Justia California Supreme Court Opinion Summaries

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

At issue in this case was the adequacy of an environment impact report certified by the California Department of Fish and Wildlife (DFW) for a land development in northwest Los Angeles County. Plaintiffs challenged DFW’s actions by a petition for writ of mandate, raising several claims under the California Environmental Quality Act. The superior court granted the petition. The Court of Appeal reversed. The Supreme Court reversed, holding (1) the environmental impact report did not validly determine that the development would not significantly impact the environment by its discharge of greenhouse gases; (2) the report’s mitigation measures adopted for protection of a freshwater fish, a fully protected species under the Fish and Game Code, constituted a prohibited taking of the fish under the Code; and (3) Plaintiffs exhausted their administrative remedies regarding certain claims of deficiency. Remanded. View "Ctr. for Biological Diversity v. Cal. Dep’t of Fish & Wildlife" on Justia Law

A private citizen called a 911 operator to report an incident of suspected child abuse during the child’s visit with his father. A deputy sheriff, who was dispatched to investigate the report, determined that the child was not a victim of child abuse. Neither the officer nor the Sheriff’s Department cross-reported the initial 911 report to the child welfare agency. Less than four weeks later, the child suffered extensive head injuries during a visit with his father. The child, through a guardian ad litem, sued the county and the deputy sheriff for failing to cross-report the initial child abuse allegations to the county child welfare agency, in violation of the Child Abuse and Neglect Reporting Act. The trial court granted summary judgment for Defendants. The Court of Appeal affirmed. The Supreme Court reversed in part and affirmed in part, holding (1) the Sheriff’s Department had a mandatory and ministerial duty to cross-report the child abuse allegations made to the 911 operator to the child welfare agency, and the failure to cross-report can support a finding of breach of a mandatory duty; but (2) the officer had no duty to report the child abuse allegations and her investigative findings to the child welfare agency. View "B.H. v. County of San Bernardino" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the delay in bringing charges against Defendant did not violate his due process rights; (2) the trial court did not commit prejudicial error in its evidentiary rulings during the guilt phase of trial; (3) the prosecutor did not commit misconduct during the guilt phase closing argument; (4) the trial court did not commit prejudicial error in its evidentiary rulings during the penalty phase of trial; (5) the trial court properly instructed the jury during the penalty phase; and (6) the remainder of Defendant’s claims have already been rejected by the Court. View "People v. Cordova" on Justia Law

At issue in this case was whether Cal. Labor Code 4458.2, which provides workers’ compensation benefits to certain peace officers injured in the line of duty, applies to both volunteer peace officers and to regularly sworn, salaried officers. While employed as a police officer by the City of Marysville, John Larkin sustained injuries in the course of duty. A workers’ compensation judge determined that Larkin was entitled to workers’ compensation benefits but not to the maximum indemnity levels available under section 4458.2 because section 4458.2 did not apply to regularly sworn, salaried officers like Larkin. The Workers’ Compensation Appeals Board denied Larkin’s petition for reconsideration. The Court of Appeal affirmed. The Supreme Court affirmed, holding that a review of the legislative history governing the relevant statutory provisions of section 4458.2 leads to the conclusion that the statute does not extend maximum disability indemnity levels to regularly sworn, salaried peace officers. View "Larkin v. Workers’ Comp. Appeals Bd." on Justia Law

After a jury trial, Defendant was convicted of violating Cal. Penal Code 451(b), which forbids arson of “an inhabited structure or inhabited property.” Specifically, the jury found Defendant guilty of “arson of an inhabited structure as charged.” The prosecution did not charge Defendant with arson of property, but the court instructed the jury on it. In accordance with the trial court’s instructions, the jury did not return a verdict on the lesser crimes, including arson of property. The Court of Appeal reversed, finding the evidence insufficient to sustain the conviction, which precludes retrial of that charge. The Supreme Court reversed, holding that, under the circumstances, the lesser offense of arson of property was prosecuted in a single proceeding along with the section 451(b) charge, and therefore, Cal. Penal Code 654, as interpreted in Kellett v. Superior Court, does not prohibit retrying Defendant for that lesser offense. View "People v. Goolsby" on Justia Law

Defendant was charged with attempted murder and assault with a firearm. The prosecution alleged that these offenses were committed for the benefit of a criminal street gang and were thus subject to a sentence enhancement under Cal. Penal Code 186.22(f). The jury convicted Defendant of the lesser included offense of attempted voluntary manslaughter and of assault with a firearm. The jury found true that Defendant committed the offenses for the benefit of a criminal street gang. The Court of Appeal sustained Defendant’s sentence enhancement under section 186.22. The Supreme Court reversed the judgment as to Defendant’s sentence, holding (1) section 186.22(f)’s definition of a “criminal street gang” - and, in particular, its requirement of an “ongoing organization, association, or group” - calls for evidence that an organizational or associational connection unites the group members; (2) where, as in this instance, the prosecution’s case positing the existence of a single criminal street gang turns on the existence of gang subsets, the prosecution must show some associational or organizational connection uniting those subsets and also that the gang those subsets comprise is the same gang the defendant sought to benefit; and (3) the decision below was not consistent with this standard. Remanded. View "People v. Prunty" on Justia Law