Justia California Supreme Court Opinion Summaries

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

In this wrongful death action, the Supreme Court affirmed the judgment of the court of appeal determining that a minor's eighteenth birthday is excluded in calculating when the statute of limitations begins to run, holding that an individual's eighteenth birthday is excluded when calculating the applicable limitations period.Plaintiff brought this lawsuit against the City of Fontana and several of its police officers (collectively, Defendants) under 42 U.S.C. 1983 alleging that one of the officers wrongfully shot and killed his father. Plaintiff was a minor at the time of his father's death. The trial court ruled that the claim was time-barred because Plaintiff filed suit one day outside the two-year limitations period and that Plaintiff's eighteenth birthday must be included in calculating the limitations period. The court of appeal reversed, ruling that Plaintiff's eighteenth birthday should have been excluded pursuant to Code of Civil Procedure section 12. The Supreme Court affirmed, holding (1) in cases in which the statute of limitations is tolled bad on a plaintiff's minor age, the day after tolling ends is excluded in calculating whether an action is timely filed; and (2) Plaintiff's lawsuit in this case was timely filed. View "Shalabi v. City of Fontana" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal in this case involving allegations of active gang participation and gang enhancements attached to other offenses, holding that the commission of two or more predicate offenses must be proven by independent admissible evidence, and such proof may not be established solely by the testimony of an expert who has no personal knowledge of facts otherwise necessary to satisfy the prosecution's burden.The two defendants in this case were charged with two counts of attempted murder, assault with a firearm, and active street gang participation. Gang and firearm enhancements were attached to the charges. The first trial ended when the jury hung on almost all charges, but a second jury convicted Defendants of the remaining allegations. The court of appeal reversed the active gang participation and enhancement allegations, as well as Defendant's firearm enhancements attached to those allegations, and otherwise affirmed, holding that some of an expert's testimony constituted inadmissible hearsay. The Supreme Court affirmed, holding (1) the jury was permitted to improperly rely on hearsay to conclude that the predicate offenses had been proven and that Defendants acted with intent to benefit a gang when they committed the crimes with which they were charged; and (2) the error was not harmless. View "People v. Valencia" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of kidnapping and killing Shirley and Andrew Demko after burglarizing and robbing their home, holding that there was no error in the proceedings below.On appeal, Defendant raised numerous allegations of error both during the guilt phase and the penalty phase. The Supreme Court rejected the claims and affirmed the judgment in its entirety, holding (1) the trial court did not err in denying Defendant's Batson/Wheeler motion upon finding that the prosecutor did not make a prima facie showing that the prosecutor exercised a peremptory challenge in a discriminatory manner; (2) assuming, without deciding, that the trial court erred in admitting statements that Defendant identified as implicating prior burglaries, any error was harmless as a matter of law; and (3) there were no penalty phase errors and no cumulative prejudice to consider. View "People v. Battle" on Justia Law

The Supreme Court held that capacity or willingness to accept treatment is a relevant factor to be considered on the issue of grave disability but is not a separate element that must be proven to establish a conservatorship.Under the Lanterman-Petris-Short Act, Cal. Welf. & Inst. Code 5000 et seq., those subject to a conservatorship petition are entitled to a court or jury trial to decide if they are "gravely disabled." At issue was whether the trier of fact must additionally find that the individual is unwilling or unable to accept treatment voluntarily. The jury in this case found that K.P. was gravely disabled and granted a petition to renew K.P.'s conservatorship. The court of appeal affirmed. On appeal, K.P. claimed that a finding of unwillingness or inability to accept voluntary treatment was required for a conservatorship to be established. The Supreme Court affirmed, holding that inability or unwillingness to accept voluntary treatment need not be separately proven at trial. View "Conservatorship of K.P." on Justia Law

The Supreme Court reversed the order of the court of appeal denying a certificate of appealability in this case, holding that under the law as amended by Proposition 66 the requirement that habeas corpus petitioners must make a showing of actual innocence or death ineligibility if they seek a second chance to make an argument they could have made earlier does not apply to the habeas petition who raises a newly available claim at the first opportunity.Petitioner was convicted of a robbery murder and sentenced to death. In 2015, the Supreme Court denied Petitioner's habeas corpus petition. Petitioner then filed a federal habeas petition in the federal district court, which stayed proceedings to allow Petitioner to exhaust six claims in state court. Thereafter, Proposition 66 came into force. In 2018, Petitioner filed a second state habeas petition raising the six unexhausted claims. The state court dismissed Petitioner's recently filed habeas petition as successive. The court of appeals denied Petitioner's request for a certificate of appealability. The Supreme Court reversed, holding that Proposition 66 should be read to provide a means for appealing the superior court's determination that a subsequent petition is successive. View "In re Friend" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the judgment of the trial court imposing an additional three-year term of imprisonment for a great bodily injury enhancement, holding that the act of furnishing a controlled substance is not by itself sufficient to establish that the defendant "personally inflict[ed]" great bodily injury.A jury convicted Defendant of offering a controlled substance to a minor and furnishing or giving away a controlled substance to a minor. The jury also sustained the allegation that Defendant personally inflicted great bodily injury upon his girlfriend, who died from fentanyl intoxication, within the meaning of Cal. Penal Code 12022.7, subdivision (a). The trial court sentenced Defendant to nine years in prison, plus an additional three years for the great bodily injury enhancement. The court of appeal affirmed. The Supreme Court reversed and remanded the case, holding that the trial court erred as a matter of law by precluding defense counsel from arguing that, in light of the girlfriend's voluntary ingestion of the controlled substance, the facts did not support a great bodily injury enhancement. View "People v. Ollo" on Justia Law

The Supreme Court reversed the decision of the court of appeal concluding that Defendant's case was final because Defendant could have appealed his sentence when it was imposed, holding that when a defendant is placed on probation with execution of an imposed state prison sentence suspended the case is not yet final if the defendant may still timely obtain direct review of an order revoking probation and causing the state prison sentence to take effect.Defendant pleaded no contest to a felony. In 2015, the trial court suspended him. In 2018, the court found Defendant in violation of a condition of probation and ordered the sentence to take effect. During the pendency of Defendant's appeal, the Legislature amended the provision under which the trial court had imposed two one-year enhancements. The parties agreed that the amendment applies to all cases that were not final when the legislation took effect but disagreed as to whether Defendant's case was final. The court of appeals held that it was. The Supreme Court reversed, holding that legislation ameliorating punishment presumptively applies to suspended execution cases pending on appeal from an order causing a previously imposed sentence to take effect. View "People v. Esquivel" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of assault and robbery, holding that there was no constitutional violation in the trial court's providing the jury with an instruction modeled on CALCRIM No. 315 that listed fifteen factors the jury should consider when evaluating eyewitness identification evidence.The instruction in this case listed as a factor the jury should consider when evaluating eyewitness identification evidence how "certain" the witness was when he or she made an identification. On appeal, Defendant argued that the certainty instruction violated his state and federal due process rights to a fair trial because research shows that a witness's confidence in an identification is generally not a reliable indicator of accuracy. The Supreme Court affirmed, holding that listing the witness's level of certainty as one of the factors the jury should consider when evaluating identification testimony did not render Defendant's trial fundamentally unfair. However, given the significance that witness certainty plays in the fact-finding process, the Court referred the matter to the Judicial Council to evaluate whether the instruction might be modified to avoid juror confusion regarding the correlation between certainty and accuracy. View "People v. Lemcke" on Justia Law

The Supreme Court reversed the decision of the court of appeal reversing the judgment of the trial court that Mother had established one of a series of enumerated exceptions to avoid termination of parental rights, holding that the court of appeals erred in its analysis.The trial court in this case found that Child was likely to be adopted but that Mother had established the parental-benefit exception precluding termination of parental rights. The court therefore declined to terminate parental rights and ordered that Child remain in foster care subject to periodic review. The court of appeal reversed, concluding that because Mother continued to struggle with mental health issues and substance abuse and because the benefits of the potential adoptive home and the risks of foster care, a reasonable court could not find that Child's relationship with Mother outweighed the benefits of adoption. The Supreme Court reversed, holding that the court of appeal's holding that no reasonable court could apply the parental-benefit exception given Mother's substance abuse and mental health issues was in error. View "In re Caden C." on Justia Law