Justia California Supreme Court Opinion Summaries

Wilson next argues that the trial court erred in admitting statements he made to detectives after the break when he was outside smoking with Detective Hagen. As Wilson notes, Detective Hagen agreed to end the interview in response to Wilson’s statement that he was not going to discuss the case further and request to be taken back to the holding cell. These circumstances reflect Wilson’s unambiguous invocation of his right to remain silent. (People v. Krebs, supra, 8 Cal.5th at p. 313 [defendant’s invocation was unambiguous when he asked to be returned to his cell and told officers he had nothing to say].) Despite recognizing that Wilson no longer wished to speak, Detective Hagen made additional comments that were reasonably likely to prompt Wilson to continue speaking: He encouraged Wilson to cooperate “right now” to get beneficial treatment before his “partner” did, and he stated that he had “[n]o doubt [Wilson] did it.”However, the trial court found that Wilson reinitiated the conversation during the cigarette break, and substantial evidence supports this finding. Detective Hagen testified that Wilson began discussing the case again during the break, expressing concerns about his family’s safety and asking questions about the investigation. This testimony indicates that Wilson voluntarily chose to resume the conversation, thereby waiving his previously invoked right to remain silent. The trial court’s credibility determinations and factual findings are supported by substantial evidence, and we defer to those findings.Given these circumstances, the trial court did not err in admitting the statements Wilson made to the California detectives after the cigarette break. Wilson’s reinitiation of the conversation and his voluntary engagement in the subsequent interview indicate that his statements were not the product of coercion or improper interrogation tactics. Therefore, the admission of these statements did not violate Wilson’s Fifth Amendment rights. View "P. v. Wilson" on Justia Law

The case involves three Lyft drivers, Tina Turrieta, Brandon Olson, and Million Seifu, who each filed separate lawsuits under the California Labor Code Private Attorneys General Act of 2004 (PAGA) against Lyft, Inc. for alleged labor violations. Turrieta settled her case with Lyft, but before the settlement was approved, Olson and Seifu sought to intervene and object to the settlement, arguing it was unfair and that they had overlapping claims. The trial court denied their motions to intervene, approved the settlement, and later denied their motions to vacate the judgment.Olson and Seifu appealed the trial court's decisions. The Court of Appeal affirmed the trial court's rulings, holding that Olson and Seifu lacked standing to intervene or to challenge the settlement because they were not aggrieved by the judgment. The appellate court reasoned that PAGA actions are representative actions on behalf of the state, and thus, Olson and Seifu did not have a personal interest in the settlement of Turrieta’s PAGA claim.The California Supreme Court reviewed the case and agreed with the Court of Appeal. The Supreme Court held that PAGA does not authorize one aggrieved employee to intervene in another employee’s PAGA action asserting overlapping claims. The Court reasoned that allowing such intervention would be inconsistent with the statutory scheme of PAGA, which provides for oversight of settlements by the Labor and Workforce Development Agency (LWDA) and the courts, but does not mention intervention by other PAGA plaintiffs. The Court emphasized that the statutory language and legislative history indicate that the Legislature intended for the LWDA and the courts to ensure the fairness of PAGA settlements, not other PAGA plaintiffs.The Supreme Court affirmed the judgment of the Court of Appeal, concluding that Olson and Seifu did not have the right to intervene, object to, or move to vacate the judgment in Turrieta’s PAGA action. View "Turrieta v. Lyft, Inc." on Justia Law

Deandre Lynch was convicted of three counts of domestic violence resulting in a traumatic condition and one count of simple assault. The trial court imposed an upper term sentence based on eight aggravating circumstances, including Lynch's use of a weapon and his prior convictions. The court cited Lynch's criminal history and the severity of his actions as reasons for the upper term sentence.The Court of Appeal affirmed the upper term sentence, finding that two of the aggravating circumstances were proven in compliance with the current law, but the remaining six were not. The court applied a "reasonably probable" standard to determine that the failure to satisfy the current statute was harmless error.The California Supreme Court reviewed the case to determine the appropriate standard for remanding cases for resentencing under the amended Penal Code section 1170(b). The court held that a sentence imposed under the former version of section 1170(b) must be reversed and remanded unless the reviewing court concludes beyond a reasonable doubt that a jury would have found true all of the aggravating facts upon which the trial court relied to justify the upper term sentence, or that those facts were otherwise proven in compliance with the current statute.The court concluded that Lynch's sentence must be reversed and remanded for resentencing because the trial court relied on aggravating facts that were not proven beyond a reasonable doubt by a jury. The court also applied the Gutierrez standard, which requires a remand unless the record clearly indicates that the trial court would have imposed the same sentence even if it had been aware of its more limited discretion under the current law. The court found that the record did not clearly indicate that the trial court would have imposed the same sentence under the new law. View "P. v. Lynch" on Justia Law

In May 2019, the City of Sunnyvale Department of Public Safety imposed a 44-hour suspension on Officer David Meinhardt, which was upheld by the City of Sunnyvale Personnel Board. Meinhardt challenged the suspension by filing a petition for writ of administrative mandate in the Santa Clara County Superior Court. On August 6, 2020, the court issued an order denying the petition. Subsequently, on September 25, 2020, a formal judgment was entered, and Meinhardt filed a notice of appeal on October 15, 2020.The Fourth Appellate District, Division One, dismissed the appeal as untimely, concluding that the August 6 order was the final judgment from which Meinhardt should have appealed. The court reasoned that the order denied the petition in its entirety and did not contemplate further action, thus starting the 60-day period for filing an appeal.The Supreme Court of California reviewed the case to resolve the uncertainty about when the time to appeal starts in writ of administrative mandate proceedings. The court held that the time to appeal begins with the entry of a "judgment" or the service of notice of entry of "judgment," rather than with the filing of an "order" or other ruling. This decision was based on the plain language of relevant statutes and rules, which contemplate the entry of a "judgment," and the policy of providing clear jurisdictional deadlines to avoid inadvertent forfeiture of the right to appeal. The court reversed the judgment of the Court of Appeal, concluding that Meinhardt's notice of appeal was timely filed within 60 days of the entry of the September 25 judgment. View "Meinhardt v. City of Sunnyvale" on Justia Law

Twanda Bailey, an African-American employee, sued the San Francisco District Attorney’s Office, former District Attorney George Gascon, and the City and County of San Francisco for racial harassment and retaliation under the California Fair Employment and Housing Act (FEHA). Bailey alleged that a coworker called her the N-word, and after reporting the incident, the human resources manager obstructed her complaint, engaged in intimidating conduct, and threatened her.The San Francisco City and County Superior Court granted summary judgment for the City, finding that Bailey failed to make a prima facie case for her FEHA claims. The trial court concluded that a single racial slur by a coworker did not constitute severe or pervasive harassment and that Bailey did not suffer an adverse employment action. The Court of Appeal affirmed the trial court’s decision.The Supreme Court of California reviewed the case and held that an isolated act of harassment, such as the use of an unambiguous racial epithet like the N-word, can be actionable if it is sufficiently severe under the totality of the circumstances. The Court emphasized that the severity of harassment should be judged from the perspective of a reasonable person in the plaintiff’s position. The Court also held that a course of conduct that effectively withdraws an employee’s means of reporting and addressing racial harassment can constitute an adverse employment action. The Court found that there were triable issues of fact regarding both Bailey’s harassment and retaliation claims and reversed the judgment of the Court of Appeal, remanding the case for further proceedings. View "Bailey v. San Francisco District Attorney's Office" on Justia Law

Peter Quach filed a lawsuit against California Commerce Club (Commerce Club) after being terminated from his job at the casino where he had worked for nearly 30 years. Quach's complaint included claims of wrongful termination, age discrimination, retaliation, and harassment, and he demanded a jury trial. Commerce Club had previously provided Quach with a signed arbitration agreement from 2015, which mandated binding arbitration for employment-related disputes. Instead of moving to compel arbitration, Commerce Club answered the complaint and engaged in extensive discovery, including propounding interrogatories and taking Quach’s deposition.The Los Angeles County Superior Court denied Commerce Club’s motion to compel arbitration, finding that Commerce Club had waived its right to arbitrate by engaging in litigation for 13 months. The court noted that Commerce Club had actively participated in discovery and requested a jury trial, actions inconsistent with an intent to arbitrate. Commerce Club appealed, and the Second Appellate District, Division One, reversed the trial court’s decision, holding that Quach had not shown sufficient prejudice from Commerce Club’s delay in seeking arbitration.The Supreme Court of California reviewed the case and abrogated the state’s arbitration-specific prejudice requirement, aligning with the U.S. Supreme Court’s decision in Morgan v. Sundance, Inc. The court held that under California law, as under federal law, courts should apply the same principles to determine waiver of the right to compel arbitration as they do for other contracts. The court concluded that Commerce Club had waived its right to compel arbitration by engaging in litigation conduct inconsistent with an intent to arbitrate. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings consistent with this decision. View "Quach v. Cal. Commerce Club, Inc." on Justia Law

The case involves Business and Professions Code section 7451, enacted through Proposition 22, which classifies app-based drivers for companies like Uber, Lyft, and DoorDash as independent contractors rather than employees, provided certain conditions are met. This classification exempts these drivers from California workers’ compensation laws, which typically apply to employees. Plaintiffs, including several individuals and unions, argue that section 7451 conflicts with article XIV, section 4 of the California Constitution, which grants the Legislature plenary power to create and enforce a complete system of workers’ compensation.The Alameda County Superior Court found Proposition 22 unconstitutional, reasoning that it improperly limited the Legislature’s power to govern workers’ compensation, a power deemed "unlimited" by the state Constitution. The court held that the people must amend the Constitution through an initiative constitutional amendment, not an initiative statute, to impose such limitations. Consequently, the court invalidated Proposition 22 in its entirety.The California Court of Appeal reversed the lower court’s decision, holding that article XIV, section 4 does not preclude the electorate from using its initiative power to legislate on workers’ compensation matters. The court reasoned that the Legislature’s power under article XIV, section 4 is not exclusive and that Proposition 22 does not conflict with this constitutional provision. The court did, however, affirm the invalidation of certain severable provisions of Proposition 22 not at issue in this appeal.The California Supreme Court affirmed the Court of Appeal’s judgment, agreeing that section 7451 does not conflict with article XIV, section 4. The court held that the Legislature’s plenary power under article XIV, section 4 is not exclusive and does not preclude the electorate from enacting legislation through the initiative process. The court did not address whether other provisions of Proposition 22 improperly constrain the Legislature’s authority, as those issues were not presented in this case. View "Castellanos v. State of California" on Justia Law

Jayde Downey was on the phone with her daughter, Malyah Jane Vance, giving driving directions when Vance was severely injured in a car crash. Downey heard the collision and its immediate aftermath but could not see what caused it. She claims the crash was partly due to the condition of the roadway and sued the City of Riverside and the owners of adjacent private property for negligent infliction of emotional distress.The Riverside County Superior Court sustained the defendants' demurrers without leave to amend, agreeing that Downey could not claim emotional distress damages because she was not aware of the defendants' role in causing the crash at the time it occurred. The Court of Appeal affirmed, holding that Downey needed to show contemporaneous awareness of the causal connection between the defendants' negligence and her daughter's injuries.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that for purposes of emotional distress recovery, it is sufficient for a plaintiff to be aware of an event that is injuring the victim, not necessarily the defendant’s role in causing the injury. The court emphasized that the requirement is awareness of the injury-producing event, not the specific negligent conduct of the defendant. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings. View "Downey v. City of Riverside" on Justia Law

Plaintiff Katherine Rosenberg-Wohl procured a homeowners insurance policy from State Farm Fire and Casualty Company, which covered various risks including fire. After her neighbor fell on her staircase, she discovered the stairs needed replacement and filed a claim with State Farm. The insurer denied her claim, citing policy exclusions. Rosenberg-Wohl then filed two lawsuits: one for breach of contract and another under the Unfair Competition Law (UCL), seeking declaratory and injunctive relief regarding State Farm’s general claims-handling practices.The San Francisco City and County Superior Court sustained State Farm’s demurrer, concluding that the one-year limitations period in the insurance policy applied to all of Rosenberg-Wohl’s claims, including her UCL claim. The court reasoned that her claims were essentially “on the policy” because they were grounded in the denial of her insurance claim. The Court of Appeal affirmed this decision, with a majority agreeing that the one-year limitations period applied, while a dissenting justice argued that the UCL’s four-year limitations period should govern.The Supreme Court of California reviewed the case and concluded that the one-year limitations period in section 2071 of the Insurance Code and the insurance policy did not apply to Rosenberg-Wohl’s UCL cause of action. The court determined that her lawsuit was not a “suit or action on [the] policy for the recovery of any claim” because she sought only declaratory and injunctive relief, not a financial recovery under the policy. The court emphasized that the UCL’s four-year statute of limitations governed her claim. Consequently, the Supreme Court reversed the judgment of the Court of Appeal and remanded the matter for further proceedings consistent with its opinion. View "Rosenberg-Wohl v. State Farm Fire & Casualty Co." on Justia Law

A former employee sued her employer, Charter Communications, Inc., alleging discrimination, harassment, and retaliation under the Fair Employment and Housing Act (FEHA), as well as wrongful discharge. Charter moved to compel arbitration based on an agreement the employee had signed during the onboarding process. The employee opposed, arguing the arbitration agreement was procedurally and substantively unconscionable.The Los Angeles County Superior Court found the agreement to be a contract of adhesion and substantively unconscionable due to provisions that shortened the time for filing claims, allowed Charter to recover attorney fees contrary to FEHA, and imposed an interim fee award for compelling arbitration. The court refused to enforce the agreement, finding it permeated with unconscionability. The Second Appellate District, Division Four, affirmed, identifying additional unconscionable provisions and disagreeing with another appellate decision regarding interim fee awards.The Supreme Court of California reviewed the case and agreed that certain provisions of the arbitration agreement were substantively unconscionable, including the lack of mutuality in covered and excluded claims, the shortened limitations period for filing claims, and the potential for an unlawful award of attorney fees. The court clarified that the discovery limitations were not unconscionable, as the arbitrator had the authority to order additional discovery if necessary.The Supreme Court held that the agreement's unconscionable provisions could potentially be severed, and the matter was remanded for further consideration of whether the unconscionable provisions could be severed to enforce the remainder of the agreement. The court also concluded that the Court of Appeal’s decision did not violate the Federal Arbitration Act. View "Ramirez v. Charter Communications, Inc." on Justia Law