Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of rape of an intoxicated person and rape of an unconscious person. The convictions were based on the same act. On appeal, the Court of Appeal held that Defendant could not be convicted of both counts and vacated the conviction of rape of an unconscious person. The Supreme Court reversed, holding that Defendant was properly convicted of both rape of an intoxicated person and rape of an unconscious person, as the Legislature did not intend a defendant who commits oral copulation of an intoxicated and unconscious person can be guilty of two offenses, whereas a defendant who commits rape of an intoxicated and unconscious person can be guilty of only one offense. View "People v. White" on Justia Law

Eke Wokocha sued Sharp Memorial Hospital alleging that the Hospital’s negligence caused his quadriplegia. The jury found that the Hospital was negligent but that this negligence did not cause Wokocha’s quadriplegia. Wokocha subsequently died, and Wokocha’s widow, Berthe Kabran, was substituted as plaintiff. Kabran moved for a new trial on the basis of evidence obtained from an autopsy that purportedly called into question the jury’s causation determination. Kabran did not timely pay the necessary filing fee in submitting expert affidavits explaining the significance of this new evidence. The Hospital, however, did not object to the timeliness of the affidavits. Consequently, the trial court granted Kabran’s motion for a new trial. The Hospital appealed, arguing that because the affidavits were not timely filed, the trial court lacked jurisdiction to rely on them in hearing the motion for a new trial. The Court of Appeal affirmed. The Supreme Court affirmed, holding that because the Hospital did not object to the timeliness of the affidavits in the trial court, it may not raise this issue for the first time on appeal. View "Kabran v. Sharp Memorial Hospital" on Justia Law

Under California’s anti-SLAPP statute, unless a plaintiff establishes a probability of prevailing on a cause of action arising from constitutionally protected speech or petitioning activity, the court must grant the defendant’s motion to strike the claim and, generally, must also award the defendant attorney’s fees. In the instant case, Plaintiff, an attorney, filed an action against the State Bar after she was disciplined for committing violations of the rules of professional conduct. The State Bar filed a special motion to strike the complaint under the anti-SLAPP statute. The superior court granted the motion and awarded attorney’s fees to the State Bar, concluding that Plaintiff’s claims arose from protected petitioning activity and that Plaintiff had not shown a likelihood of prevailing because, inter alia, a superior court lacks subject matter jurisdiction over attorney discipline matters. The Court of Appeal reversed, concluding that because the trial court had no jurisdiction to rule on the anti-SLAPP motion, it also lacked jurisdiction to award attorney fees under Cal. Civ. Proc. Code 425.16. The Supreme Court reversed, holding that a court that lacks subject matter jurisdiction over a claim may grant a special motion to strike the claim under section 425.16 and thus may award attorney’s fees and costs to the defendant. View "Barry v. State Bar of California" on Justia Law

The ACLU submitted a request under the California Public Records Act (PRA) to the Los Angeles County Counsel seeking invoices specifying the amounts that the County and been billed by any law firm in connection with several different lawsuits alleging excessive force against jail inmates. The County refused to provide invoices for the lawsuits that were still pending on the basis of attorney-client privilege. The ACLU petitioned for writ of mandate seeking to compel the County to disclose the requested records. The superior court granted the petition, concluding that the County had failed to show that the invoices were attorney-client privileged communications. The County then filed a petition for writ of mandate. The court of appeal granted the petition and vacated the superior court’s order, concluding that the invoices were confidential communications within the meaning of Cal. Evid. Code 952. The Supreme Court affirmed, holding (1) the attorney-client privilege does not categorically shield everything in a billing invoice from PRA disclosure, but invoices for work in pending and active legal matters implicate the attorney-client privilege; and (2) therefore, the privilege protects the confidentiality of invoices for work in pending and active legal matters. View "Los Angeles County Board of Supervisors v. Superior Court of Los Angeles County" on Justia Law

After a trial, Defendant was convicted of carjacking and robbery. Both convictions were based on the same forceful taking of a vehicle. Defendant appealed, arguing that his forceful taking of the vehicle constituted a single physical act subject to the prohibition on multiple punishment under Cal. Penal Code 654, and therefore, section 654 barred his robbery sentence. The court of appeal affirmed, concluding that there was sufficient evidence from which the trial court could have concluded that there were two intents. The Supreme Court reversed, holding that the same action completed the actus reus for each of the crimes of which Defendant was convicted, and therefore, Defendant’s one-year robbery sentence must be stayed. View "People v. Corpening" on Justia Law

Plaintiffs worked as security guards for Defendant. Defendant required that guards keep their pagers and radio phones on even during off-duty rest periods required under Cal. Labor Code 226.7 and Industrial Welfare Commission wage order 4-2001. Defendant also required Plaintiffs to be responsive to calls when needs arose. Plaintiffs sued Defendant alleging that Defendant failed to provide the rest periods that Plaintiffs were entitled to receive under state law. The trial court granted summary judgment for Plaintiffs. The Court of Appeal reversed. The Supreme Court reversed, holding that California law requires employers to relieve their employees of all work-related duties and employer control during ten-minute rest periods. View "Augustus v. ABM Security Services, Inc." on Justia Law

This case involved the practice of short-term deferred deposit lending, often referred to as “payday” or “cash advance” lending. After the Legislature enacted the California Deferred Deposit Transaction Law (the Law), which limits the size of each loan and the fees that lenders may charge, some deferred deposit lenders sought affiliation with federal recognized Indian tribes, which are generally immune from suit on the basis of tribal sovereign immunity. In this case, a pair of federally recognized tribes created affiliated business entities, which provide deferred deposit loans through the internet to borrowers in California under terms that allegedly violated the Law. At issue in this case was whether these tribally affiliated entities were immune from suit as “arms of the tribe.” The Supreme Court clarified the legal standard and burden of proof for establishing arm-of-the-tribe immunity and held that the entities in this case failed to show by a preponderance of the evidence that they were entitled to tribal immunity as an arm of its affiliated tribe. Remanded for the trial court to address the issue of whether the parties had the opportunity to fully litigate their claims under that standard. View "People ex rel. Owen v. Miami Nation Enterprises" on Justia Law

After a jury trial, Defendant was convicted of the first degree murder of a peace officer. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not err in failing to suspend proceedings and investigate whether Defendant was competent to stand trial; (2) Defendant’s ineffective assistance of counsel claim was inappropriate to address on appeal; (3) the trial court’s failure to suspend proceedings and hold a competency hearing prior to judgment did not violate Defendant’s due process rights; (4) the trial court did not err in allowing Defendant to waive his right to counsel; (5) the trial court did not err by failing to revoke Defendant’s self-representation during the penalty phase pursuant to Cal. Penal Code 686.1; (6) the trial court did not err in failing to obtain an updated Faretta waiver after the People filed a notice of intent to seek death; (7) Defendant’s claim that certain jurors should have been excused for cause was forfeited; (8) the trial court did not deprive Defendant of his constitutional right to testify in his own defense by excluding his liberty defense; and (9) Defendant’s challenges to the death penalty statute were without merit. View "People v. Mickel" on Justia Law

The Automobile Sales Finance Act (ASFA) is a consumer protection law that governs the sale of vehicles in which the buyer finances all or part of the car’s purchase. Plaintiffs were consumers who purchased vehicles from Raceway Ford, Inc., an automobile dealership. Plaintiffs alleged that Raceway violated ASFA when (1) after agreeing to an initial finance contract, Raceway would enter into a subsequent finance contract with a buyer and backdate the second contract to the date of the first contract, and (2) a computer error caused Raceway to incorrectly include smog-related fees in buyers’ purchase contracts. The trial court found in favor of Raceway on all claims relevant to this appeal. The court of appeal affirmed with respect to Plaintiffs’ smog fee claims but reversed with respect to Plaintiffs’ backdating claims. The Supreme Court affirmed in part and reversed in part, holding (1) Raceway’s practice of backdating contracts did not violate the ASFA; and (2) Raceway did violate the ASFA when its disclosed inaccurate smog fees, but Plaintiffs were not entitled to a remedy under ASFA because the violation was due to an accidental or bona fide error in computation. View "Raceway Ford Cases" on Justia Law

In 2006, Milan REI IV LLC (Milan) purchased more than fifty acres of land in the Orange Park Acres area in the City of Orange with plans to develop a residential development on the property. The City approved Milan’s request to amend its general plan and permit development on the property, despite controversy over the private development replacing public open space. Orange Citizens for Parks and Recreation and Orange Parks Association (together, Orange Citizens) challenged the City’s amendment by referendum. The City concluded that the referendum, whatever its outcome, would have no effect because a resolution from 1973 permitted residential development on the property. In 2012, fifty-six percent of voters rejected the City’s general plan amendment. The court of appeal upheld the City’s approval of the project. The Supreme Court reversed, holding that the City abused its discretion in interpreting its 2010 General Plan to permit residential development on the property. View "Orange Citizens for Parks & Recreation v. Superior Court of Orange County" on Justia Law