Justia California Supreme Court Opinion Summaries

The Supreme Court answered a question regarding California's Unruh Civil Rights Act, Cal. Civ. Code 51 et seq., by holding that a plaintiff has standing to bring a claim under the Act when the plaintiff visits a business's website with the intent of using its services and encounters terms and conditions that allegedly deny the plaintiff full and equal access to the website's services and then leaves the website without entering into an agreement with the service provider.Plaintiff sued Defendant, alleging that Defendant's seller agreement discriminated against him in violation of the Act. The district court dismissed the complaint on the ground that Plaintiff lacked standing under the Act to sue Defendant because Plaintiff had not attempted to use Defendant's services. On appeal, the United States Court of Appeals for the Ninth Circuit issued the certification order at issue in this case. The Supreme Court held that, under the rule announced today, Plaintiff sufficiently alleged injury for Unruh Civil Rights Act standing because entering into an agreement with the business is not required for standing under the Act. View "White v. Square, Inc." on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and sentence of death, holding that there was no error in the proceedings below that entitled Defendant to reversal of his convictions.Specifically, the Court held (1) both prongs of Cal. Const. art. I, 28(d)'s requirement were met in this case, and allowing the jury to judge the relevant evidence did not violate Defendant's due process rights; (2) a witness's decision not to testify, upheld by the court, did not deny Defendant the right to present a defense; (3) the state and federal constitutions supported the trial court's decision to grant the witness her Fifth Amendment privilege; (4) Defendant's challenges to California's death penalty law were unavailing; and (5) Defendant failed to establish cumulative error because there were no errors to aggregate. View "People v. Capers" on Justia Law

In this putative class action brought on behalf of retail purchasers of an inflatable outdoor pool the Supreme Court reversed the judgment of the court of appeal upholding the ruling of the trial court denying the representative plaintiff's motion for class certification, holding that the trial court erred in determining that the class proposed by the plaintiff was not ascertainable.The claims in this case arose out of the plaintiff's purchase out of an inflatable pool sold in packaging that allegedly misled buyers about the pool's size. The trial court denied the plaintiff's motion for class certification in its entirety on ascertainability grounds. The court of appeal found no abuse of discretion in the denial of class certification. The Supreme Court reversed, holding that the trial court erred in demanding that the plaintiff offer evidence showing how class members might be individually identified when that identification became necessary. Specifically, the Court held (1) an ascertainable class is one defined in objective terms that make the eventual identification of class members possible; and (2) the trial court abused its discretion when it found no ascertainable class existed. View "Noel v. Thrifty Payless, Inc." on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of first degree murder and other crimes but reversed Defendant's sentence of death imposed after a penalty retrial, holding that the trial court erred by permitting the prosecution to make improper use of inflammatory character evidence for purposes unrelated to any legitimate issue in the proceeding.Defendant was convicted of two counts of first degree murder, attempted murder, and carjacking. The jury was unable to reach a verdict as to penalty, and the trial court declared a mistrial. The jury sentenced Defendant to death after a penalty retrial. The Supreme Court affirmed Defendant's convictions but reversed his sentence of death, holding (1) assuming that the trial court erred in admitting Defendant's statement "You heard it all" and admitting certain evidence of Defendant's racist tattoos, affiliations, and beliefs, neither error was prejudicial either individually or cumulatively; and (2) the trial court erred in allowing the prosecution to use evidence of Defendant's abstract beliefs when advising the jury whether to impose the death penalty, and the error was prejudicial. View "People v. Young" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeal concluding that the anti-SLAPP statute, Cal. Code Civ. Proc. 425.16, cannot be used to judicially screen claims alleging discriminatory or retaliatory employment actions, holding that the statute contains no exception for discrimination or retaliation claims.Plaintiff alleged that Defendant, his employer, ultimately fired him for unlawful discriminatory and retaliatory reasons. Defendant, a news organization, filed an anti-SLAPP motion. The trial court granted the motion, concluding that Plaintiff had not shown any of his claims had minimal merit. The court of appeal reversed, concluding that discrimination and retaliation do not qualify as protected activity, and therefore, the anti-SLAPP statute did not apply. The Supreme Court reversed in part, holding (1) in cases alleging discrimination or retaliation claims in the employment context, the plaintiff's allegations about the defendant's invidious motives will not shield the claim from the same preliminary screening for minimal merit that would apply to any other claim arising from protected activity; and (2) Defendant showed that Plaintiff's claims arose in limited part from protected activity, and therefore, Defendant was entitled to a determination of whether those limited portions of Plaintiff's claims had sufficient potential merit to proceed. View "Wilson v. Cable News Network, Inc." on Justia Law

In this tort action arising out of a fatal tour bus accident in Arizona, the Supreme Court held that the trial court did not err by declining to reconsider its prior choice of law ruling after an Indiana defendant was dismissed from this case.The parties in this case initially included plaintiffs from China and defendants from both Indiana and California. The trial court conducted the governmental interest test and concluded that Indiana law governed. Before trial, Plaintiffs accepted a settlement offer from the Indiana defendant. The court of appeals reversed, concluding that the trial court should have reconsidered the initial choice of law ruling after the Indiana defendant was dismissed from the case. The court then applied the governmental interest test and concluded that California law governed. The Supreme Court reversed, holding (1) given the importance of determining the choice of law early in a case, the circumstances in which trial courts are required to revisit a choice of law determination should be the exception and not the rule; and (2) the trial court in this case was not required to reconsider the prior choice of law ruling based on the Indiana defendant's settlement. View "Chen v. Los Angeles Truck Centers, LLC" on Justia Law

The Supreme Court issued a writ of mandate directing the trial court to vacate its order denying Petitioner's request to release ballistics evidence for expert testimony in preparation for filing a habeas corpus petition, holding that the trial court erred in denying the request based solely in Petitioner's failure to establish good cause.Petitioner was sentenced to death for the first degree murders of two victims. In preparation for filing a habeas corpus petition, Petitioner filed his request for the ballistics evidence. The superior court denied Petitioner's request to release ballistics evidence for expert testimony under the authority of Cal. Penal Code 1054.9, which governs discovery in habeas corpus proceedings involving certain judgments, including a sentence of death. The court found specifically that Petitioner had failed to show good cause to believe his access to the evidence was reasonably necessary to obtain relief. The Supreme Court vacated the order, holding that, under the statute, a threshold showing of good cause is not required. View "Satele v. Superior Court of Los Angeles County" on Justia Law

In this original habeas corpus action the Supreme Court granted Petitioner habeas corpus relief insofar as the petition sought relief from the judgment of death after accepting the finding of the referee that a prosecution witness had falsely identified Petitioner as the man who sexually assaulted her, holding that the false testimony was material.Petitioner was convicted of first degree murder and second degree murder and sentenced to death. Petitioner later filed a habeas corpus petition alleging, among other things, that a penalty phase witness had misidentified him as the man who assaulted and raped her. The Supreme Court appointed a referee who conducted an evidentiary hearing, after which the referee found that, during the penalty phase, the witness had testified falsely when she identified Petitioner as her assailant. Noting that the Court generally accepts the referee's findings, the Supreme Court granted Petitioner relief on the basis of false evidence by overturning his sentence of death, holding that the false testimony undermined this Court's confidence in the outcome of the trial and that Petitioner was entitled to relief on this claim as to the penalty verdict. View "In re Rogers" on Justia Law

In this negligence case, the Supreme Court held that the immunity provision of the Government Claims Act (GCA) that bars any statutory liability that might otherwise exist for injuries resulting from the condition of firefighting equipment or facilities, Cal. Gov't Code 850.4, does not deprive a court of fundamental jurisdiction but, rather, operates as an affirmative defense to liability.Plaintiff sued the Chester Fire Protection District and the Garden Valley Fire Protection District alleging that Defendants created a "dangerous condition" of public property for which public entities may be held liable under Cal. Gov't Code 835. Defendants did not allege the immunity conferred by section 850.4. After trial began, defense counsel presented a written motion for nonsuit in which Defendants for the first time invoked section 850.4. Plaintiff objected on the ground that Defendants waived section 850.4 immunity by failing to invoke the immunity in their answer. The trial court overruled the objection, concluding that governmental immunity is jurisdictional and can't be waived. The court of appeal affirmed. The Supreme Court reversed, holding that section 850.4 immunity operates as an affirmative defense and not a jurisdictional bar. The Court remanded the case so the court of appeal may address the parties' remaining arguments in the first instance. View "Quigley v. Garden Valley Fire Protection District" on Justia Law

The Supreme Court reversed the decision of the court of appeal reversing the ruling of the trial court denying Defendants' motion for dismiss this breach of contract suit under the anti-SLAPP statutes, holding that Plaintiff met its burden of showing its breach of contract claim had "minimal merit" sufficient to defeat an anti-SLAPP motion.The parties to a tort action agreed to settle their lawsuit. The agreement, which was reduced to writing, included provisions purporting to impose confidentiality obligations on the parties and their counsel. All parties signed the agreement, and the parties' lawyers signed under a notation that they approved the agreement. Plaintiff brought this suit against Defendants, counsel in the tort action, alleging that Defendants violated the agreement by making public statements about the settlement. Defendants moved to dismiss the suit under the anti-SLAPP statutes. The trial court denied the motion. The court of appeal reversed, concluding that the notation meant only that counsel recommended their clients sign the document. The Supreme Court reversed, holding that it would be reasonable to argue that Defendants' signature on the agreement evinced a willingness to be bound by its terms. View "Monster Energy Co. v. Schechter" on Justia Law