Justia California Supreme Court Opinion Summaries

Unlike most other personal injury actions, which generally must be filed within two years of the date on which the challenged act or omission occurred, professional negligence actions against health care providers must be brought within one year after the plaintiff discovers, or should have discovered, the injury, pursuant to Cal. Civ. Proc. Code 340.5. Plaintiff was a hospital patient who was injured when one of the rails on her hospital bed collapsed. Plaintiff sued the hospital, claiming negligence in failing to inspect and maintain the equipment. The trial court dismissed the lawsuit, concluding that Plaintiff’s claim was untimely because it sounded in professional, rather than ordinary negligence, and therefore, the action was governed by the special limitations period in section 340.5. The Court of Appeal reversed, concluding that the hospital’s alleged failure to take reasonable precautions to make a dangerous condition safe sounded in ordinary negligence. The Supreme Court reversed, holding that the trial court correctly determined that section 340.5 was the applicable statute of limitations, and the Court of Appeal erred in holding to the contrary. View "Flores v. Presbyterian Intercommunity Hosp." on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and of attempting to dissuade a witness from testifying. At issue during trial was Defendant’s intellectual ability. Following a penalty phase, the jury returned a verdict of death. The trial court sentenced Defendant accordingly. The Supreme Court reversed the conviction for dissuading a witness, vacated the witness-killing special-circumstance finding, and otherwise affirmed, holding (1) the trial court did not err in failing to reinstate competency proceedings based on certain testimony; (2) the admission of a psychiatrist’s testimony did not violate state law or Defendant’s federal constitutional rights; (3) the trial court did not prejudicially err in permitting three lay witnesses to testify that they did not categorize Defendant as intellectually disabled; (4) the trial court did not err in overruling defense objections to questions the prosecutor posed to a witness as to whether it was possible Defendant had received information on how to “fake” psychological tests while in jail; (5) the trial court committed prejudicial error in instructing the jury in regard to Defendant’s intellectual disability evidence, requiring reversal of the dissuading count and the witness-killing special-circumstance finding; and (6) no prejudicial error occurred during the penalty phase, and the death penalty is both lawful and constitutional. View "People v. Townsel" on Justia Law

At issue in this case was California wage order requirements that an employer provide suitable seating for employees under certain circumstances. In two related federal appeals, the Ninth Circuit certified three questions to the Supreme Court regarding wage orders stating that “[a]ll working employees shall be provided with suitable seats when the nature of the work reasonably permits the use of seats.” The Court answered the questions as follows: (1) the “nature of the work” refers to an employee’s tasks performed at a given location for which a right to a suitable seat is claimed, and if the tasks being performed at a given location reasonably permit sitting and provision of a seat would not interfere with the employee’s tasks that require standing, a seat is called for; (2) whether the nature of the work “reasonably permits” sitting is a question to be determined objectively based on the totality of the circumstances; and (3) if an employer argues that there is no suitable seat available, the burden is on the employer to show that compliance is infeasible. View "Kilby v. CVS Pharmacy, Inc." on Justia Law

As a condition of her employment with Defendants, Plaintiff signed an agreement to resolve any employment-related disputes through arbitration. After Plaintiff resigned, she filed a complaint against Defendants, alleging that she suffered harassment, discrimination, and retaliation during the course of her employment. Defendants filed a motion to compel arbitration. Plaintiff opposed the motion, asserting that it was unconscionable. The trial court agreed with Plaintiff and denied the motion to compel arbitration. The court of appeal reversed. The primary issue before the Supreme Court was whether the arbitration agreement was unconscionable because of a clause in the agreement providing that, in the event a claim proceeds to arbitration, the parties are authorized to seek preliminary injunctive relief in the superior court. The Supreme Court affirmed, holding that the arbitration agreement was not unconscionable because the clause did no more that restate existing law. View "Baltazar v. Forever 21, Inc." on Justia Law

As a condition of her employment with Defendants, Plaintiff signed an agreement to resolve any employment-related disputes through arbitration. After Plaintiff resigned, she filed a complaint against Defendants, alleging that she suffered harassment, discrimination, and retaliation during the course of her employment. Defendants filed a motion to compel arbitration. Plaintiff opposed the motion, asserting that it was unconscionable. The trial court agreed with Plaintiff and denied the motion to compel arbitration. The court of appeal reversed. The primary issue before the Supreme Court was whether the arbitration agreement was unconscionable because of a clause in the agreement providing that, in the event a claim proceeds to arbitration, the parties are authorized to seek preliminary injunctive relief in the superior court. The Supreme Court affirmed, holding that the arbitration agreement was not unconscionable because the clause did no more that restate existing law. View "Baltazar v. Forever 21, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment on appeal, holding (1) no prejudicial error occurred in the jury selection process; (2) substantial evidence supported Defendant’s convictions; (3) the trial court did not err in its evidentiary rulings; (4) the prosecutor did not engage in impermissible misconduct during closing argument; (5) the trial court did not commit prejudicial error in its instructions to the jury; and (6) Defendant’s challenges to California’s death penalty statute were without merit. View "People v. Rangel" on Justia Law

Plaintiff filed a class action lawsuit against the City of Los Angeles challenging the validity of a certain tax and seeking a refund of taxes. In 2007, during discovery proceedings in the underlying litigation, the trial court determined that certain documents the City possessed were privileged under either the the attorney-client privilege or the privilege for attorney work product. In 2013, Plaintiff filed a request under the California Public Records Act seeking to obtain copies of documents relating to the tax at issue. The City’s administrative office, in response, inadvertently provided Plaintiff with some of the privileged documents. The City filed a motion for an order compelling the return of the privileged material. The trial court denied the motion, concluding that the production of the documents under the Public Records Act had waived any privilege. The Court of Appeal affirmed. The Supreme Court reversed, holding that Cal. Gov’t Code 6254.5, which generally provides that “disclosure” of a public record waives any privilege, applies to an intentional, not an inadvertent, disclosure. Remanded. View "Ardon v. City of Los Angeles" on Justia Law

Charges that Defendants committed attempted murder were twice dismissed. Thereafter, the People charged Defendants with conspiracy to commit murder based on the same underlying facts as the dismissed charges. At issue in this case was whether Cal. Penal Code 1387, which generally permits a felony charge to be dismissed and refiled once but not twice barred Defendants’ prosecution for conspiracy to commit murder. Defendants moved to dismiss the complaint under section 1387. The magistrate denied the motion. Defendants then filed a petition for writ of habeas corpus. The superior court granted the petition and dismissed the case. The Court of appeal reversed, concluding that conspiracy to commit murder is not the “same offense” as attempted murder under section 1387, and thus the statute did not bar prosecution for that crime. The Supreme Court reversed, holding that because the conspiracy to commit murder charges, as pleaded, contain all of the elements of the previously dismissed attempted murder charges, they are the same offenses as the previous charges under section 1387. View "People v. Juarez" on Justia Law

At issue in this case was whether a plaintiff who voluntarily dismisses an action after entering into a monetary settlement is a “prevailing party” for purposes of Cal. Civ. Proc. Code 1032(a)(4) and thus entitled to recover costs in an action or proceeding. After the parties in this case entered into a settlement, Plaintiff voluntarily dismissed two causes of action against Defendant. The trial court adjudged that Plaintiff recover nothing from Defendant. The court of appeal reversed, concluding that Plaintiff had obtained a “net monetary recovery” under section 1032(a)(4) and was therefore the prevailing party. The Supreme Court affirmed, holding (1) a dismissal pursuant to a monetary settlement is not a dismissal in the defendant’s “favor” as that term is used in section 1032(a)(4); and (2) a plaintiff that enters into a stipulated judgment to be paid money in exchange for a dismissal has obtained a “net monetary recovery” within the meaning of section 1032(a)(4), regardless of whether the judgment mentions the settlement. View "DeSaulles v. Cmty. Hosp. of the Monterey Peninsula" on Justia Law

Defendant entered a commercial store with the intent to commit a robbery inside. After accomplishing the robbery, Defendant took a store employee to a bathroom in the back of the business, bound her hands, and raped her. After a jury trial, Defendant was convicted of aggravated kidnapping, forcible rape, and two burglaries. The verdict reflected the jury’s determination that Defendant committed two burglaries first when he entered the store, and then when he entered the bathroom, with the intent to commit a felony inside each space. The court of appeal affirmed. The Supreme Court reversed the court of appeal’s judgment upholding Defendant’s two burglary convictions, holding that the fact that a defendant has committed two entries with felonious intent into a structure and a room within that structure does not, by itself, permit multiple burglary convictions. View "People v. Garcia" on Justia Law