Justia California Supreme Court Opinion Summaries

The Supreme Court of California, in a case involving a dispute over California's lemon law, ruled in favor of the plaintiff, Lisa Niedermeier. Niedermeier had purchased a new Jeep Wrangler from FCA US LLC, which was defective. Despite numerous attempts to repair the vehicle, the issues persisted. Niedermeier requested FCA buy back the vehicle, but FCA declined. Eventually, she traded in the defective vehicle for a new one, receiving a trade-in credit.Niedermeier later sued FCA for breach of warranty under the Song-Beverly Consumer Warranty Act. A jury found in her favor and awarded her a significant sum. FCA appealed, arguing the award should be reduced by the trade-in amount. The Court of Appeal agreed with FCA, but the Supreme Court reversed this decision.The Supreme Court held that in an action under the Song-Beverly Act, neither a trade-in credit nor sale proceeds reduce the statutory restitution remedy. The court reasoned that the Act's plain language does not permit such a reduction. Additionally, the court found that this interpretation is supported by the legislative history and consumer-protective purpose of the Act. The court further noted that allowing such a reduction would incentivize manufacturers to delay compliance with the Act.The court concluded that the statutory restitution remedy should not be reduced by a trade-in credit or sale proceeds, at least in cases where a consumer is forced to trade in or sell a defective vehicle due to the manufacturer's failure to comply with the Act. Therefore, the court reversed the judgment of the Court of Appeal. View "Niedermeier v. FCA US LLC" on Justia Law

In this case, the Supreme Court of California held that a trial court has discretion to grant or deny relief from a jury trial waiver under section 631(g) of the Code of Civil Procedure. The court is not required to grant relief just because proceeding with a jury would not cause hardship to other parties or the court. The court should consider various factors, including the timeliness of the request and the reasons supporting the request. The court further held that a litigant who challenges the denial of relief from a jury waiver for the first time on appeal must show actual prejudice to obtain reversal.The case involved TriCoast Builders, Inc. and Nathaniel Fonnegra. Fonnegra hired TriCoast to repair his house after a fire, but he was unhappy with the quality of the work and terminated the contract. TriCoast sued Fonnegra for damages. Fonnegra initially demanded a jury trial, but waived this right on the day of the trial. TriCoast, which had not demanded a jury trial or paid the jury fee, requested a jury trial after Fonnegra’s waiver. The trial court denied their request and a bench trial was held. TriCoast appealed the judgment, arguing that the trial court erred in denying their request for a jury trial. The Supreme Court affirmed the judgment of the Court of Appeal, concluding that TriCoast had not established the prejudice necessary to justify reversing the trial court's judgment. View "TriCoast Builders, Inc. v. Fonnegra" on Justia Law

In this case, the Supreme Court of California was asked to interpret the "collective engagement" requirement under the California Penal Code section 186.22(f) and its application to the proof of predicate offenses. This requirement was introduced through Assembly Bill 333, which amended gang sentencing provisions. The defendant, Kejuan Darcell Clark, a member of the Northside Parkland street gang, was charged with several offenses related to a home invasion and assault. The prosecution sought to apply gang enhancements under section 186.22, subdivision (b).The court held that the term "collective engagement" in section 186.22(f) does not require that each predicate offense must have been committed by at least two gang members acting in concert. Rather, the court interpreted the term to require a showing that links the two predicate offenses to the gang as an organized, collective enterprise. This can be demonstrated by evidence linking the predicate offenses to the gang's organizational structure, its primary activities, or its common goals and principles.The court reversed the judgment of the Court of Appeal as to Clark's gang enhancement and remanded the case for further proceedings to apply this interpretation of the collective engagement requirement. View "P. v. Clark" on Justia Law

In this case before the Supreme Court of California, the court interprets the provisions regarding the modification of a revocable trust under California Probate Code sections 15401 and 15402. The dispute revolves around a trust created by Jeane M. Bertsch, which was amended multiple times, with the final amendment excluding her niece, Brianna McKee Haggerty, from distribution. Haggerty challenged the validity of the final amendment, arguing that it was not properly notarized as required by the modification method specified in the trust agreement.The court held that under section 15402 of the Probate Code, a trust may be modified using the procedures set out under section 15401 for revocation, including the statutory method, unless the trust instrument specifies a method of modification and makes it exclusive, or it expressly precludes the use of revocation procedures for modification. The court clarified that merely distinguishing between revocation and modification in the trust instrument does not preclude the use of revocation procedures for modification.The court affirmed the judgment of the Court of Appeal, which held that Bertsch’s final amendment was a valid modification, since the trust agreement did not explicitly state that the specified method of modification was exclusive or expressly preclude the use of revocation procedures for modification.The court disapproved previous appellate decisions that were inconsistent with this holding, including King v. Lynch, Balistreri v. Balistreri, Diaz v. Zuniga, Pena v. Dey, Conservatorship of Irvine, and Haggerty v. Thornton. View "Haggerty v. Thornton" on Justia Law

In 2019, the California Supreme Court ruled that the defendant, Oscar Manuel Vaquera, did not receive fair notice of the sentence that the prosecution was seeking in his case, which violated his right to due process. Vaquera was charged with two counts of a sex offense covered by California's "One Strike" law and was convicted on both counts. In the habeas corpus proceeding, Vaquera challenged the 25-year-to-life sentence the trial court imposed for the second count.The prosecution had initially requested a sentence of 15 years to life for the second count, but later argued for a 25-year-to-life sentence under a different provision of the One Strike law. Vaquera contended that the imposition of the 25-year-to-life sentence violated due process because he did not receive fair notice that the prosecution intended to seek that sentence. The California Supreme Court agreed with Vaquera and ordered the trial court to resentence him to 15 years to life for the second count.The Court ruled that the One Strike allegation in Vaquera's case did not provide him with fair notice that the prosecution was seeking a 25-year-to-life sentence under the specific provision of the law based on the victim's age. The Court held that due process requires an accusatory pleading to inform the defendant of the particular One Strike sentence the prosecution is seeking and of the factual basis it intends to prove to support that sentence. In this case, the prosecution did not provide fair notice of its intent to seek the longer One Strike sentence, which violated Vaquera's due process rights. View "In re Vaquera" on Justia Law

In the case before the Supreme Court of California, the dispute revolved around a residential driveway in Sierra Madre and raised a significant question about the law of easements. The plaintiffs, Tatana Spicakova Romero and Cesar Romero, and the defendants, Li-Chuan Shih and Tun-Jen Ko, owned neighboring properties that were previously a single parcel divided and sold in 1986. An eight-foot-wide strip of land, which belonged to the Romeros but had been used as the driveway for the Shih-Kos' home, was in dispute. The trial court concluded that the parties to the 1986 sale had intended to create an implied easement over this strip of land, allowing the Shih-Kos to continue using it as a driveway. The Court of Appeal reversed, arguing that the law prohibits a court from recognizing an implied easement that precludes the property owners from making all or most practical uses of the easement area.The Supreme Court of California disagreed with the Court of Appeal's interpretation and held that the law does not impose such a limitation on the recognition of implied easements. The court emphasized that the evidentiary standard for recognizing an implied easement is a high one, and it will naturally be more difficult to meet where the nature of the easement effectively precludes the property owners from making most practical uses of the easement area. However, if there is clear evidence that the parties to the 1986 sale intended for the neighboring parcel’s preexisting use of the area to continue after separation of title, the law obligates courts to give effect to that intent. The court reversed and remanded the case back to the Court of Appeal to consider whether substantial evidence supports the trial court’s finding that an implied easement existed under the circumstances of this case. View "Romero v. Shih" on Justia Law

In the Supreme Court of California, the defendant, Glen Taylor Helzer, pleaded guilty to five counts of murder and multiple other charges, including robbery, kidnapping, and conspiracy. After a penalty trial, the jury sentenced him to death for the five counts of murder. The murders were particularly gruesome, involving kidnapping, robbery, and dismemberment of the bodies. The defendant argued that he was under the influence of methamphetamine and suffering from a mental or emotional disturbance at the time of the crimes. On appeal, the defendant raised several issues, including the exclusion of a potential juror due to their views on the death penalty, the denial of a proposed question during jury selection, and the admission of graphic evidence including photographs of the dismembered bodies and the sound of a power saw used in the dismemberment during the prosecution's closing argument. The court affirmed the judgment, finding that the trial court did not abuse its discretion in its rulings and that any error was harmless. The court held that the photographs and the sound of the saw were relevant to the circumstances of the crimes and did not unduly prejudice the jury. The court also held that the removal of a potential juror due to their views on the death penalty did not violate the defendant's right to a representative jury. View "People v. Helzer" on Justia Law

In the Supreme Court of California, the case revolved around the question of whether trial courts have the inherent authority to dismiss a claim under the Labor Code Private Attorneys General Act of 2004 (PAGA) on the grounds of manageability. PAGA permits aggrieved employees to act as private attorneys general to recover civil penalties on behalf of the state for Labor Code violations. In this case, defendant Royalty Carpet Mills, Inc. (Royalty) argued that trial courts should have the power to dismiss PAGA claims if they are deemed unmanageable.The Supreme Court of California held that trial courts do not have the inherent authority to dismiss PAGA claims on manageability grounds. The court emphasized that trial courts do not generally possess a broad inherent authority to dismiss claims, nor is it appropriate for them to dismiss PAGA claims by using class action manageability requirements. The court also affirmed the judgment of the Court of Appeal, which had reached the same conclusion.The court also discussed the facts of the case. Jorge Luis Estrada and Paulina Medina, former employees of Royalty, brought a PAGA claim against the company for alleged violations of Labor Code provisions requiring the provision of meal periods. The trial court certified a class action suit and later decertified it, dismissing the PAGA claim on manageability grounds. The Court of Appeal reversed this decision, which led to Royalty's appeal to the Supreme Court.The Supreme Court stated that while trial courts may use various tools to efficiently manage PAGA claims, striking such claims due to manageability concerns is not among these tools. It also noted that while trial courts and the Labor and Workforce Development Agency (LWDA) share discretion in assessing a civil penalty, the trial court's discretion does not extend to determining which cases can be investigated and enforced, a power reserved for the LWDA.The Supreme Court further rejected the argument that the retrial of the plaintiffs' representative PAGA claim would violate Royalty's right to due process. It stated that while defendants have a due process right to present an affirmative defense, this does not include the right to present the testimony of an unlimited number of individual employees. It also concluded that trial courts lack inherent authority to dismiss a PAGA claim on manageability grounds to protect a defendant's due process rights. However, the court left open the possibility that a defendant could show that a trial court's use of case management techniques so abridged the defendant's right to present a defense that its right to due process was violated.The Supreme Court affirmed the judgment of the Court of Appeal, and remanded the case for further proceedings consistent with its opinion. View "Estrada v. Royalty Carpet Mills, Inc." on Justia Law

In the case of The People v. Fernando Rojas, the Supreme Court of California addressed the issue of whether the application of Assembly Bill 333 to the gang-murder special circumstance in section 190.2(a)(22) of the California Penal Code constituted an unlawful amendment of Proposition 21, which had previously defined the term "criminal street gang".The defendant, Fernando Rojas, was convicted of first degree murder and was found to have committed the crime while being an active participant in a criminal street gang, which made him subject to life imprisonment without the possibility of parole under section 190.2(a)(22). While Rojas's appeal was pending, the state legislature passed Assembly Bill 333, which substantially narrowed the definition of "criminal street gang" for the purposes of section 190.2(a)(22).The lower courts disagreed on whether the application of Assembly Bill 333 would constitute an unlawful amendment of Proposition 21, which had been passed by the voters and was therefore protected from legislative amendment without a two-thirds majority vote of each house of the legislature or approval by the voters.The Supreme Court of California concluded that the application of Assembly Bill 333 to the gang-murder special circumstance did not violate the limitation on legislative amendment in Proposition 21. The Court reasoned that the voters who enacted Proposition 21 intended to impose a specific punishment for gang-related murder while relying on an existing statutory provision to define "criminal street gang". The Court found no indication that the voters intended to adopt a fixed definition of "criminal street gang" and held that applying Assembly Bill 333's narrower definition did not change the punishment for those convicted of the gang-murder special circumstance. Therefore, the Court reversed the judgment of the Court of Appeal and remanded the case for further proceedings. View "P. v. Rojas" on Justia Law

In the case, a defendant, Mario Rodriguez, was charged with several felonies, each carrying a maximum sentence exceeding two years. In 2018, Rodriguez was found mentally incompetent to stand trial and committed to a state hospital. After a certificate indicating his restoration to competency was filed within the two-year time limit, Rodriguez was returned to court. However, due to COVID-19 restrictions, his hearing to confirm his competency did not take place within the two-year period. Rodriguez sought to dismiss the charges against him, claiming the time for commitment had run out.The Supreme Court of California held that under the relevant statutes, the time between the filing of a certificate of restoration of mental competency and the court's ruling on that certificate counts towards the two-year maximum commitment period mandated by section 1370(c)(1) of the California Penal Code. Therefore, the filing of a certificate of restoration does not end the period of mental incompetency commitment.The court sent the case back to the Court of Appeal to decide whether the two-year limit was exceeded in this case, and if so, what remedy Rodriguez might be entitled to. The court did not decide whether Rodriguez was entitled to the remedy of dismissal he sought, or whether and how the issue of tolling may affect Rodriguez's entitlement to any relief. View "Rodriguez v. Super. Ct." on Justia Law