Justia California Supreme Court Opinion Summaries

In the case before the Supreme Court of California, the dispute revolved around a residential driveway in Sierra Madre and raised a significant question about the law of easements. The plaintiffs, Tatana Spicakova Romero and Cesar Romero, and the defendants, Li-Chuan Shih and Tun-Jen Ko, owned neighboring properties that were previously a single parcel divided and sold in 1986. An eight-foot-wide strip of land, which belonged to the Romeros but had been used as the driveway for the Shih-Kos' home, was in dispute. The trial court concluded that the parties to the 1986 sale had intended to create an implied easement over this strip of land, allowing the Shih-Kos to continue using it as a driveway. The Court of Appeal reversed, arguing that the law prohibits a court from recognizing an implied easement that precludes the property owners from making all or most practical uses of the easement area.The Supreme Court of California disagreed with the Court of Appeal's interpretation and held that the law does not impose such a limitation on the recognition of implied easements. The court emphasized that the evidentiary standard for recognizing an implied easement is a high one, and it will naturally be more difficult to meet where the nature of the easement effectively precludes the property owners from making most practical uses of the easement area. However, if there is clear evidence that the parties to the 1986 sale intended for the neighboring parcel’s preexisting use of the area to continue after separation of title, the law obligates courts to give effect to that intent. The court reversed and remanded the case back to the Court of Appeal to consider whether substantial evidence supports the trial court’s finding that an implied easement existed under the circumstances of this case. View "Romero v. Shih" on Justia Law

In the Supreme Court of California, the defendant, Glen Taylor Helzer, pleaded guilty to five counts of murder and multiple other charges, including robbery, kidnapping, and conspiracy. After a penalty trial, the jury sentenced him to death for the five counts of murder. The murders were particularly gruesome, involving kidnapping, robbery, and dismemberment of the bodies. The defendant argued that he was under the influence of methamphetamine and suffering from a mental or emotional disturbance at the time of the crimes. On appeal, the defendant raised several issues, including the exclusion of a potential juror due to their views on the death penalty, the denial of a proposed question during jury selection, and the admission of graphic evidence including photographs of the dismembered bodies and the sound of a power saw used in the dismemberment during the prosecution's closing argument. The court affirmed the judgment, finding that the trial court did not abuse its discretion in its rulings and that any error was harmless. The court held that the photographs and the sound of the saw were relevant to the circumstances of the crimes and did not unduly prejudice the jury. The court also held that the removal of a potential juror due to their views on the death penalty did not violate the defendant's right to a representative jury. View "People v. Helzer" on Justia Law

In the Supreme Court of California, the case revolved around the question of whether trial courts have the inherent authority to dismiss a claim under the Labor Code Private Attorneys General Act of 2004 (PAGA) on the grounds of manageability. PAGA permits aggrieved employees to act as private attorneys general to recover civil penalties on behalf of the state for Labor Code violations. In this case, defendant Royalty Carpet Mills, Inc. (Royalty) argued that trial courts should have the power to dismiss PAGA claims if they are deemed unmanageable.The Supreme Court of California held that trial courts do not have the inherent authority to dismiss PAGA claims on manageability grounds. The court emphasized that trial courts do not generally possess a broad inherent authority to dismiss claims, nor is it appropriate for them to dismiss PAGA claims by using class action manageability requirements. The court also affirmed the judgment of the Court of Appeal, which had reached the same conclusion.The court also discussed the facts of the case. Jorge Luis Estrada and Paulina Medina, former employees of Royalty, brought a PAGA claim against the company for alleged violations of Labor Code provisions requiring the provision of meal periods. The trial court certified a class action suit and later decertified it, dismissing the PAGA claim on manageability grounds. The Court of Appeal reversed this decision, which led to Royalty's appeal to the Supreme Court.The Supreme Court stated that while trial courts may use various tools to efficiently manage PAGA claims, striking such claims due to manageability concerns is not among these tools. It also noted that while trial courts and the Labor and Workforce Development Agency (LWDA) share discretion in assessing a civil penalty, the trial court's discretion does not extend to determining which cases can be investigated and enforced, a power reserved for the LWDA.The Supreme Court further rejected the argument that the retrial of the plaintiffs' representative PAGA claim would violate Royalty's right to due process. It stated that while defendants have a due process right to present an affirmative defense, this does not include the right to present the testimony of an unlimited number of individual employees. It also concluded that trial courts lack inherent authority to dismiss a PAGA claim on manageability grounds to protect a defendant's due process rights. However, the court left open the possibility that a defendant could show that a trial court's use of case management techniques so abridged the defendant's right to present a defense that its right to due process was violated.The Supreme Court affirmed the judgment of the Court of Appeal, and remanded the case for further proceedings consistent with its opinion. View "Estrada v. Royalty Carpet Mills, Inc." on Justia Law

In the case of The People v. Fernando Rojas, the Supreme Court of California addressed the issue of whether the application of Assembly Bill 333 to the gang-murder special circumstance in section 190.2(a)(22) of the California Penal Code constituted an unlawful amendment of Proposition 21, which had previously defined the term "criminal street gang".The defendant, Fernando Rojas, was convicted of first degree murder and was found to have committed the crime while being an active participant in a criminal street gang, which made him subject to life imprisonment without the possibility of parole under section 190.2(a)(22). While Rojas's appeal was pending, the state legislature passed Assembly Bill 333, which substantially narrowed the definition of "criminal street gang" for the purposes of section 190.2(a)(22).The lower courts disagreed on whether the application of Assembly Bill 333 would constitute an unlawful amendment of Proposition 21, which had been passed by the voters and was therefore protected from legislative amendment without a two-thirds majority vote of each house of the legislature or approval by the voters.The Supreme Court of California concluded that the application of Assembly Bill 333 to the gang-murder special circumstance did not violate the limitation on legislative amendment in Proposition 21. The Court reasoned that the voters who enacted Proposition 21 intended to impose a specific punishment for gang-related murder while relying on an existing statutory provision to define "criminal street gang". The Court found no indication that the voters intended to adopt a fixed definition of "criminal street gang" and held that applying Assembly Bill 333's narrower definition did not change the punishment for those convicted of the gang-murder special circumstance. Therefore, the Court reversed the judgment of the Court of Appeal and remanded the case for further proceedings. View "P. v. Rojas" on Justia Law

In the case, a defendant, Mario Rodriguez, was charged with several felonies, each carrying a maximum sentence exceeding two years. In 2018, Rodriguez was found mentally incompetent to stand trial and committed to a state hospital. After a certificate indicating his restoration to competency was filed within the two-year time limit, Rodriguez was returned to court. However, due to COVID-19 restrictions, his hearing to confirm his competency did not take place within the two-year period. Rodriguez sought to dismiss the charges against him, claiming the time for commitment had run out.The Supreme Court of California held that under the relevant statutes, the time between the filing of a certificate of restoration of mental competency and the court's ruling on that certificate counts towards the two-year maximum commitment period mandated by section 1370(c)(1) of the California Penal Code. Therefore, the filing of a certificate of restoration does not end the period of mental incompetency commitment.The court sent the case back to the Court of Appeal to decide whether the two-year limit was exceeded in this case, and if so, what remedy Rodriguez might be entitled to. The court did not decide whether Rodriguez was entitled to the remedy of dismissal he sought, or whether and how the issue of tolling may affect Rodriguez's entitlement to any relief. View "Rodriguez v. Super. Ct." on Justia Law

A person identified as O.R. appealed the decision of the Los Angeles County Superior Court to place his child, N.R., under the jurisdiction of the Los Angeles County Department of Children and Family Services (the Department) based on allegations of substance abuse. The Supreme Court of California reviewed two issues concerning the interpretation of the Welfare and Institutions Code section 300, subdivision (b)(1)(D), which allows for jurisdiction over a child in cases where the parent’s substance abuse results in an inability to provide regular care for the child and causes or could cause the child serious physical harm or illness.First, the court clarified the term “substance abuse” as used in the statute. It rejected O.R.’s argument that “substance abuse” must be shown through a medical diagnosis or by meeting the criteria for a substance use disorder as outlined in the Diagnostic and Statistical Manual of Mental Disorders (DSM). The court held that “substance abuse” in this context should be given its ordinary meaning, which refers to the excessive use of drugs or alcohol. The court cautioned that to establish dependency jurisdiction, the abuse must render the parent unable to provide regular care for the child and either cause the child serious physical harm or illness, or place the child at substantial risk of such harm or illness.Second, the court rejected the so-called “tender years presumption,” which holds that substance abuse by a parent is prima facie evidence of an inability to provide regular care and a substantial risk of serious physical harm when the child is very young. The court held that this presumption is not supported by the language of the statute or the legislative intent, and improperly simplifies the analysis required under section 300(b)(1)(D). Instead, the court held that the government must establish each element of the statute separately, without shifting the burden to the parent to rebut a presumption created by a finding of substance abuse.The court reversed the decision of the Court of Appeal and remanded the case for further proceedings consistent with its opinion. View "In re N.R." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Petitioner's petition for relief and resentencing under the new procedure set forth in Senate Bill No. 1437 (former Cal. Penal Code 1170.95, subd. (a); now Cal. Penal Code 1172.6, subd. (a)), holding that the trial court erred.Petitioner was convicted of first degree murder and sentenced to life imprisonment without the possibility of parole. Twelve years later, the Legislature enacted Senate Bill 1437 narrowing or eliminating certain forms of accomplice liability for murder. Petitioner petitioned for relief and resentencing under the new procedure, but the trial court denied the petition for failure to state a prima facie case. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court erred in rejecting Petitioner's prima facie showing and should have proceeded to an evidence hearing on Petitioner's resentencing petition. View "People v. Curiel" on Justia Law

The Supreme Court reversed the judgment of the court of appeal declining to remand this case for resentencing in light of a new law that was enacted after Defendant had been sentenced but while his appeal was still pending, holding that the court of appeal erred.At issue was Senate Bill No. 567, which created a presumption that the sentencing court shall entered a lower term sentence when, inter alia, a "psychological, physical, or childhood trauma" contributed to the offense and set forth the circumstances when a sentencing court may depart from the lower term presumption. Defendant was found guilty of false imprisonment by violence or menace and sentenced to seven years and four months in prison. While Defendant's appeal was pending, Senate Bill 567 was passed, amending Cal. Pen. Code 1170, subd. (b)(6) & (A). The Supreme Court remanded this case for resentencing, holding that the court of appeal erred by finding that the record clearly indicated that the trial court would not have imposed a lower term sentence if it had been aware of the scope of its discretionary powers under the current section 1170 at the time Defendant was sentenced. View "People v. Salazar" on Justia Law

The Supreme Court held, in response to a request by the United States Court of Appeals for the Ninth Circuit, that Cal. Publ. Util. Code 1759 bars a lawsuit that seeks damages resulting from public safety power shutoffs (PSPS) events where the suit alleges that a utility's negligence in maintaining its grid necessitated shutoffs but does not allege that the shutoffs were unnecessary or violated the regulations of the California Public Utilities Commission (PUC).To reduce the risk that its utility infrastructure would ignite a wildfire during extreme weather conditions Pacific Gas and Electric Company (PG&E) conducted a series of emergency power shutoffs that Plaintiff alleged were necessitated by PG&E's negligence in maintaining its power grid. Plaintiff filed a class action complaint against PG&E requesting class damages of $2.5 billion. At issue before the Supreme Court was whether section 1759 barred this lawsuit. The Supreme Court answered the question in the positive, holding that allowing suit under the circumstances here would interfere with the PUC's comprehensive regulatory and supervisory authority over PSPS. View "Gantner v. PG&E Corp." on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court determining that because of racially polarized voting, the at-large method of election had impaired Latino voters' ability to elect candidates of their choice or to influence the outcome of an election, holding that the court of appeal misconstrued the California Voting Rights Act of 2001 (CVRA), Cal. Elec. Code 14025 et seq.The trial court in this case concluded that the at-large method of electing city council members in the City of Santa Monica diluted Latinos' ability to elect their preferred candidates and their ability to influence the outcome of council elections and, as a remedy, ordered the City to conduct a special election using a map drafted by an expert who testified at trial. The court of appeal reversed. The Supreme Court reversed and remanded the case, holding (1) a court presented with a dilution claim should undertake a searching evaluation of the totality of the facts and circumstances; and (2) remand was required for the court of appeal to evaluate the dilution standard of the CVRA under this standard. View "Pico Neighborhood Ass'n v. City of Santa Monica" on Justia Law