Justia California Supreme Court Opinion Summaries

The Supreme Court held that voter approval was not required for a transfer from a utility’s enterprise fund to the city’s general fund.Cal. Const. art. XIIIC prohibits local governments from imposing or increasing any tax without voter approval. Any charge imposed for a service or product that does not exceed the reasonable costs of providing it is excepted from the definition of tax. The City of Redding operated an electric utility as a department of its city government. At issue was whether an annual interfund transfer from the utility’s enterprise fund to the city’s general fund required voter approval where the transfer was intended to compensate the general fund for costs of services that other city departments provide to the utility. The Supreme Court held that because neither the budgetary transfer nor the rate the city charged its utility customers constituted a tax, voter approval was not required. View "Citizens for Fair REU Rates v. City of Redding" on Justia Law

At issue was what relationship, if any, must exist between a person’s convictions for forgery and identity theft for the identity theft conviction to result in denial of the relief an individual could otherwise receive under Cal. Penal Code 473(b).Defendant pled guilty to multiple offenses, including four counts of check forgery and one count of identity theft. After Proposition 47 was enacted, Defendant filed a petition to reduce his forgery convictions to misdemeanors under section 473(b). The trial court denied the petition because forgery is therefore ineligible for reclassification as a misdemeanor for “any person who is convicted both of forgery and of identity theft.” The Court of Appeal reversed, concluding that section 473(b) precludes relief only if the identity theft offense is “transactionally related” to a forgery conviction. The Supreme Court affirmed, holding that there must be a connection between both the forgery and the identity theft convictions to disqualify an offender from resentencing. Because Defendant’s offenses were unrelated, they were not subject to exclusion under section 473(b), and Defendant was eligible for resentencing. View "People v. Gonzales" on Justia Law

The Supreme Court held that the people of a county or city can challenge by referendum a zoning ordinance amendment that would bring the ordinance into compliance with a change to the county’s or city’s general plan, at least where the local government has other means available to make the zoning ordinance and general plan consistent.Cal. Gov. Code 65860(a) requires zoning ordinances to “be consistent with the general plan of the county or city.” When the general plan is amended without also changing the corresponding zoning ordinance, the city or county must amend the zoning ordinance within a reasonable time to make it consistent with the general plan. At issue was whether the people may challenge by referendum a zoning ordinance amendment that would bring the ordinance into compliance with a general plan, even though the referendum would temporarily leave in place a zoning ordinance that does not comply with the general plan. The Supreme Court held in this case that the Court of Appeal did not err in holding that a referendum can invalidate a zoning ordinance amendment to achieve compliance with a general plan amendment, where other general-plan-compliant zoning designations are available that would be consistent with a successful referendum. View "City of Morgan Hill v. Bushey" on Justia Law

In this action alleging that a utilization reviewer caused Plaintiff additional injuries by denying his treating physician’s request to continue prescribing certain medication for his injuries without authorizing a weaning regimen or warning him of possible side effects of abruptly ceasing the medication, the Supreme Court held that the workers’ compensation law provided the exclusive remedy for the employee’s injuries and thus preempted the employee’s tort claims.Plaintiff sustained a work-related back injury that caused him chronic pain, anxiety and depression. A mental health profession prescribed Klonopin to treat the anxiety and depression. Two years later, a utilization reviewer determined that Klonopin was medically unnecessary and decertified the prescription. After Plaintiff immediately stopped taking the medication he suffered a series of four seizures. Plaintiff filed a complaint asserting several tort claims. Defendants demurred, arguing that the claims were preempted by the Workers’ Compensation Act. The trial court sustained the demurrer. The Court of Appeals affirmed. The Supreme Court reversed the judgment insofar as it permitted Plaintiffs to amend their complaint to bolster their claim that Defendants were liable in tort for failure to warn, holding that because the acts alleged did not suggest that Defendants acted outside of the utilization review role contemplated by statute, Plaintiff’s claims were preempted. View "King v. CompPartners, Inc." on Justia Law

The Supreme Court affirmed the judgment of the Court of Appeal concluding that some overlap between the Investigative Consumer Reporting Agencies Act (ICRAA), Cal. Civ. Code 1786 et seq. and the Consumer Credit Reporting Agencies Act (CCRAA), Cal. Civ. Code 1785.1 et seq., does not render ICRAA unconstitutionally vague as applied to employer background checks when the statutes are otherwise unambiguous.In this class action, Plaintiff sued Defendants, investigative consumer reporting agencies, for violating ICRAA because Defendants did not obtain her written authorization to conduct a background check. Defendants moved for summary judgment, claiming (1) ICRAA was unconstitutionally vague as applied to Plaintiff’s claim because it overlapped with CCRAA, and (2) Defendants satisfied CCRAA. The trial court granted the motion. The Court of Appeal reversed. The Supreme Court affirmed and remanded, holding (1) the background check that Defendants conducted was an investigative consumer report under ICRAA; and (2) although the CCRAA also applied here, Defendants were not exempted from the requirement that they obtain Plaintiff’s written authorization under ICRAA before conducting or procuring a background investigation. View "Connor v. First Student, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeal upholding the ruling of the superior court denying the requests of Bianka M., a minor, for an order placing her in her mother’s sole custody and for findings that would enable her to seek “special immigrant juvenile” (SIJ) status under federal immigration law, holding that the superior court erred in concluding that it could not issue either a custody order or findings relevant to SIJ status unless Bianka first established a basis for exercising personal jurisdiction over her father and joined him as a party to the action.Bianka entered the United States unaccompanied and without prior authorization. In a family court action, Bianka asked to be placed in the sole custody of her mother, who had left Honduras for the United States years before, and sought findings enabling her to seek special immigrant juvenile status, alleging that her father, who resided in Honduras, abandoned her. The superior court denied the requests. The Supreme Court reversed, holding (1) the superior court erred in requiring Bianka’s father to be joined as a party in her parentage action seeking SIJ findings because he received adequate notice and took no steps to participate; and (2) the action may proceed regardless of Bianka’s perceived immigration-related motivations for filing the action. View "Bianka M. v. Superior Court" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death following a second penalty proceeding, holding that there was no error requiring reversal.Specifically, the Court held (1) the Ireland merger doctrine did not bar Defendant’s convictions for torture murder and mayhem murder; (2) the evidence was sufficient to support Defendant’s convictions for torture murder and rape murder; (3) the trial court’s admission of gang affiliation evidence during the guilt phase of trial was harmless; (4) the evidence supported the special circumstance findings of torture murder and mayhem murder; (5) the jury’s finding that Defendant was sane at the time of the killing did not require reversal; (6) the trial court did not err in admitting evidence of Defendant’s possible gang affiliation and racist beliefs during the penalty phase; (7) imposition of the death penalty on a mentally ill defendant does not violate the Eighth Amendment; and (8) Defendant’s constitutional challenges to California’s imposition of the death penalty failed. View "People v. Powell" on Justia Law

The Supreme Court held that the interest rate on consumer loans of $2,500 or more may render the loans unconscionable under section 22302 of the Financial Code.Defendant, a lender of consumer loans to high-risk borrowers, had as one of its signature products an unsecured $2,600 loan carrying an annual percentage rate (APR) of either ninety-six percent or, later in the class period, 135 percent. Plaintiffs alleged that CashCall violated California’s Unfair Competition Law (UCL), Cal. Bus. & Prof. Code 17200 because its lending practice was unlawful where it violated section 22302, the section that applies the unconscionability doctrine to consumer loans. The district court certified Plaintiffs’ lawsuit as a class action and then granted CashCall’s motion for summary judgment. On appeal, the federal court of appeals certified to the Supreme Court a question of law. The Supreme Court answered in the positive, holding that an interest rate on consumer loans of $2,500 or more may be deemed unconscionable under section 22302. View "De La Torre v. CashCall, Inc." on Justia Law

At issue was whether the immunity from damages for collisions resulting from police chases provided by Cal. Veh. Code 17004.7 is available to a public agency only if all peace officers of the agency certify in writing that they have received, read, and understood the agency’s vehicle policy.The Supreme Court held that a public agency may receive immunity provided by section 17004.7 only if every peace officer the agency employs has provided written certification that the officer has received, read, and understood the agency’s written policy on vehicular pursuits. While the agency’s policy must require the written certification, the agency need not prove total compliance with that requirement as a prerequisite to receiving the immunity.The Court of Appeal reached a similar conclusion, holding (1) it suffices if a public agency imposes the certification requirement, but the agency does not have to prove total compliance with the requirement; and (2) because the pursuit policy promulgated by the City in this case imposed such a requirement, summary judgment was correctly granted in the City’s favor. View "Ramirez v. City of Gardena" on Justia Law

At issue was what standards of review apply to the Public Employment Relations Board’s (PERB) legal interpretations and findings of fact when a final decision by PERB under the Meyers-Milias-Brown Act (MMBA), Cal. Gov’t Code 3500 et seq., is appealed.The Supreme Court held (1) PERB’s legal findings are entitled to deferential review, and PERB’s factual findings are “conclusive” “if supported by substantial evidence”; and (2) governing bodies or representatives properly designated are required to engage with unions on matters within the scope of representation prior to arriving at a determination of policy or course of action, even if that action is not a formal one taken by the governing body itself.Here, unions filed unfair practice claims after San Diego’s mayor sponsored a citizen’s initiative to eliminate pensions for new municipal employees and denied union demands to meet and confer over the measure. The Court of Appeal annulled PERB’s finding that the failure to meet and confer constituted an unfair labor practice. The Supreme Court reversed, holding (1) the MMBA applied to the mayor’s official pursuit of pension reform as a matter of policy; and (2) the Court of Appeals improperly reviewed PERB’s interpretation of the governing statutes de novo and took an unduly constricted view of the duty to meet and confer. View "Boling v. Public Employment Relations Board" on Justia Law