Justia California Supreme Court Opinion Summaries

Under Cal. Code Civ. Proc. 580b, when an individual borrows money from a bank to buy a home and the bank forecloses on the home, the bank can collect proceeds from the foreclosure sale but may not obtain a deficiency judgment against the borrower. In this case, a Borrower arranged a short sale of her home and sold her home to a third party for an amount that fell short of her outstanding loan balance to a Bank. The Bank then demanded the balance remaining on the Borrower’s home. The Borrower brought this declaratory action, claiming that section 580b prohibited the Bank from collecting the deficiency. The trial court sustained the Bank’s demurrer. The court of appeals reversed, concluding that section 580b’s protections apply after a short sale, not just a foreclosure. The Supreme Court affirmed, holding that section 580b applies to short sales just as it does to foreclosure sales. View "Coker v. JPMorgan Chase Bank" on Justia Law

A grand jury returned an indictment against Defendant on charges of conspiracy to commit murder and active participation in a criminal street gang. The grand jury found reasonable cause to believe that Defendant came within the provisions of Cal. Welf. & Inst. Code 707(d)(4). Defendant initially pleaded not guilty but later demurred to the indictment, arguing that section 707(d)(4) requires a determination that a juvenile qualifies for prosecution in adult court, and because he was a juvenile at the time of the alleged offenses, the grand jury had no legal authority to inquire into the charged offenses. The trial court agreed with Defendant, allowed him to withdraw his plea, and sustained his demurrer. The court of appeal reversed. The Supreme Court affirmed, holding that section 707(d) allows prosecutors the option of filing charges against certain juveniles accused of specified offenses in criminal court by grand jury indictment. View "People v. Arroyo" on Justia Law

In 2014, the California Legislature sought to place on the general election ballot Proposition 49, a nonbinding advisory question that would have asked the electorate whether Congress should propose, and the Legislature ratify, a federal constitutional amendment overturning the U.S. Supreme Court’s decision in Citizens United v. Federal Election Commission. Petitioners filed an original emergency petition for writ of mandate in the Supreme Court seeking to prevent the Secretary of State from proceeding with placement of Proposition 49 on the November 2014 ballot. The Supreme Court issued an order to show cause and stayed the Secretary from taking further actions in connection with Proposition 49 until after a final decision, effectively removing the advisory question from the November 2014 ballot. Despite this case being moot, the Court resolved the merits of Proposition 49’s constitutionality. The Court denied the instant petition for a writ of mandate, holding that Proposition 49 is reasonably related to the Legislature’s authority to use advisory questions to inform the Legislature’s exercise of its powers under U.S. Const., art. V, and therefore, Proposition 49 is constitutional. View "Howard Jarvis Taxpayers Ass’n v. Padilla" on Justia Law

In 1974, the state of California joined the Multistate Tax Compact, which contained an apportionment formula and permitted a taxpayer election between the Compact’s formula and any other formula provided by state law. In 1993, the Legislature adopted a different apportionment formula by amending the Revenue and Taxation Code to provide that, notwithstanding the Compact’s provisions, the new apportionment formula “shall” apply. Between 1993 and 2005, six multistate corporations (Taxpayers) paid income tax calculated under the new formula but then sought a refund, contending that they remained entitled to elect between the new statutory formula and that contained in the Compact. The trial court concluded that the Legislature could, consistent with the Compact, eliminate the election provision. The court of appeal reversed. The Supreme Court reversed, holding that the Legislature may properly preclude a taxpayer from relying on the Compact’s election provision. View "Gillette Co. v. Franchise Tax Bd." on Justia Law

After a jury trial, Defendant was convicted of premeditated murder and attempted murder. The jury found that the murder was committed with the special circumstance that the victim was a peace officer engaged in the lawful performance of his duties and that it was committed by means of lying in wait for the purpose of preventing a lawful arrest. Defendant was sentenced to death. The Supreme Court reversed the special circumstance finding that Defendant committed the murder by means of lying in wait but otherwise affirmed, holding (1) Defendant was prejudiced by the trial court’s failure to sua sponte instruct on circumstantial evidence as it relates to the lying-in-wait special circumstance; and (2) no other prejudicial error occurred. View "People v. Sandoval" on Justia Law

In 2010, the Bar Area Air Quality Management District passed a resolution adopting new thresholds of significance for air pollutants and published new California Environmental Quality Act (CEQA) air quality guidelines. The California Building Industry Association (CBIA) filed a petition for writ of mandate challenging these thresholds. The superior court entered judgment in favor of CBIA, concluding that the District’s promulgation of the 2010 thresholds was a “project” subject to CEQA review, and the District was bound to evaluate the thresholds’ potential impact on the environment. The Court of Appeal reversed, concluding that the promulgation of the 2010 thresholds was not a project subject to CEQA review. The Supreme Court reversed, holding (1) CEQA does not generally require an agency to consider the effects of existing environmental conditions on a proposed project’s future users or residents except in specific instances; and (2) because the Court of Appeal’s analysis of CBIA’s petition for writ relief did not address potentially important arguments for and against such relief in light of CEQA’s requirements as interpreted in this opinion, this case is remanded so the court may have an opportunity to address those issues. View "Cal. Building Ind. Ass’n v. Bay Area Air Quality Mgmt. Dist." on Justia Law

Plaintiff was seriously injured in a collision between his vehicle and another that occurred at an intersection in San Diego County. Plaintiff and his wife sued the County for maintaining an allegedly dangerous condition of public property, claiming that the design and construction of the intersection where the accident occurred afforded inadequate visibility under applicable County design standards. The trial court granted summary judgment in favor of the County on the basis of design immunity. The Court of Appeal affirmed, concluding that the County had established the defense of design immunity for the purpose of summary judgment. At issue before the Supreme Court was second element a public entity claiming design immunity must establish - discretionary approval. The Supreme Court affirmed, holding (1) the issue of the adequacy of the deliberative process with respect to design standards may be considered in connection with the court’s determination whether there is substantial evidence that the design was reasonable; and (2) the discretionary approval element does not require the public entity to demonstrate in its prima facie case that the employee who had authority to and did approve the plans also had authority to disregard applicable standards. View "Hampton v. County of San Diego" on Justia Law

Defendant was convicted of petty theft with a prior-theft related conviction. Before Defendant was released from prison, the Board of Parole Hearings found that Defendant met the criteria for commitment as a Mentally Disordered Offender (MDO) under Cal. Penal Code 2969(d)(1) and (e)(2)(Q). Defendant petitioned for a hearing to challenge the Board’s determination. The court eventually concluded that Defendant met all the necessary MDO Act criteria specified in section 2962. The Court of Appeal affirmed. The Supreme Court reversed, holding (1) a mental health expert’s opinion testimony in support of a defendant’s commitment under the MDO Act may not be used to prove the defendant committed a qualifying offense for commitment involving one of the offenses specified in section 2962(e)(2)(A) through (O) or involved behavior described in subdivision (e)(2)(P) or (Q); (2) mental health experts may not testify about a topic that is not sufficiently beyond common experience; and (3) the prosecution failed to present evidence other than its mental health expert’s opinion testimony and supporting foundational facts, and that expert improperly opined on a topic that is not beyond common experience, and therefore, substantial evidence did not support the trial court’s finding on the MDO commitment. Remanded. View "People v. Stevens" on Justia Law

This case was a putative class action challenging an herb grower’s (Defendant) marketing of its herbs as organic. Defendant sought judgment on the pleadings on federal preemption and primary jurisdiction grounds, arguing that the Organic Foods Production Act of 1990 vests the United States Department of Agriculture with exclusive authority to to regulate the labeling and marketing of organic products and both expressly and impliedly preempts state truth-in-advertising requirements. The trial court agreed and entered a judgment for Defendant. The Court of Appeals affirmed, concluding that the express preemption provisions in the Organic Food Act did not foreclose state false advertising suits, but such suits were impliedly preempted. The Supreme Court reversed, holding that a state law claim that produce is being intentionally mislabeled as organic is neither expressly nor impliedly preempted. Remanded. View "Quesada v. Herb Thyme Farms, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and of being a felon in possession of a firearm. The trial court sentenced Defendant to death for the two murders. The Supreme Court affirmed the judgment in its entirety, holding (1) during the guilt phase, the trial court did not err in admitting evidence of Defendant’s past crimes and bad acts against his family; (2) the evidence was sufficient to support the first-degree murder convictions; (3) the jury instructions during both the guilt phase and the penalty phase were constitutional; (4) the trial court did not err in admitting purported victim impact testimony during either the guilt phase or the penalty phase; (5) the trial court did not err in admitting crime scene and autopsy photographs during the guilt phase; (6) Defendant’s death sentence was not grossly disproportionate to Defendant’s personal culpability; and (7) Defendant’s challenges to California’s death penalty scheme failed. View "People v. Cage" on Justia Law