Justia California Supreme Court Opinion Summaries

In this case where Plaintiff selected the remedy of restitution under the Song-Beverly Consumer Warranty Act, Cal. Civ. Code 1790 et seq. after Mercedes-Benz USA LLC (Mercedes) was unable to repair defects in the vehicle Plaintiff leased from Mercedes the Supreme Court held that Mercedes was required to reimburse vehicle registration renewal and nonoperation fees Plaintiff paid if the fees were incurred as a result of Mercedes' breach of its duty to promptly provide a replacement vehicle or restitution.At issue was whether the Act required Mercedes to reimburse the vehicle registration renewal and nonoperation fees Plaintiff paid after the initial lease of his vehicle either as collateral charges or as incidental damages. The trial court excluded the vehicle registration renewal fees and the nonoperation fee from the restitution award. The court of appeals affirmed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the fees at issue were not recoverable as collateral charges because they were not auxiliary to and did not supplement the price paid for the vehicle; but (2) the fees were recoverable as incidental damages if they were incurred as a result of the manufacturer's breach of its duty to promptly provide a replacement vehicle or restitution under the Act. View "Kirzhner v. Mercedes-Benz USA, LLC" on Justia Law

The Supreme Court answered a question from the United States Court of Appeals for the Ninth Circuit regarding which presumption governs the characterization of joint tenancy property in a dispute between a couple and the bankruptcy trustee of one of the spouses.The Supreme Court held (1) Cal. Evid. Code 662 does not apply when it conflicts with the Cal. Fam. Code 760 community property presumption; (2) when a married couple uses community funds to acquire property with joint tenancy title on over after January 1, 1975 the property is presumptively community property under Cal. Fam. Code 760 in a dispute between the couple and a bankruptcy trustee, and for properly purchased before January 1, 1975, the presumption is that separate property interests arise from joint tenancy title; and (3) joint tenancy titling of property acquired by spouses using community funds on or after January 1, 1985 is not sufficient by itself to transmute community property into separate property. View "Speier v. Brace" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming Defendant's sentence in connection with his convictions for several offenses, including five counts of second degree robbery, holding that the trial court erred in imposing five twenty-five-year-to-life enhancements in connection with counts as to which the enhancements had not been alleged.As to each of the five counts of second degree robbery, the information alleged personal firearm use enhancements. After the close of the evidence, however, the trial court instructed the jury on a set of more serious firearm enhancements based on the theory that Defendant was vicariously responsible for a coparticipant's harmful discharge of a firearm. None of the vicarious firearm discharge enhancements had been alleged in connection with the robbery counts. The jury returned true findings. The trial court enhanced Defendant's sentence for the robberies by five consecutive additional terms of twenty-five years to life. The court of appeal affirmed. The Supreme Court reversed, holding that the trial court committed a pleading error because Defendant did not receive adequate notice that the prosecution was seeking to impose additional punishment on the robbery counts, and the error was not harmless. View "People v. Anderson" on Justia Law

The Supreme Court answered a question posed by the Court of Appeals for the Ninth Circuit regarding the time gap between the denial of a petition for a writ of habeas corpus in a lower California court and the filing of a new petition in a higher California court raising the same claims for purposes of determining whether a claim was timely presented.The Court summarized the procedures relevant to gap delay and then answered that, during the process, the delay between the filing of a habeas corpus petition challenging a state court judgment in a high court after the lower court denied relief is relevant to the overall question of timeliness of the claims presented in the petition, but no specific time limits exist. Specifically, delay of up to 120 days would not be considered substantial delay and would not alone make the claim untimely if the petition had otherwise presented the claim without substantial delay. Gap delay of more than 120 days is not automatically considered substantial delay but is a relevant factor in a court's analysis under In re Robbins, 18 Cal.4th, 770 (1998). View "Robinson v. Lewis" on Justia Law

The Supreme Court granted the emergency petition filed by the Legislature for a peremptory writ of mandate seeking relief from redistricting deadlines set by California law in light of the delay of census data collection and processing, holding the Legislature was entitled to a one-time adjustment to the deadlines.Under California law, the Citizens Redistricting Commission has the task of redistricting and draws new maps based on the federal census data. As a result of the COVID-19 pandemic, the federal Census Bureau delayed census data collection and processing. Consequently, the data required to draw new district maps would not be released to states in time for the Commission to meet the redistricting deadlines. The Supreme Court issued a peremptory writ of mandate directing the Commission to release the first preliminary statewide maps for public display and comment no later than November 1, 2021, notwithstanding Cal. Gov't Code 8253, subdivision (a)(7), and directing the Commission to approve and certify the final statewide maps by no later than December 15, 2021. View "Legislature of State of California v. Padilla" on Justia Law

In this inverse condemnation action, the Supreme Court affirmed the judgment of the court of appeal reversing the judgment of the trial court, holding that the trial court erred in borrowing section 1260.040 from the Eminent Domain Law and using to it making a dispositive pretrial ruling on inverse condemnation liability.The public entity defendants in this inverse condemnation action asked the trial court to use Cal. Code Civ. P. 1260.40, which authorizes a pretrial motion for a ruling on "an evidentiary or other legal issue affecting the determination of compensation," in inverse condemnation procedure. The trial court granted the motions and entered judgment in the defendants' favor. The court of appeals reversed, concluding that the procedure at issue did not meaningfully supplement existing pretrial procedures governing a summary judgment motion. Supreme Court affirmed, holding (1) this Court declines to import section 1260.070 into inverse condemnation procedure; and (2) the trial erred in entering judgment on the defendants' "Motion for Legal Determination of Liability," holding that the trial court erred in using the procedures because the summary judgment statute was available for that purpose, and any disputes could have been resolved in a bench trial. View "Weiss v. People ex rel. Department of Transportation" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and other crimes and sentence of death, holding that there was no prejudicial error in the trial proceedings.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized during a warrantless probation search of his home; (2) the trial court did not abuse its discretion in denying Defendant's motion to sever the capital charges from his remaining charges; (3) the evidence was sufficient to support the convictions; (4) Defendant's challenges to the trial court's guilt phase instructions lacked merit; (5) a failure of consular notification under the Vienna Convention occurred in this case, but no prejudice resulted from it; (6) the trial court did not err in denying Defendant's motion to modify the verdict; and (7) Defendant's challenges to California's death penalty law were unavailing. View "People v. Vargas" on Justia Law

The Supreme Court held that equitable tolling can lessen the otherwise strict time limit on the availability of writs of administrative mandate under Cal. Gov't Code 11523.The State Department of Public Health (the Department) imposed a fine on Saint Francis Memorial Hospital when it learned that doctors left a surgical sponge in a patient during a surgery. The Department later denied Saint Francis's request for reconsideration. Eleven days after the Department denied reconsideration but forty-one days after being served with the Department's final decision Saint Francis filed a petition for a writ of administrative mandate.The Department demurred on the ground that the petition was untimely under section 11523. The superior court sustained the Department's demurrer, reasoning that Saint Francis's petition was time-barred and that Saint Francis's mistake about the availability of reconsideration was not a sufficient basis to excuse a late filing. The court of appeal affirmed. The Supreme Court vacated the court of appeal's judgment, holding (1) equitable tolling may apply to petitions filed under section 11523; and (2) because the court of appeal didn't address equitable tolling's third element, the case is remanded for further proceedings. View "Saint Francis Memorial Hospital v. State Department of Public Health" on Justia Law

In this case concerning the application of various California wage and hour laws to flight attendants who work primarily outside California's territorial jurisdiction, the Supreme Court held that California's wage statement laws apply only to flight attendants who have their base of work operations in California.Plaintiffs, flight attendants for Delta Air Lines, Inc., filed a putative class action in federal court alleging that Delta violates California labor law by failing to pay its flight attendants minimum wage. The federal district court ruled in favor of Delta. On appeal, the United States Court of Appeals for the Ninth Circuit asked that the Supreme Court resolve unsettled questions of California law underlying Plaintiffs' claims. The Supreme Court held (1) California's wage statement laws apply only to flight attendants who have their base of work operations in California, and the same is true of California laws governing the timing of wage payments; and (2) whether or not California's minimum wage laws apply to work performed on the ground during Plaintiffs' brief and episodic stops in California, the challenged pay scheme complies with the state requirement that employers pay their employees at least the minimum wage for all hours worked. View "Oman v. Delta Air Lines, Inc." on Justia Law

The Supreme Court held that the question of whether Plaintiffs, pilots and flight attendants who resided in California but performed most of their work in airspace outside California's jurisdiction, were entitled to California-compliant wage statements depended on whether Plaintiffs' principal place of work was in California.Plaintiffs worked for a global airline based outside California. Plaintiffs were not paid according to California wage law but according to the terms of a collective bargaining agreement entered under federal law. At issue before the Supreme Court was whether the airline-employer was required to provide Plaintiffs with wage statements that met the requirements of California law. The Supreme Court held (1) workers are entitled to California-complaint wage statements if they are based for work purposes in California; and (2) for interstate transportation workers who do not perform a majority of their work in any one state, this test is satisfied when California serves as the workers' base of work operations, regardless of their place of residence or whether a collective bargaining agreement governs their pay. View "Ward v. United Airlines, Inc." on Justia Law