Justia California Supreme Court Opinion Summaries

Financial Casualty & Surety, Inc. posted a bail bond on behalf of Oscar Grijalva. The bail was subsequently forfeited. Under Cal. Penal Code 1305, the bond would be exonerated if Grijalva appeared in court by the 185th day after the notice was mailed. Five days after the appearance period ended, Financial Casualty moved to extend the period under section 1305.4. The trial court granted an extension for fewer than 180 days. At the end of the extension period, Financial Casualty filed a second extension motion. The trial court denied the second extension motion and entered summary judgment on the bond. The court of appeal affirmed. The Supreme Court affirmed, holding (1) a trial court may weigh the likelihood of apprehension in deciding whether the surety has shown good cause for an extension; (2) because at the time Financial Casualty’s second extension motion was heard fewer than 180 days had passed since the first extension was ordered, the trial court had discretion to grant a further extension; and (3) the trial court did not abuse its discretion in considering, as grounds for denying the extension of the period for exonerating the bail bond, that Financial Casualty had not shown the requests extension was likely to produce Grijalva’s appearance in court. View "People v. Financial Casualty & Surety, Inc." on Justia Law

Defendant filed a motion to suppress the evidence found on his phone, arguing that the search of his phone resulted from an unduly prolonged and unjustified detention. The trial court denied the motion, concluding that the phone search was justified under the existing authority of People v. Diaz. The court of appeals affirmed, acknowledging that Diaz’s reasoning was repudiated in Riley v. California but determining that the good faith exception applied because Diaz was controlling law at the time. The Supreme Court reversed, holding (1) the phone search was conducted without a warrant and was improper; and (2) the good faith exception did not apply in this case because the search was not authorized by Diaz. View "People v. Macabeo" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. The jury returned a verdict of death, and the trial court entered the death judgment. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in denying Defendant’s motion for mistrial for discovery violations; (2) the prosecutor did not engage in prejudicial misconduct; (3) the trial court’s rulings regarding Defendant’s proffered third party culpability evidence were not in error; (4) the trial court did not abuse its discretion when it failed to exclude evidence of Defendant’s past uncharged incidents of sexual misconduct; (5) the trial court did not violate Defendant’s due process right to a fair trial in refusing to allow into evidence videotaped interviews of defense witnesses; (6) the trial court did not err in sustaining the prosecution’s objection to testimony that Defendant was alcohol dependent; (7) the trial court did not err in instructing the jury during the penalty phase; and (8) there was no constitutional violation of the state’s death penalty law. View "People v. Williams" on Justia Law

Domestic or take-home exposure to asbestos occurs when a worker who is directly exposed to a toxin carries it home on his person or clothing and a member of his household is exposed through physical proximity with that worker or the worker’s clothing. Plaintiffs filed these actions for personal injury and wrongful death, alleging that take-home exposure to asbestos was a contributing cause to the deaths of the two decedents and that the employers of the decedents’ family members had a duty to prevent this exposure. The trial and appellate courts in the two cases reached varying conclusions as to the existence of a duty on the part of users of asbestos to prevent nonemployees who have never visited their facilities from being exposed to asbestos used in the defendants’ business. The Supreme Court held (1) employers have a duty to prevent exposure to asbestos carried by the bodies and clothing got on-site workers, and where it is reasonably foreseeable that workers will carry asbestos from the premises to household members, employers have a duty to take reasonable care to prevent this means of transmission; and (2) this duty, which also applies to premises owners who use asbestos on their property, extends only to members of a worker’s household. View "Kesner v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of both conspiracy to murder and the first-degree murder of her husband. The jury set the penalty at death after weighing aggravating and mitigating evidence presented by the parties. The Supreme Court affirmed the guilt and penalty judgments in their entirety, holding (1) the trial court’s determinations that seven jurors were all substantially impaired and subsequent exclusion of the jurors due to their views on the death penalty was adequately supported by the record; (2) the trial court did not err by denying Defendant’s motions to sever her trial from that of her codefendant; (3) the trial court did not commit reversible error in its rulings regarding several discovery issues; (4) the trial court did not err in its evidentiary rulings; (4) the jury instructions were proper; and (5) no prejudicial error occurred during the penalty phase of trial. View "People v. Thompson" on Justia Law

Seller retained Coldwell Banker Residential Brokerage Company to list a luxury residence for sale. Buyer, also represented by Coldwell Banker, made an offer to purchase the property, and both parties agreed that Coldwell Banker, acting through its associate licensee, would function as a dual agent in the transaction. After the sale was complete, Buyer filed suit alleging breach of fiduciary duty by Coldwell Banker and by the associate licensee because of a significant discrepancy between the square footage of the residence as represented in the marketing materials for the property and as set out in its building permit. The trial court granted nonsuit on the cause of action against the associate licensee, ruling that the associate licensee had no fiduciary duty to Buyer. A jury subsequently found in favor of Coldwell Banker. The Court of Appeal reversed the judgment on the breach of fiduciary duty claim against the associate licensee and Coldwell Banker. The Supreme Court affirmed, holding (1) Coldwell Banker owed to Buyer a duty to learn nd disclose information regarding the discrepancy between the square footage of the residence as advertised and as reflected in publicly recorded documents; and (2) the associate licensee owed Buyer an equivalent duty of disclosure under Cal. Civ. Code. 2079.13(b). View "Horiike v. Coldwell Banker Residential Brokerage Co." on Justia Law

If a patient who receives emergency medical services is an enrollee in a health care service plan, the plan is required to reimburse the emergency service provider for essential emergency medical services and care. Plans are statutorily permitted to delegate this financial responsibility to their contracting medical providers. Here the defendants - health care service plans - delegated their emergency services financial responsibility to their contractor medical providers, three individual practice associations (“IPAs”). The IPAs failed to reimburse the plaintiff noncontracting service providers for the emergency care that they provided to enrollees of the defendant health plans. When the IPAs went out of business, the plaintiff providers brought actions seeking reimbursement from the defendants. The Supreme Court held (1) a health care service plan may be liable to noncontracting emergency service providers for negligently delegating its financial responsibility to an IPA or other contracting medical provider group that it knew or should have known would not be able to pay for emergency service and care provided to the health plan’s enrollees; and (2) a health care service plan has a narrow continuing common law tort duty to protect noncontracting emergency service providers once it makes an initial delegation of its financial responsibility. View "Centinela Freeman Emergency Medical Associates v. Health Net of California" on Justia Law

Petitioner was charged with robbery. Pursuant to a plea agreement, Petitioner pleaded guilty to grand theft from the person, a felony, and admitted a prior robbery conviction on condition that he receive a six-year prison sentence. The People, in return, dismissed the robbery charge. The electorate later enacted Proposition 47, which reduced the grand theft offense to a misdemeanor. Defendant filed a petition for recall of sentence, asking the trial court to resentence him as a misdemeanant. The trial court denied relief, concluding that reducing the sentence would deprive the People of the benefit of their plea bargain, and thus they should be permitted to rescind the plea and reinstate the original robbery charge. The Court of Appeal affirmed. The Supreme Court reversed, holding that the People were not entitled to set aside the plea agreement when Defendant sought to have his sentence recalled under Proposition 47. View "Harris v. Superior Court of Los Angeles County" on Justia Law

Petitioner, an inmate, filed a petition for writ of habeas corpus, alleging that he received ineffective assistance of counsel in his criminal proceedings. One week later, Petitioner asked the court clerk for the name of the judge assigned to his petition. Superior Court Judge John M. Thompson subsequently summarily denied Petitioner’s habeas corpus petition. Petitioner then filed a new petition for writ of habeas corpus, and, in addition, Petitioner alleged that he was denied his statutory right to peremptorily challenge Judge Thompson. The Court of Appeal issued a writ of mandate directing the superior court to reassign the assessment of Maas’s petition for writ of habeas corpus to a judge other than Judge Thompson. The Supreme Court affirmed, holding that a petitioner who requests the name of the judge assigned to examine his habeas corpus petition is entitled to notice of that assignment and is entitled to peremptorily challenge the assigned judge, so long as all of the procedural requirements of Cal. Civ. Proc. Code 170.6 have been satisfied. View "Maas v. Superior Court" on Justia Law

In 2006, the San Mateo Community College District and its Board of Trustees (collectively, District) proposed a district-wide facilities improvement plan that called for demolishing certain buildings and renovating others. The District approved the plan, determining that it would have no potentially significant, unmitigated effect on the environment. In 2011, the District proposed changes to the plan. The District approved the changes, determining that they did not require the preparation of a subsequent or supplemental environmental impact report under Public Resources Code section 21166 and CEQA Guidelines section 15162. The Court of Appeal invalidated the District’s decision, ruling that the District’s proposal was a new project altogether and, therefore, subject to the initial environmental review standards of Public Resources Code section 21151 rather than the subsequent review standards of section 21166 and section 15162. The Supreme Court reversed, holding that the Court of Appeal erred in its application of the new project test. Remanded for further proceedings. View "Friends of College of San Mateo Gardens v. San Mateo Cmty. College Dist." on Justia Law