Justia California Supreme Court Opinion Summaries
Mendoza v. Fonseca McElroy Grinding Co.
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
Posted in:
Labor & Employment Law
Natarajan v. Dignity Health
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
People v. Raybon
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
Posted in:
Criminal Law
Daly v. San Bernardino County Board of Supervisors
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
Posted in:
Government & Administrative Law
People v. Bryant
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
Posted in:
Criminal Law
Bonni v. St. Joseph Health System
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
Posted in:
Labor & Employment Law
Pollock v. Tri-Modal Distribution Services, Inc.
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
Posted in:
Civil Rights, Labor & Employment Law
People v. Lewis
The Supreme Court reversed the judgment of the court of appeals affirming the trial court's summary denial of Defendant's Cal. Penal Code 1170.95 petition, holding that the statutory language and legislative intent of section 1170.95 make clear that petitioners are entitled to the appointment of counsel upon the filing of a facially sufficient petition.Senate Bill No. 1437 eliminated natural and probable consequences liability for muder and limited the scope of the felony murder rule. The bill also added section 1170.95 to the Penal Code, which creates a procedure for convicted murderers who could not be convicted under the law as amended to retroactively seek relief. Defendant filed a section 1170.95 petition. The trial court considered Defendant's record of conviction without appointing counsel and summarily denied the petition. The Supreme Court reversed, holding (1) a petitioner is statutorily entitled to counsel, if requested, upon the filing of a facially sufficient petition, and section 1170.95, subdivision (c) describes only one prima facie showing; (2) a trial court can rely on the record of conviction in determining whether that single prima facie showing is made; and (3) the trial court's failure to appoint counsel to represent Defendant was state law error only, and the court of appeal shall determine on remand whether the error was prejudicial. View "People v. Lewis" on Justia Law
Posted in:
Criminal Law
People v. Dworak
The Supreme Court affirmed Defendant's conviction of one count each of murder and rape and his sentence of death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err in excluding defense evidence relating to third party culpability and victim character; (2) the trial court did not by admitting three photographs of the victim proffered by the prosecutor while excluding a booking photograph of the victim offered by Defendant; (3) the trial court did not abuse its discretion in excluding certain newspaper articles or evidence of other crimes; (4) the trial court did not err in permitting the prosecutor to elicit testimony from Defendant's wife and from the victim's father; (5) assuming the trial court's instruction pursuant to CALJIC No. 2.50.01 was erroneous, there was no prejudice; (6) the trial court did not abuse its discretion in denying Defendant discovery of a witness's medical records; (7) any error in the admission of evidence and regiment regarding Defendant's lack of remorse was harmless; (8) assuming that the prosecutor erred in her penalty phase argument, the error was not prejudicial; and (9) Defendant's challenges to his sentence were unavailing. View "People v. Dworak" on Justia Law
Ferra v. Loews Hollywood Hotel, LLC
The Supreme Court held that "regular rate of compensation" under Cal. Lab. Code 226.7(c), like "regular rate of pay" under Cal. Lab. Code 510(a), encompasses all nondiscretionary payments, such that the calculation of premium pay for a noncompliant meal, rest, or recovery period, like the calculation of overtime pay, must account for not only hourly wages but also for nondiscretionary payments for work performed by the employee.Plaintiff, who was employed by Defendant as a bartender, filed a class action suit alleging that Defendant, by omitting nondiscretionary incentive payments from its calculation of premium pay, failed to pay her for noncompliant meal or rest breaks in accordance with her "regular rate of compensation," as required by section 226.7(c). The trial court granted summary adjudication for Defendant, concluding that "regular rate of compensation" in section 226.7(c) is not interchangeable with the term "regular rate of pay" under section 510(a), which governs overtime pay. The court of appeal affirmed. The Supreme Court reversed, holding that the term “regular rate of compensation” in section 226.7(c) has the same meaning as “regular rate of pay” in section 510(a) and therefore encompasses all nondiscretionary payments for work performed by the employee, not just hourly wages. View "Ferra v. Loews Hollywood Hotel, LLC" on Justia Law
Posted in:
Labor & Employment Law