Justia California Supreme Court Opinion Summaries

At issue in this case was the application of the general rule that a litigant may appeal an adverse ruling only after the trial court renders a final judgment when a trial court has granted a petition for writ of administrative mandamus and remanded the matter for proceedings before an administrative body. The court of appeal dismissed Defendant’s appeal, concluding that the superior court’s order remanding the matter to the administrative body was not a final, appealable order. The Supreme Court reversed the dismissal of Defendant’s appeal and remanded the matter to the court of appeal with directions to reinstate the appeal, holding that because the issuance of the writ marked the end of the writ proceeding in the trial court, even if it did not definitely resolve the dispute between the parties, the trial court’s order was a final judgment. View "Dhillon v. John Muir Health" on Justia Law

Defendant was involved in an accidental collision with a twelve-year-old boy riding on a scooter. Defendant stopped and checked on the boy. Defendant drove off when he saw the boy loaded into an ambulance. Defendant pleaded guilty to leaving the scene of an injury accident in violation of Cal. Veh. Code 20001(a). The trial court sentenced Defendant to three years in prison and ordered him to pay $425,654.68 to the victim as restitution for injuries suffered as a result of the accident. The court of appeal reversed the restitution order, concluding that the trial court erred in fixing the amount of restitution. The Supreme Court affirmed. Cal. Penal Code 1202.4 provides that a defendant must pay restitution to the victim for losses incurred “as a result of the commission of a crime.” Here, Defendant’s crime was not being involved in a traffic accident but, rather, was leaving the scene of the accident without presenting identification or rendering aid. Accordingly, the trial court was authorized to order restitution for injuries that were caused or exacerbated by Defendant’s criminal flight from the scene of the accident, but it was not authorized to award restitution for injuries resulting from the underlying accident that involved no criminal wrongdoing. View "People v. Martinez" on Justia Law

The Supreme Court answered questions certified to it by the Ninth Circuit Court of Appeals regarding the construction of the state’s day of rest statutes, which prohibit an employer from causing his or her employees to work more than “six days in seven” but do not apply “when the total hours of employment do not exceed 30 hours in any week or six hours in any one day thereof.” The Court answered (1) periods of more than six consecutive days of work that stretch across more than one workweek are no per se prohibited; (2) the exemption for employees working shifts of six hours or less applies only to those who never exceed six hours of work on any day of the week; and (3) an employer “causes” its employee to go without a day of rest when it induces the employee to forgo rest to which he or she is entitled. View "Mendoza v. Nordstrom, Inc." on Justia Law

The Supreme Court held that a claim alleging a discriminatory decision is not subject to a motion to strike simply because it contests an action or decision that was arrived at following speech of petition activity or that was thereafter communicated by means of speech or petitioning activity. Plaintiff, a tenure-track assistant professor, filed suit under the California Fair Employment and Housing Act for national origin discrimination and failure to receive a discrimination-free workplace after his application for tenure was denied. The Board of Trustees of the California State University responded with a motion to strike, arguing that the communications that led up to the decision to deny Plaintiff tenure were protected activities. The trial court denied the motion, but the Court of Appeal reversed. The Supreme Court reversed, holding that “a claim may be struck only if the speech or petitioning activity itself is the wrong complained of and not just evidence of liability or a step leading to some different act for which liability is asserted.” View "Park v. Board of Trustees of California State University" on Justia Law

Petitioner committed murder when he was sixteen years old and was sentenced to life without the possibility of parole. The sentencing court did not give due consideration to the factors in Miller v. Alabama in imposing this sentence. Petitioner did not pursue an appeal. Here, Petitioner filed a petition for a writ of habeas corpus seeking a resentencing hearing at which the court would properly integrate the Miller factors into its sentencing calculus. The superior court granted habeas corpus relief. The Court of Appeal reversed, concluding that Petitioner could seek recall of his sentence and resentencing to a term of life with the opportunity for parole pursuant to Cal. Penal Code 1170(d)(2), which remedied any constitutional defect in Petitioner’s sentence and therefore precluded habeas corpus relief. The Supreme Court reversed, holding that section 1170(d)(2) does not provide an adequate remedy at law for Miller error, and Petitioner may obtain a Miller resentencing as a form of habeas corpus relief. Remanded for a resentencing hearing. View "In re Kristopher Kirchner" on Justia Law

Section 391.7’s prefiling process applies to self-represented plaintiffs who have been declared vexatious litigants. Plaintiff initiated an unlawful detainer action against Defendant. Defendant largely represented herself in the case. The trial court issued a writ of possession. Defendant appealed. In a separately filed action in which Defendant was the plaintiff and appellant, the Court of Appeal declared Defendant a vexatious litigant plaintiff. The court also entered a prefiling order under Cal. Code Civ. Proc. 391.7(c) that prohibited Defendant from filing any new litigation in California courts. In the instant case, the trial court’s appellate division dismissed Defendant’s consolidated appeals. Defendant petitioned the Court of Appeal for a writ of mandate directing the appellate division in the consolidated appeals to decide the appeals on their merits. The Court of Appeal ordered the appellate division to vacate its order dismissing Defendant’s appeals, concluding that a defendant’s status as a vexatious litigant plaintiff in one matter cannot limit that same defendant’s ability to pursue her appeal in an action she did not initiate as a plaintiff. The Supreme Court affirmed, holding that 391.7’s prefiling requirements do not apply to declared vexatious litigants who are self-represented defendants appealing from an adverse judgment in litigation they did not initiate. View "John v. Superior Court of Los Angeles County" on Justia Law

After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a witness, murder, in the commission of kidnapping, and lying in weight. The jury also found Defendant guilty of kidnapping, rape, and dissuading a witness. After a penalty trial, the jury returned a verdict of death for the murder conviction. The trial court imposed a judgment of death. The Supreme Court reversed the lying-in-wait special-circumstance finding for insufficient evidence but otherwise affirmed the judgment, holding (1) the evidence did not support the lying-in-wait special-circumstance finding, but no other prejudicial error occurred during the guilt phase of trial; and (2) there was no prejudicial error during the penalty phase of trial. View "Poeple v. Becerrada" on Justia Law

Plaintiff filed suit against Defendants, alleging that she was unlawfully terminated from employment. The complaint set forth two causes of action, one based on Cal. Health & Safety Code 1278.5(g) and one based on wrongful termination in violation of public policy. At issue in these proceedings was whether there was a right to a jury trial as to Plaintiff’s cause of action authorized by section 1278.5(g). The trial court denied a jury trial on the section 1278.5(g) cause of action. Plaintiff then filed a petition for writ of mandate in the Court of Appeal. The Court of Appeal ruled in Plaintiff’s favor, holding, inter alia, that the trial court erred in determining that there was no right to a jury trial in an action based on section 1278.5(g). The Supreme Court affirmed in part and reversed in part, holding (1) a trial court ruling denying a requested jury trial may be challenged prior to trial by a petition for an extraordinary writ; but (2) there is no right to a jury trial in a cause of action for retaliatory termination under section 1278.5(g) when a plaintiff seeks damages in such an action. Remanded. View "Shaw v. Superior Court" on Justia Law

Plaintiff and Defendants entered into a business relationship embodied in a series of oral and written agreements. Two of the written agreements contained clauses subjecting disputes arising out of the agreements to the sole jurisdiction of Florida courts. Plaintiff later brought this action for breach of contract, fraud, and related causes of action. Citing the two Florida forum selection clauses, Defendants moved to dismiss the action on grounds of forum non conveniens. The trial court granted the motion. Defendants then moved to recover $84,640 in attorney fees incurred in connection with the motion to dismiss, relying on an attorney fee clause in the agreements. The trial court denied the motion, ruling that Defendants were not the prevailing party for purposes of Cal. Civ. Code 1717 because the merits of the contract issues were still under litigation. The Court of Appeal affirmed. The Supreme Court affirmed, holding that the trial court acted within its discretion in denying Defendants’ motion for attorney fees because Defendants’ success in moving the litigation to Florida did not make them the prevailing party as a matter of law under section 1717. View "DisputeSuite.com, LLC v. Scoreinc.com" on Justia Law

Plaintiff opened a credit card account with Defendant Citibank, N.A. and purchased a credit protector plan. Defendant later amended the original agreement by adding an arbitration provision. The provision waived the right to seek public injunctive relief in any forum. The arbitration provision became effective in 2001. In 2011, Plaintiff filed this class action based on Defendant’s marketing of the Plan and the handling of a claim she made under it when she lost her job, alleging claims under the Consumers Legal Remedies Act (CLRA), the unfair competition law (UCL), and the false advertising law. Defendant petitioned to compel Plaintiff to arbitrate her claims on an individual basis pursuant to the arbitration provision. Based on the Broughton-Cruz rule, the trial court ordered Plaintiff to arbitrate all claims other than those for injunctive relief under the UCL, the CLRA, and the false advertising law. The Court of Appeal reversed and remanded for the trial court to order all of Plaintiff’s claims to arbitration, concluding that the Federal Arbitration Act preempts the Broughton-Cruz rule. The Supreme Court reversed, holding that the arbitration provision was invalid and unenforceable because it waived Plaintiff’s right to seek public injunctive relief in any forum. Remanded. View "McGill v. Citibank, N.A." on Justia Law