Justia California Supreme Court Opinion Summaries

The Supreme Court of California ruled that the Taxpayer Protection and Government Accountability Act (TPA), a proposed initiative measure, could not be placed on the November 2024 general election ballot. The TPA sought to revise the California Constitution by requiring voter approval for any new or increased state or local tax, and by expanding the definition of "tax" to include a wider range of government charges. The petitioners, the Legislature of the State of California, Governor Gavin Newsom, and former Senate President Pro Tempore John Burton, argued that the TPA was invalid because it attempted to revise the California Constitution via citizen initiative, and because it would seriously impair essential government functions.The court agreed with the petitioners, finding that the TPA would substantially alter the basic governmental framework set forth in the California Constitution. The court noted that the TPA would eliminate the Legislature's ability to levy taxes without prior voter approval, shift power between the executive and legislative branches, and transform local revenue-raising by requiring that exempt charges go through legislative rather than administrative processes. The court concluded that these changes were so significant that they amounted to a revision of the Constitution, which could not be enacted by initiative. The court therefore issued a writ of mandate directing the Secretary of State to refrain from placing the TPA on the November 2024 election ballot. View "Legislature of the State of California v. Weber" on Justia Law

This case involves a dispute over insurance coverage for continuous injury claims. The plaintiff, Truck Insurance Exchange, was a primary insurer for Kaiser Cement and Gypsum Corporation. Truck filed an equitable contribution claim against several insurers that had issued first-level excess policies to Kaiser for policy years where the directly underlying primary policy had been exhausted. Truck argued that the excess insurers’ indemnity obligations were triggered immediately upon exhaustion of the directly underlying primary policies. The excess insurers, however, argued that they had no duty to indemnify Kaiser until it had exhausted every primary policy issued during the period of continuous damage. The trial court and the Court of Appeal agreed with the excess insurers, interpreting the excess policies as requiring horizontal exhaustion of all primary insurance.The Supreme Court of California disagreed, concluding that the language of the first-level excess policies at issue in this case is essentially identical to the policy language in the higher-level excess policies that it considered in a previous case, Montrose III. The Court held that the first-level excess policies are most reasonably construed as requiring only vertical exhaustion. However, the Court also noted that its conclusion does not fully resolve the questions presented in this appeal, which involves a contribution claim between coinsurers. The Court remanded the matter to allow the Court of Appeal to address these alternative arguments in the first instance. View "Truck Ins. Exchange v. Kaiser Cement & Gypsum Corp." on Justia Law

In the case of The People v. Giles Albert Nadey, Jr., the defendant was convicted of one count of unlawful sodomy and one count of first-degree murder for the killing of Terena Fermenick. The jury found that both offenses were committed with the use of a knife and the murder occurred during the commission of unlawful sodomy. After the first jury deadlocked on penalty, a second jury returned a verdict of death. The Supreme Court of California affirmed the judgment.The case revolved around the murder of Terena Fermenick, who was sexually assaulted and killed. The defendant, Giles Albert Nadey, Jr., was a carpet cleaner who had been assigned to clean the carpets at the Fermenick's new home on the day of the murder. The prosecution's evidence included DNA evidence linking Nadey to the crime, as well as testimony from various witnesses.In the lower courts, Nadey was convicted of the charges and sentenced to death. His appeal to the Supreme Court of California was automatic due to the death sentence.In the Supreme Court of California, Nadey's conviction and sentence were affirmed. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also rejected Nadey's claims of legal error and prosecutorial misconduct. The court held that the prosecutor's comments during closing arguments were not improper and did not prejudice Nadey's right to a fair trial. The court also found that the trial court did not err in admitting certain evidence or in its handling of jury instructions. View "P. v. Nadey" on Justia Law

The Supreme Court of California reviewed a case involving the University of California, Berkeley's (UC Berkeley) plan to build a housing project on a site called People's Park. The plaintiffs, Make UC a Good Neighbor and People’s Park Historic District Advocacy Group, challenged the certification of an environmental impact report (EIR) for the project, arguing that it failed to consider the environmental impacts of "student-generated noise" and did not adequately consider alternatives to the People’s Park location. The Court of Appeal agreed with the plaintiffs.The Supreme Court of California granted review of the Court of Appeal’s decision. During the review, the Legislature passed Assembly Bill No. 1307, which added sections to the Public Resources Code stating that noise generated by project occupants and their guests is not a significant environmental effect for residential projects, and that public higher education institutions are not required to consider alternatives to the location of a proposed residential or mixed-use housing project if certain requirements are met. The plaintiffs conceded that this new law applied to the case and made clear that the EIR was not required to examine "social noise" or potential alternative locations to People’s Park.The Supreme Court of California concluded that none of the plaintiffs' claims had merit in light of the new law. The court held that the new law applied to both the People’s Park housing project and the development plan, and the EIR was not inadequate for having failed to study the potential noisiness of future students at UC Berkeley in connection with this project. The court declined to consider the plaintiffs' alternative locations argument with respect to potential future housing projects. The court reversed the Court of Appeal’s judgment. View "Make UC a Good Neighbor v. The Regents of the University of California" on Justia Law

In 2021, the California Legislature passed Assembly Bill 333, known as the STEP Forward Act of 2021. This bill amended Penal Code section 186.22, imposing new requirements relating to gang enhancements and the criminal offense of gang participation. It also added section 1109, which provides that, if requested by the defense, a trial court must try a gang enhancement charge separately from the underlying offense. The Supreme Court of California was asked to determine whether section 1109’s provisions governing bifurcation apply retroactively to cases in which the judgment is not yet final.The lower courts were divided on this issue. Some courts concluded that section 1109 applies retroactively, while others concluded that it does not. The Supreme Court of California held that the Estrada inference of retroactivity does not extend to section 1109. The court reasoned that Estrada’s principle of statutory interpretation infers retroactivity from statutory reductions in punishment, not from the type of prophylactic rules of criminal procedure embodied in section 1109’s bifurcation provisions. Accordingly, the general presumption of prospective-only application applies to section 1109. The court also held that equal protection principles do not require section 1109 to be applied retroactively. The court reversed the judgment of the Court of Appeal and remanded the matter for further proceedings consistent with its opinion. View "P. v. Burgos" on Justia Law

A dispute arose over whether a transfer of property from a family corporation to a trust constituted a "change in ownership" under California's Proposition 13, which would trigger a reassessment of the property's value for tax purposes. The Los Angeles County Assessor determined that the transfer did constitute a change in ownership because the transfer eliminated the interests of individual shareholders who held nonvoting stock in the corporation. The Los Angeles County Assessment Appeals Board reversed this decision, asserting that the beneficial interest in the corporation's real property was held by the persons who controlled the corporation through its voting stock. The Superior Court granted a petition by the assessor to vacate the Appeals Board's decision, and the Court of Appeal affirmed the Superior Court's decision.The Supreme Court of California affirmed the Court of Appeal's decision. The court held that the term "ownership interests" in the relevant statute, Revenue and Taxation Code section 62, subdivision (a)(2), refers to beneficial ownership interests in real property, not interests in a legal entity. For a corporation, these beneficial ownership interests are measured by all corporate stock, not just voting stock. The court rejected the argument that the term "stock" in section 62, subdivision (a)(2) must be interpreted to mean voting stock. The court concluded that the transfer of the properties from the corporation to the trust resulted in a change in ownership because the proportional beneficial ownership interests in the properties did not remain the same before and after the transfer. View "Prang v. Los Angeles County Assessment Appeals Board" on Justia Law

In 2019, Emily Wheeler, a property owner, was charged with various violations of the Los Angeles Municipal Code related to unlicensed cannabis activity on her property. Wheeler, who was 85 years old and had no criminal record, claimed she had no knowledge of the illegal activity. The trial court dismissed the charges against her, citing her age, clean record, and lack of knowledge about the illegal activity on her property. The People appealed the dismissal, arguing that the trial court erred in considering Wheeler's lack of knowledge because the charges were strict liability offenses.The appellate division of the superior court reversed the dismissal, agreeing with the People that the trial court should not have considered Wheeler's lack of knowledge. The appellate division reasoned that since the charges were strict liability offenses, Wheeler's lack of knowledge was not mitigating. Wheeler then petitioned the Court of Appeal for a writ of mandate to affirm the trial court's dismissal, but the Court of Appeal affirmed the appellate division's decision.The Supreme Court of California reversed the Court of Appeal's judgment. The Supreme Court held that a trial court has discretion to consider a defendant's lack of knowledge when deciding whether to dismiss charges in furtherance of justice under Penal Code section 1385, even for strict liability offenses. The Supreme Court reasoned that the nature of the charged offense and a defendant's minimal culpability can be relevant considerations for a section 1385 dismissal. The Supreme Court remanded the case to the Court of Appeal with instructions to issue a writ of mandate directing the appellate division to affirm the trial court's dismissal. View "Wheeler v. Appellate Division of Superior Court" on Justia Law

In the case before the Supreme Court of California, Another Planet Entertainment, LLC, a live entertainment venue operator, sued its insurer, Vigilant Insurance Company, for denying its claim for coverage of pandemic-related business losses. The plaintiff argued that the actual or potential presence of the COVID-19 virus at its venues constituted "direct physical loss or damage to property," triggering coverage under its insurance policy. The district court dismissed the case, and the plaintiff appealed. The Ninth Circuit Court of Appeals then asked the Supreme Court of California to clarify whether the presence of the COVID-19 virus could constitute "direct physical loss or damage to property" under California law.The Supreme Court of California concluded that allegations of the actual or potential presence of COVID-19 on an insured’s premises do not, without more, establish direct physical loss or damage to property within the meaning of a commercial property insurance policy. Under California law, direct physical loss or damage to property requires a distinct, demonstrable, physical alteration to property. The physical alteration need not be visible to the naked eye, nor must it be structural, but it must result in some injury to or impairment of the property as property. The court found that Another Planet’s allegations did not satisfy this standard. While Another Planet alleges that the COVID-19 virus alters property by bonding or interacting with it on a microscopic level, Another Planet does not allege that any such alteration results in injury to or impairment of the property itself. Its relevant physical characteristics are unaffected by the presence of the COVID-19 virus. View "Another Planet Entertainment, LLC v. Vigilant Insurance Co." on Justia Law

In 2007, Ishmael Michael Carter was committed to Coalinga State Hospital pending trial on a petition to commit him as a sexually violent predator (SVP) under the Sexually Violent Predator Act. After waiting for trial for over 12 years, Carter filed a motion to dismiss the petition, asserting his due process right to a timely trial. Additionally, he filed a motion to replace his public defender, believing the office would be disqualified from litigating the motion to dismiss on his behalf. The trial court denied Carter's motion to replace his counsel, declined to rule on the motion to dismiss, and conducted a trial resulting in Carter's indeterminate commitment as an SVP.The Court of Appeal affirmed the trial court's decisions. Carter argued that the trial court's inquiry into his request for new counsel was insufficient and required a full reversal of the judgment or, alternatively, a conditional reversal pending reconsideration of his request for new counsel and potential litigation of his motion to dismiss. The Attorney General agreed that the trial court should have investigated whether a potential conflict of interest would have prevented Carter's public defender from litigating the motion to dismiss.The Supreme Court of California held that the trial court conducted an insufficient inquiry into Carter's request for new counsel and erred in instructing Carter to file his motion to dismiss pro se. The court agreed with the Attorney General that a full reversal at this stage would be premature. The court conditionally reversed the judgment of the Court of Appeal and remanded the case with directions to conditionally vacate the SVP judgment and remand to the trial court for further proceedings consistent with this opinion. View "P. v. Carter" on Justia Law

The case involves Gustavo Naranjo and other plaintiffs who worked as guards for Spectrum Security Services, Inc. The plaintiffs alleged that Spectrum violated state regulations governing meal breaks by not providing legally compliant meal breaks and failing to pay an additional hour of pay, known as "premium pay," for each day on which this occurred. The plaintiffs also claimed that Spectrum violated Labor Code sections 201, 202, 203, and 226 by not timely paying owed meal break premiums as wages to employees once they were discharged or resigned, and by not reporting the premium pay it owed as wages on employees’ wage statements.The case has been through multiple stages of litigation. Initially, the trial court granted summary judgment for Spectrum, but this was reversed by the Court of Appeal. On remand, the trial court certified a class for the meal break and related timely payment and wage statement claims and held a trial in three phases. The trial court found that Spectrum had violated sections 203 and 226 by failing to pay and report the missed-break premium pay as wages. However, it issued a split decision on the question of penalties. It ruled in Spectrum’s favor regarding section 203 penalties, finding that Spectrum’s defenses were presented in good faith and were not unreasonable or unsupported by the evidence. But it ruled against Spectrum regarding section 226 penalties, finding that Spectrum was liable for penalties because its failure to report premium pay for missed meal breaks in employees’ wage statements was “knowing and intentional and not inadvertent.”Both sides appealed the trial court’s ruling. The Court of Appeal affirmed the trial court’s holding that Spectrum had violated meal break laws between June 2004 and September 2007. But it reversed the trial court’s holding that Spectrum had violated section 203 and section 226 by failing to timely pay and report the meal break premium pay owed as “wages,” reasoning that the premium pay was instead in the nature of a penalty rather than compensation for work performed.The Supreme Court of California held that if an employer reasonably and in good faith believed it was providing a complete and accurate wage statement in compliance with the requirements of section 226, then it has not knowingly and intentionally failed to comply with the wage statement law. The court affirmed the judgment of the Court of Appeal, which reached the same conclusion. View "Naranjo v. Spectrum Security Services, Inc." on Justia Law