Justia California Supreme Court Opinion Summaries

In this negligence action, the Supreme Court affirmed the judgment of the court of appeal affirming the trial court's decision to dismiss one of several named defendants, the United States Olympic Committee (USOC), for failure to adequately allege a special relationship giving rise to an affirmative duty to protect, holding that the court of appeals did not err.Plaintiffs, former athletes who trained in the Olympic sport of taekwondo, filed this suit against their former coach, Marc Gitelman, and several others, alleging, among other things, that USOC and USA Taekwondo (USAT) were negligent in failing to protect them from Gitelman's sexual abuse. USOC and USAT both demurred to the complaint, contending that Plaintiffs had not adequately alleged that they had an affirmative duty to take action to protect Plaintiffs from Gitelman's abuse. The trial court sustained the demurrers and entered judgments of dismissal. The court of appeal reversed as to USAT but affirmed as to USOC. The Supreme Court affirmed, holding that the court of appeal did not err by declining to apply the factors set out in Rowland v. Christian, 69 Cal. 2d 108 (1968), as an alternative source of duty. View "Brown v. USA Taekwondo" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that Cal. Penal Code 632.7 applies only to nonparties and does not forbid a party to a phone call transmitted to or from a cellular or cordless telephone from recording the conversation without the consent of the other party or parties, holding that section 632.7 applies to parties as well as nonparties.Setion 632.7(a) makes it a crime when a person, "without consent of all parties to a communication," intercepts or intentionally records a communication transmitted between a cellular or cordless telephone and another telephone. At issue was whether the statute is concerned only with recording by persons other than parties, or nonparties, to the communication. The Supreme Court held that the statute applies to parties as well as nonparties that that recording a communication without the speaker's consent is unlawful, regardless of whether a party or someone else is performing the recording. View "Smith v. LoanMe, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeal reversing the trial court's ruling granting Defendant's motion to strike Plaintiffs' prevailing wage allegations, holding that Plaintiffs' belt sorting qualified as "public works" Cal. Labor Code 1720, subd.(a)(2).Plaintiffs were contract workers who acted as belt sorters for a county sanitation district. Plaintiffs brought a class action suit alleging failure to (1) pay minimum and/or prevailing wages, (2) pay overtime at prevailing wage rates, (3) provide meal periods, and (4) pay all wages owed at the time of termination. At issue was whether Plaintiffs' work fell within the definition of public works in section 1720(a)(2) entitling them to prevailing wage compensation. The trial court granted Defendant's motion to strike. The court of appeals reversed, concluding that Plaintiffs' labor qualified as public work under section 1720(a)(2). The Supreme Court affirmed, holding that the court of appeals did not err. View "Kaanaana v. Barrett Business Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeal concluding that Petitioner was entitled to a new bail hearing, holding that the common practice of conditioning freedom solely on whether an arrestee can afford bail is unconstitutional.The trial court set Petitioner's bail at $350,000 without commenting on Petitioner's inability to afford bail. Petitioner filed a petition for writ of habeas corpus claiming that requiring money bail as a condition of release at an amount he could not pay was the functional equivalent of a pretrial detention order and requesting immediate release or a new bail hearing. The court of appeals reversed the bail order because the trial court failed to determine whether Petitioner could feasibly post bail. On remand, the superior court conducted a new bail hearing and ordered Petitioner released on various non-financial conditions. The Supreme Court affirmed, holding (1) where a financial condition is necessary, the court must consider the arrestee's ability to pay the stated amount of bail and may not detain the arrestee solely because the arrestee lacked the resources to post bail; and (2) Petitioner was entitled to a new bail hearing. View "In re Humphrey" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court granting a class injunctive relief, holding that Insurer was not entitled to immunity under the Insurance Code and that the Insurance Commission did not have exclusive jurisdiction.At issue was whether, if a title insurer charges rates without filing them with the Insurance Commissioner, a consumer can challenge the charges as unlawful in court. The trial court rejected Insurer's argument that it should be held immune from Plaintiff's putative class action under Cal. Ins. Code 12414.26, but the court of appeals reversed, concluding that the class claims were barred because Insurer was in fact immune and that the trial court lacked jurisdiction. The Supreme Court reversed, holding (1) the statutory immunity for "act[s] done...pursuant to the authority conferred" by the rate-filing statutes does not shield title insurers from suit for charging unauthorized rates; and (2) the Insurance Commissioner does not have exclusive jurisdiction over unfiled-rate claims. View "Villanueva v. Fidelity National Title Co." on Justia Law

The Supreme Court decided two questions of law related to meal periods for employees and, in light of its holdings, reversed the judgment of the court of appeals.Plaintiff filed a class action lawsuit against Defendant alleging various wage and hour violations, including that meal period claim at issue on this appeal. The trial court granted summary judgment for Defendant, and the court of appeals affirmed. The Supreme Court reversed and remanded the case for further proceedings consistent with this opinion, holding (1) an employer cannot engage in the practice of adjusting the hours that an employee has actually worked to the nearest present time increment in the meal period context; and (2) time records showing noncompliant meal periods raise a rebuttable presumption of meal period violations, including at the stage of summary judgment. View "Donohue v. AMN Services, LLC" on Justia Law

The Supreme Court upheld Senate Bill 1391 as a permissible amendment to Proposition 57 and reversed the judgment in the case, holding that the Legislature acted within its authority.Proposition 57, which was passed in the November 2016 general election, allowed prosecutors to move to transfer some minors as young as fourteen years old from juvenile court to adult criminal court. Senate Bill 1391, enacted in 2018, amended Proposition 57 to prohibit minors under the age of sixteen from being transferred to adult criminal court. The court of appeal held that Senate Bill 1391 was invalid because it was inconsistent with Proposition 57. The Supreme Court reversed, holding that the amendment was fully consistent with and furthered Proposition 57's purposes of promoting rehabilitation of youthful offenders and reducing the prison population, and therefore, Senate Bill 1391 was a constitutional amendment to Proposition 57. View "O.G. v. Superior Court" on Justia Law

The Supreme Court affirmed Defendant's conviction for five counts of murder, one count of residential burglary, and three counts of residential robbery with enhancements for personal use of a firearm and Defendant's death sentence, holding that there was no reasonable possibility that any assumed error could have affected the verdict.Specifically, the Supreme Court assumed potential errors in the trial court's failure to admonish support persons each time they accompanied a witness and in admitting hearsay during the penalty phase of trial. The Court, however, found no reasonable possibility that either assumed error could have affected the verdict. The Court further concluded that no cumulative prejudice rendered Defendant's trial unfair and therefore affirmed Defendant's convictions and his sentence of death. View "People v. Chhoun" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and sentence of death, holding that any errors, found or assumed, were not prejudicial.Specifically, the Supreme Court held (1) at the guilt phase, assuming that the trial court erred in admitting certain DNA evidence, the error was not prejudicial; (2) at the penalty phase, assuming the trial court erred in admitting evidence of potential animal abuse, the error was not prejudicial; (3) any error in imposing a parole revocation fine was harmless; (4) even when viewed in combination, the guilt phase and penalty phase errors were not prejudicial; and (5) the abstract of judgment reflected a clerical error, which will be corrected. View "People v. Baker" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder, attempted murder, and other offenses, and sentencing Defendant to death, holding that any errors that occurred during the trial proceedings were not prejudicial.Specifically, the Supreme Court held (1) during the guilt phase, there was error with respect to the prosecutor's misstatement of the reasonable doubt standard and with respect to defense counsel's agreement with the prosecutor on a certain point of law, but there was no reasonable probability that the prosecutor's or defense counsel's misstatements were prejudicial; (2) at the penalty phase, the prosecutor's comment about Defendant during penalty phase arguments bordered on "inflammatory" rhetoric, but any error was not prejudicial; and (3) the cumulative effect of these errors did not rise to the level of prejudice necessary to reverse Defendant's conviction or sentence. View "People v. Johnsen" on Justia Law