Justia California Supreme Court Opinion Summaries

The case involves Angelica A. (mother) and Luis C. (father), who have two children, Dezi C. and Joshua C. In 2019, the Los Angeles County Department of Children and Family Services (Department) filed petitions to assert dependency jurisdiction over the children due to the parents' substance abuse and domestic violence issues. Both parents denied having Indian heritage on their Parental Notification of Indian Status forms. The juvenile court initially found that ICWA did not apply based on the parents' denials. The children were removed from their parents' custody, and the parents were provided with reunification services, which were later terminated due to non-compliance. The court eventually terminated the parents' rights, concluding the children were adoptable by their paternal grandparents.The mother appealed the termination of her parental rights, arguing that the Department failed to comply with its duty under ICWA and related California provisions to inquire about the children's possible Indian ancestry from extended family members. The Court of Appeal acknowledged the Department's inquiry was deficient but concluded the error was harmless unless the record suggested a reason to believe the children might be Indian children.The California Supreme Court reviewed the case to resolve the conflict among lower courts regarding the standard for assessing prejudice from an inadequate ICWA inquiry. The Court held that an inadequate Cal-ICWA inquiry requires conditional reversal of the juvenile court's order terminating parental rights. The Department must conduct an adequate inquiry and document it properly. If the juvenile court finds the inquiry proper and concludes ICWA does not apply, the termination order will be reinstated. If ICWA applies, the court must proceed accordingly. The Court emphasized the importance of protecting tribal rights and ensuring compliance with ICWA and Cal-ICWA to determine whether a child is an Indian child. View "In re Dezi C." on Justia Law

Kenneth D. was born prematurely and tested positive for amphetamine and syphilis. His mother admitted to using methamphetamine during her pregnancy. The Placer County Department of Health and Human Services filed a juvenile dependency petition to remove Kenneth from his mother and her partner, T.D., due to suspected drug use. Initial inquiries about potential Native American heritage were made, but both mother and T.D. denied having any. Kenneth was placed in temporary custody.The Placer County Superior Court recognized T.D. as the presumed father based on a voluntary declaration of paternity and Kenneth’s birth certificate. Kenneth was adjudged a dependent and removed from the parents' custody. The court found that the Indian Child Welfare Act (ICWA) did not apply. Later, J.T. was confirmed as Kenneth’s biological father, but the court did not inquire about his potential Native American heritage. The court terminated parental rights and approved an adoption plan, again finding ICWA did not apply. J.T. appealed, arguing the failure to comply with ICWA’s inquiry and notice provisions.The California Supreme Court reviewed the case and held that, absent exceptional circumstances, an appellate court may not consider postjudgment evidence to conclude that an ICWA inquiry error was harmless. The court emphasized that the sufficiency of an ICWA inquiry must generally be determined by the juvenile court in the first instance. The Court of Appeal’s consideration of postjudgment evidence was deemed erroneous. The Supreme Court reversed the Court of Appeal’s judgment and directed a conditional reversal of the juvenile court’s order terminating parental rights, remanding the case for compliance with ICWA and California implementing statutes. View "In re Kenneth D." on Justia Law

Plaintiffs, employees of a hospital operated by Alameda Health System (AHS), alleged that AHS violated California labor laws by denying meal and rest breaks, failing to keep accurate payroll records, and not paying full wages. They sought civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA).The Alameda County Superior Court sustained AHS’s demurrer without leave to amend, concluding that AHS, as a public entity, was not subject to the Labor Code provisions cited by plaintiffs. The court also dismissed the PAGA claim, reasoning that public entities are not “persons” subject to PAGA penalties.The California Court of Appeal reversed in part, holding that AHS was not exempt from the meal and rest break requirements or the wage payment statutes. It distinguished AHS from state agencies, noting that the enabling statute indicated AHS was not an agency, division, or department of the county. However, the court agreed that AHS was exempt from the wage statement requirements and that it was not a “person” subject to default PAGA penalties.The California Supreme Court reversed the Court of Appeal’s judgment. It held that the Legislature intended to exempt public employers, including hospital authorities like AHS, from the Labor Code provisions governing meal and rest breaks and related wage payment statutes. The Court also concluded that public entities are not subject to PAGA penalties for the violations alleged. The case was remanded to the trial court to reinstate its ruling on the demurrer and conduct any further proceedings as appropriate. View "Stone v. Alameda Health System" on Justia Law

In June 2012, Maurice Walker assaulted a woman and a 78-year-old man in Los Angeles. Walker was convicted of assault with a deadly weapon, elder abuse, and misdemeanor battery. The jury found true the enhancement allegations that he used a deadly weapon and inflicted great bodily injury on an elderly person. Walker admitted to having prior strike convictions and a prior serious felony conviction. Initially, he was sentenced to 20 years in prison, which was later reduced to 19 years after one enhancement was struck in a habeas proceeding. Another habeas proceeding in 2018 led to the removal of his remaining prior prison term enhancement, and the case was remanded for potential resentencing.The Los Angeles County Superior Court conducted a full resentencing hearing in April 2022. Despite the new provisions of Penal Code section 1385, subdivision (c)(2), which favor dismissing enhancements under certain mitigating circumstances, the trial court declined to dismiss Walker’s enhancements. The court did not find it in the interest of justice to dismiss the enhancements, even though multiple enhancements were present. Walker appealed, arguing that the trial court misapplied section 1385.The California Supreme Court reviewed the case to resolve a conflict between appellate courts on the interpretation of section 1385, subdivision (c)(2). The court concluded that the statute does not create a rebuttable presumption in favor of dismissing an enhancement unless it endangers public safety. Instead, it requires trial courts to give significant weight to mitigating circumstances but allows them to consider other factors. The court affirmed the judgment of the Court of Appeal, finding that Walker was not entitled to relief under the clarified interpretation of the statute. View "P. v. Walker" on Justia Law

John’s Grill, Inc., a restaurant in San Francisco, suffered significant financial losses during the COVID-19 pandemic and sought compensation from its property insurer, Sentinel Insurance Company, Ltd. Sentinel denied the claim, stating that the losses did not fall under the policy’s “Limited Fungi, Bacteria or Virus Coverage” endorsement, which only covers virus-related losses if the virus results from specific causes like windstorms or water damage. John’s Grill argued that this limitation made the virus-related coverage illusory and unenforceable.The San Francisco City and County Superior Court sustained Sentinel’s demurrer, finding the policy language clear and enforceable. The court reasoned that the specified causes of loss could potentially cause virus damage, thus the coverage was not illusory. The Court of Appeal reversed, agreeing with John’s Grill that the specified cause of loss limitation rendered the virus coverage illusory, as the listed causes were not realistically related to virus transmission. The appellate court held that the policy’s promise of virus-related coverage was illusory and allowed John’s Grill’s claims to proceed.The Supreme Court of California reversed the Court of Appeal’s decision. The court held that the policy’s specified cause of loss limitation was clear and unambiguous, and thus enforceable. It concluded that John’s Grill did not have a reasonable expectation of coverage for pandemic-related losses under the policy. The court also determined that the illusory coverage doctrine, as articulated by John’s Grill, did not apply because the policy did offer a realistic prospect for virus-related coverage under certain conditions. The case was remanded for further proceedings consistent with this opinion. View "John's Grill, Inc. v. The Hartford Financial Services Group, Inc." on Justia Law

In June 2017, Scotlane McCune crashed a vehicle into a tree while driving without a license, injuring his passenger, Miguel Villa. McCune fled the scene, leading to charges of felony hit and run with injury and misdemeanor driving without a license. He pleaded no contest to the felony charge, and the misdemeanor was dismissed. In June 2018, McCune was placed on five years’ probation and ordered to pay restitution to Villa, with the amount to be determined later. In December 2020, Villa sought $30,166.23 in restitution. However, new legislation effective January 1, 2021, capped felony probation at two years, leading to the termination of McCune’s probation on January 14, 2021. The trial court later set the restitution amount at $21,365.94.McCune objected, arguing that the court lacked authority to set the restitution amount after his probation ended. The trial court disagreed, citing Penal Code sections 1202.4 and 1202.46, which allow the court to retain jurisdiction to determine restitution amounts until the victim’s losses are ascertainable. The Court of Appeal upheld this decision, stating that the court’s authority to fix restitution amounts persists even after probation ends, as per sections 1202.4 and 1202.46.The Supreme Court of California affirmed the Court of Appeal’s judgment. The court held that section 1202.46 applies to both probation and nonprobation cases, allowing the court to retain jurisdiction to set restitution amounts once the victim’s losses become ascertainable. The court rejected McCune’s argument that section 1203.3 limits this authority to the probation term, clarifying that section 1202.46 provides additional authority to ensure full victim restitution, consistent with the constitutional mandate. The court disapproved of contrary interpretations in Hilton v. Superior Court and People v. Waters. View "P. v. McCune" on Justia Law

Robert Ward Frazier was convicted by a jury of the murder, forcible rape, and forcible sodomy of Kathleen Loreck. The jury also found true two felony-murder special-circumstance allegations. At the penalty phase, the jury returned a death verdict, which the trial court upheld, sentencing Frazier to death. Frazier's appeal is automatic.The trial court excused a prospective juror for cause due to his views on the death penalty, denied Frazier's request for individually sequestered voir dire, and gave a jury instruction on flight from the scene of a crime. The court also denied Frazier's requests to represent himself during the penalty phase and post-verdict proceedings, including the hearing on his automatic motion to modify the death verdict and sentencing.The California Supreme Court affirmed the trial court's decisions. The court held that the trial court did not err in excusing the prospective juror, as substantial evidence supported the finding that the juror's views would substantially impair his performance. The court also found no error in denying individually sequestered voir dire, as there is no federal constitutional requirement for such in capital cases, and the trial court did not abuse its discretion under state law.The court upheld the flight instruction, finding sufficient evidence to support it and rejecting Frazier's additional arguments against the instruction. The court also ruled that Frazier's requests for self-representation were untimely and that the trial court did not abuse its discretion in denying them. Finally, the court rejected Frazier's claim that his Sixth Amendment right to choose the objective of his defense was violated by the presentation of certain mitigating evidence over his objection. View "P. v. Frazier" on Justia Law

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