Justia California Supreme Court Opinion Summaries

Plaintiffs filed suit against defendants alleging claims of medical malpractice and then later filed a claim for elder abuse. At issue is whether the definition of neglect under the Elder Abuse and Dependent Adult Civil Protection Act, Welf. & Inst. Code, 15600 et seq., applies when a health care provider - delivering care on an outpatient basis - fails to refer an elder patient to a specialist. The court concluded that the Act does not apply unless the defendant health care provider had a substantial caretaking or custodial relationship, involving ongoing responsibility for one or more basic needs, with the elder patient. It is the nature of the elder or dependent adult‘s relationship with the defendant - not the defendant‘s professional standing - that makes the defendant potentially liable for neglect. In this case, because defendants did not have a caretaking or custodial relationship with the decedent, the court found that plaintiffs cannot adequately allege neglect under the Elder Abuse Act. Plaintiffs rely solely on defendants‘ allegedly substandard provision of medical treatment, on an outpatient basis, to an elder. But without more, such an allegation does not support the conclusion that neglect occurred under the Elder Abuse Act. View "Winn v. Pioneer Med. Grp." on Justia Law

Defendant was charged with carrying a loaded firearm on his person. The charge stemmed from an incident in which Defendant was wearing a backpack containing a loaded revolver while being pursued by a police officer. The trial court granted Defendant’s motion to dismiss, finding that the firearm was not carried “on the person.” The court of appeal reversed, holding that a person wearing a backpack containing a firearm carries the firearm on his person. The Supreme Court affirmed, holding that the backpack was on Defendant’s person and, accordingly, anything inside that backpack was also on his person. View "People v. Wade" on Justia Law

In a joint trial with her codefendant, Defendant was convicted of premeditated murder and attempted premeditated murder. The court of appeal reversed Defendant’s convictions, concluding (1) the trial court erred in instructing the jury regarding a testifying defendant’s failure to explain or deny incriminating trial evidence; (2) the trial court erred in admitting Defendant’s codefendant’s out-of-court statement that he and Defendant went to shoot some gang members; and (3) the prosecution committed misconduct during closing argument in commenting about the reasonable doubt standard. The Supreme Court reversed, holding (1) the trial court properly gave the instruction at issue; (2) the trial court properly admitted the codefendant’s out-of-court statement; and (3) the prosecution’s comments on reasonable doubt did not constitute misconduct. View "People v. Cortez" on Justia Law

Plaintiff initiated an unlawful detainer action against Defendant. The jury returned a verdict in Plaintiff’s favor. Defendant’s attorney then substituted out of the case, and Defendant proceeded with self-representation. Plaintiff was awarded attorney fees. Defendant’s appeals from the underlying judgment and from the attorney fees award were consolidated. In a separately filed action in which Defendant was the plaintiff, the Court of Appeal declared Defendant a vexatious litigant plaintiff. Consequently, the presiding judge in the instant case directed Defendant to obtain permission to continue the Chan v. John consolidated appeal or to file a substitution of attorney before proceeding further. Defendant sought to vacate the prefiling order. The presiding judge declared that the court lacked jurisdiction to vacate the prefiling motion and dismissed Defendant’s consolidated appeals. The Court of Appeal vacated the appellate division’s order, holding that a defendant’s status as a vexatious litigant plaintiff in one matter cannot limit the same defendant’s ability to pursue her appeal in an action she did not initiate as a plaintiff. The Supreme Court affirmed, holding that Cal. Civ. Proc. Code 391.7’s prefiling requirements do not apply to a self-represented vexatious litigant’s appeal of a judgment or interlocutory order in an action in which she was the defendant. View "John v. Superior Court of Los Angeles County" on Justia Law

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