Justia California Supreme Court Opinion Summaries

An individual’s standing to sue under Cal. Code Civ. Proc. 526a does not require the payment of a property tax, as an allegation that the plaintiff has paid an assessed tax to the defendant locality is sufficient under section 526a.The trial court filed a stipulated order and judgment of dismissal dismissing for lack of standing Plaintiff’s complaint for declaratory and injunctive relief challenging the manner in which the City of San Rafael and County of Marin enforced Cal. Veh. Code 14602.6. The court of appeal affirmed, concluding that an individual plaintiff must be liable to pay a property tax within the relevant locality, or have paid a property tax during the previous year, to have standing. The Supreme Court reversed, holding that the court of appeal erred when it held that payment of a property tax was required under section 526a. View "Weatherford v. City of San Rafael" on Justia Law

When an assessment on nonexempt property is challenged on the ground that the taxpayer does not own the property involved, the taxpayer must seek an assessment reduction through the assessment appeal process before the county board of equalization or a county assessment appeals board or obtain a stipulation under Cal. Rev. & Tax Code 5142(b) that such proceedings are unnecessary in order to maintain a postpayment superior court action under Cal. Rev. & Tax Code 5140 that seeks reduction of the tax. The Supreme Court overruled Parr-Richmond Industrial Corp. v. Boyd 43 Cal.2d 157 (1954) to the extent that the decision provides otherwise. Because this holding operates only prospectively, the Supreme Court affirmed the judgment of the court of appeal in this action where Plaintiffs brought timely assessment appeal proceedings under Cal. Rev. & Tax Code 1603 (a). The court of appeal held that “where, as here, the taxpayer claims [an] assessment is void because the taxpayer does not own the [assessed] property, the taxpayer is not required to apply for an assessment reduction under section 1603, subdivision (a) to exhaust its administrative remedies.” View "Williams & Fickett v. County of Fresno" on Justia Law

At issue was whether Defendant’s hand gesture unaccompanied by words or sound qualified as a “statement, made verbally” under Cal. Penal Code 422. Section 422 makes it a crime to threaten infliction of great bodily injury or death on another “with the specific intent that the statement, made verbally, in writing, or by means of an electronic communication device, is to be taken as a threat….” The trial court dismissed the criminal threat allegations against Defendant, concluding that the hand gestures could not constitute criminal threats as defined by section 422. The court of appeals reversed the dismissal. The Supreme Court reversed, holding (1) a threat made through nonverbal conduct falls outside the scope of section 422; and (2) Defendant’s conduct did not constitute a verbal communication merely because he intended to convey an idea through his conduct. View "People v. Gonzalez" on Justia Law

During jury selection proceedings, three defendants joined in a Batson/Wheeler motion, arguing that the prosecutor improperly excluded prospective jurors on account of Hispanic ethnicity. The trial court denied the motion, finding the prosecutor’s reasons for exercising ten of sixteen peremptory challenges to remove Hispanic individuals from the jury panel to be neutral and nonpretextual. The court of appeal upheld the trial court’s denial of Defendants’ joint Batson/Wheeler motion. The Supreme Court reversed, holding (1) the trial court’s finding that Defendants had not met their burden of proving intentional discrimination with respect to at least one excluded panelist was unreasonable in light of the record of voir dire proceedings, and therefore, Defendants were denied their right to a fair trial and their right to a trial by a jury drawn from a representative cross-section of the community under the state Constitution; and (2) the court of appeal erred in refusing to conduct a comparative juror analysis. View "People v. Gutierrez" on Justia Law

Plaintiff-taxpayers filed a complaint against the City of Los Angeles and the Director of the Los Angeles Zoo (collectively, the City) alleging that the zoo was abusing its elephants. The trial court granted summary judgment to the City, ruling that the complaint raised nonjusticiable issues of public policy. The court of appeals reversed. After a bench trial, the trial court issued injunctions against the City. The court of appeal affirmed, holding (1) the court of appeal’s earlier decision established law of the case, thus barring the City’s new argument that the claim for equitable relief was precluded by Cal. Civ. Code 3369; and (2) the Legislature authorized taxpayer actions aimed at enjoining government expenditures that support criminal conduct. The Supreme Court reversed, holding (1) this case is governed by the general rule that law of the case does not apply to arguments that might have been but were not presented and resolved on an earlier appeal; and (2) the Legislature did not intend to overturn the long-established law governing equitable relief for violations of penal law when it amended Civil Code section 3369, but rather maintained the rule that a taxpayer action will not lie to enforce a Penal Code provision. View "Leider v. Lewis" on Justia Law

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