupied vehicle. The jury also found true several gang and firearm enhancements. In a subsequent bench trial, the court found that both defendants had prior 2015 convictions for unlawful possession of a firearm with a gang enhancement, and one defendant had an additional prior conviction for attempted burglary. These prior convictions were used to impose enhanced sentences under California’s Three Strikes law and the five-year prior serious felony enhancement.On appeal, after the passage of Assembly Bill 333, which narrowed the definitions and requirements for gang enhancements under Penal Code section 186.22, the Attorney General conceded that the new law applied retroactively to nonfinal judgments. The California Court of Appeal reversed the convictions and enhancements related to gang participation and remanded for possible retrial under the new standards. However, the Court of Appeal held that Assembly Bill 333 did not apply to the determination of whether the defendants’ 2015 convictions qualified as prior serious felonies or strikes, reasoning that such application would improperly amend voter-approved initiatives that set the list of serious felonies as of a specific date.The Supreme Court of California reviewed the case and held that Assembly Bill 333 does apply to the determination of whether a prior conviction qualifies as a serious felony under section 1192.7(c)(28) for purposes of the Three Strikes law and prior serious felony enhancements. The Court concluded that current law governs this determination, and that such application does not unconstitutionally amend any ballot initiative. The Court vacated the true findings on the prior serious felony convictions and remanded for retrial under the amended law. View "P. v. Fletcher" on Justia Law

A worker in Humboldt County performed maintenance and other services for several years on property managed by his employers, in exchange for free rent but without additional pay or benefits. After the arrangement ended, he filed claims with the Labor Commissioner, asserting he was an employee entitled to unpaid wages, liquidated damages, and penalties, including under California’s Paid Sick Leave law. The employers contended he was an independent contractor, but the Labor Commissioner found he was an employee and awarded him compensation.The employers appealed the Labor Commissioner’s decision to the Humboldt County Superior Court, which conducted a de novo bench trial. The court agreed that the worker was an employee and awarded unpaid wages, penalties, and interest. However, it denied liquidated damages, finding the employers acted in good faith based on their mutual understanding with the worker that he would work for rent and not as an employee. The court also rejected the worker’s claim for penalties under the Paid Sick Leave law, concluding such claims could not be raised in court during an employer’s appeal of a Labor Commissioner ruling. The worker appealed, and the California Court of Appeal affirmed the superior court’s rulings on both the liquidated damages and Paid Sick Leave issues.The Supreme Court of California reviewed the case. It held, first, that to establish a good faith defense to liquidated damages for minimum wage violations, an employer must show it made a reasonable attempt to determine the requirements of minimum wage law; mere ignorance of the law is insufficient. Second, the court held that an employee may raise a claim under the Paid Sick Leave law in the context of an employer’s appeal to the superior court of a Labor Commissioner ruling. The Supreme Court reversed the Court of Appeal’s judgment and remanded for further proceedings. View "Iloff v. LaPaille" on Justia Law

The case concerns a defendant who was convicted by a jury of the first degree murders of two young children, Tyler and Dylan, as well as assaulting Dylan, a child under eight, with force likely to produce great bodily injury resulting in death. The defendant was in romantic relationships with each child’s mother and lived with them at the time of the children’s deaths. Both children suffered extensive physical abuse and fatal injuries while in the defendant’s care. Medical and forensic evidence indicated repeated, severe trauma consistent with child abuse. The defendant denied responsibility, suggesting others may have caused the injuries, and presented evidence attempting to cast doubt on the mothers’ fitness as parents.After the initial trial in the Kern County Superior Court, the defendant was convicted and sentenced to death, but the trial court granted a new trial due to juror misconduct. At retrial, the jury again convicted the defendant on all counts and returned a death verdict, which the trial court entered as judgment. The defendant was also sentenced to 25 years to life for the assault charge, with that term stayed.The Supreme Court of California automatically reviewed the case. The defendant raised numerous claims, including challenges to the sufficiency of the evidence, denial of motions for change of venue and to sever charges, alleged juror misconduct, evidentiary rulings, and constitutional challenges to California’s death penalty statute. The court found the evidence sufficient to support the convictions for first degree murder, both as deliberate and premeditated and as murder by torture. The court also found no reversible error in the trial court’s evidentiary and procedural rulings, and rejected the constitutional challenges to the death penalty scheme.The Supreme Court of California’s main holding was to strike a $200 parole revocation fine imposed under Penal Code section 1202.45, as the defendant’s sentence did not include a period of parole. In all other respects, the court affirmed the judgment, including the convictions and the death sentence. View "P. v. Alvarez" on Justia Law

William Cannon was convicted of assault with intent to commit rape and dissuading a witness, after attacking a 16-year-old girl and confessing to other attempted sexual assaults. Near the end of his prison sentence, the district attorney petitioned to commit him under the Sexually Violent Predator Act (SVPA), which allows for the civil commitment of certain sex offenders after their sentences if they are found to be sexually violent predators. During pretrial proceedings, Cannon’s attorney, without Cannon’s personal attendance or express waiver, waived his right to a jury trial. The trial court did not advise Cannon of his jury trial rights or seek his personal waiver, as the SVPA does not require these steps. Following a bench trial, Cannon was found to be a sexually violent predator and was committed.On appeal, Cannon argued for the first time that the SVPA’s procedures violated his state and federal equal protection rights because, unlike other civil commitment schemes for individuals found not guilty by reason of insanity (NGI) or those with mental health disorders (OMHD), the SVPA does not require a judicial advisement of the right to a jury trial or a personal waiver from the defendant. The Court of Appeal considered the equal protection claim despite it not being raised below, found that rational basis review was the appropriate standard, and remanded the case to the trial court to allow the parties to develop a fuller record and litigate the equal protection issue.The Supreme Court of California reviewed the case to determine the appropriate standard of scrutiny for Cannon’s equal protection challenge. The court held that rational basis review, not strict scrutiny, applies to the SVPA’s jury trial demand and waiver procedures. The court affirmed the Court of Appeal’s remand order, directing the trial court to determine whether the legislative choice of procedures is constitutionally justified under rational basis review and whether Cannon knowingly waived his right to a jury trial. The order of commitment is conditionally affirmed pending the outcome of those proceedings. View "P. v. Cannon" on Justia Law

The case concerns the death of Skyler A. Womack, a dependent adult with disabilities who resided at a 24-hour skilled nursing facility operated by Silverscreen Healthcare, Inc. After Skyler’s death, his parents filed suit against the facility, alleging that neglect—including understaffing, failure to maintain the facility, and inadequate provision of basic needs—led to his injuries and death. The claims included survivor actions and a wrongful death claim. Notably, Skyler had signed an arbitration agreement upon admission, which stated that any medical malpractice disputes would be subject to arbitration and purported to bind his heirs.In the Los Angeles County Superior Court, Silverscreen moved to compel arbitration of all claims based on the arbitration agreement and the California Supreme Court’s decision in Ruiz v. Podolsky. The trial court compelled arbitration of the survivor claims but denied arbitration for the parents’ wrongful death claim, reasoning that the claim was based on neglect under the Elder Abuse Act, not professional negligence. The California Court of Appeal reversed, holding that the wrongful death claim was subject to arbitration because it was based on professional negligence as defined by the agreement and relevant statutes.The Supreme Court of California reviewed the case and reversed the Court of Appeal’s decision. The Court held that the exception recognized in Ruiz v. Podolsky applies only to wrongful death claims that are based on medical malpractice as defined by the Medical Injury Compensation Reform Act (MICRA), specifically disputes about whether medical services were improperly rendered. The Court clarified that not all wrongful death claims against health care providers fall within this exception—claims based on custodial neglect, as opposed to professional negligence in medical care, are not subject to arbitration under section 1295 and Ruiz. The Court remanded the case to allow plaintiffs to amend their complaint to clarify the basis of their wrongful death claim. View "Holland v. Silverscreen Healthcare, Inc." on Justia Law

An employee was hired by a company and, as a condition of employment, signed an agreement requiring all employment-related claims to be resolved through arbitration governed by the Federal Arbitration Act (FAA). The agreement specified that the employer would pay all arbitration costs except for certain fees. After the employee reported alleged workplace harassment and was subsequently terminated, he sued the employer in California Superior Court for retaliation and other violations. The employer moved to compel arbitration, which the court granted, and arbitration commenced. After about a year, the arbitrator issued invoices for fees, which the employer failed to pay within 30 days of receipt, as required by California Code of Civil Procedure section 1281.98. The employee then sought to withdraw from arbitration and proceed in court, arguing the employer’s late payment constituted a material breach under section 1281.98.The Superior Court denied the employee’s motion, reasoning that the arbitrator had set a new due date for payment and the employer paid within 30 days of that date. The California Court of Appeal reversed, holding that the statutory 30-day deadline applied from the original invoice date and that the employer’s late payment resulted in a material breach, allowing the employee to withdraw from arbitration. The Court of Appeal also held that section 1281.98 was not preempted by the FAA.The Supreme Court of California reviewed the case to determine whether section 1281.98 is preempted by the FAA. The court held that section 1281.98 is not preempted, but clarified that the statute does not abrogate longstanding contract principles allowing relief from forfeiture for non-willful, non-grossly negligent, or non-fraudulent breaches. The court reversed the Court of Appeal’s order lifting the stay and remanded for the trial court to determine whether the employer’s late payment was excusable and whether the employee suffered compensable harm. View "Hohenshelt v. Superior Court" on Justia Law

This case involves a dispute over the compensation structure for utility customers who generate their own electricity, such as through rooftop solar panels, and export excess energy to the power grid. The California Legislature has required utilities to compensate these “customer-generators” since 1995, but concerns arose that the original compensation method overpaid such customers and shifted costs to those without solar systems. In 2013, the Legislature directed the Public Utilities Commission to reassess the compensation framework, resulting in a 2022 tariff that significantly reduced payments for customer-generated power. Environmental groups challenged the new tariff, arguing it failed to account for all societal benefits of renewable energy and did not adequately promote growth among disadvantaged communities.The First Appellate District, Division Three, reviewed the challenge after the petitioners sought a writ of review. The Court of Appeal affirmed the Commission’s decision, applying a highly deferential standard from Greyhound Lines, Inc. v. Public Utilities Com., which upheld Commission interpretations unless they lacked a reasonable relation to statutory purposes and language. The appellate court concluded that the Commission’s approach met this deferential standard and declined to engage in further inquiry.The Supreme Court of California granted review to determine whether the deferential Greyhound standard remains appropriate following legislative amendments to the Public Utilities Code. The Supreme Court held that, due to statutory changes in the 1990s and 2000s, the Greyhound standard no longer applies to most Commission decisions, including those involving energy. Instead, courts must now independently review the Commission’s statutory interpretations, consistent with the approach outlined in Yamaha Corp. of America v. State Bd. of Equalization. The Supreme Court reversed the Court of Appeal’s judgment and remanded the case for further proceedings under the correct standard of review. View "Center for Biological Diversity, Inc. v. Public Utilities Com." on Justia Law

In October 2021, five children were removed from their home under a protective custody warrant and placed into the temporary custody of San Bernardino County Children and Family Services (the Department). Dependency petitions were filed for all five children. At the detention hearing, the mother denied Indian ancestry, and the father of two of the children also denied Indian ancestry but indicated potential Indian heritage on an ICWA form. The juvenile court found ICWA did not apply and took jurisdiction over the children, removing them from parental custody and ordering reunification services for the mother.The mother appealed, arguing the Department failed to fulfill its duty to inquire about the children's potential Indian ancestry from extended family members, as required by former section 224.2, subdivision (b). The Court of Appeal held that the extended-family inquiry duty did not apply because the children were placed into temporary custody pursuant to a warrant under section 340, not section 306, and thus rejected the mother's argument.The Supreme Court of California reviewed the case to resolve the conflict regarding the scope of the initial inquiry duty under former section 224.2. The court concluded that the county welfare department has an extended-family inquiry duty in all cases where a child is placed into temporary custody, regardless of whether the child was removed from the home with or without a warrant. The court held that Assembly Bill 81, which clarified this duty, applies retroactively as it merely clarified existing law.The Supreme Court of California reversed the judgment of the Court of Appeal and remanded the matter to the juvenile court for compliance with the inquiry requirements of section 224.2. If the juvenile court finds the inquiry duty has been satisfied and ICWA does not apply, it shall reinstate the jurisdiction and disposition order. If ICWA applies, the court shall proceed in conformity with ICWA and California implementing provisions. View "In re Ja. O." on Justia Law