Justia California Supreme Court Opinion Summaries

This case concerned an insured’s assignment of the right to invoke defense and indemnification coverage under a liability policy issued by Hartford Accident & Indemnity Company. The Supreme Court held in Henkel Corp. v. Hartford Accident & Indemnity Co., a case decided on similar facts, that the consent-to-assignment clause was enforceable and precluded the insured’s transfer of the right to invoke coverage without the insurer’s consent even after the coverage-triggering event had already occurred. At issue here was whether Cal. Ins. Code 520 - a statute that was not considered by the Court when it Henkel - changes the Court’s determination in Henkel. Section 520 specifically restricts an insurer’s ability to limit an insured’s right to transfer or assign a claim for insurance coverage. The court of appeal below concluded that section 520 does not apply to liability insurance and that, even assuming the statute applies, it should be construed to reflect the same rule articulated in Henkel. The Supreme Court reversed, holding (1) in light of the relevant language and history of section 520, the statute applies to third party liability insurance and bars an insurer from refusing to honor an insured’s assignment of policy coverage regarding injuries that predate the assignment; and (2) consequently, the decision in Henkel cannot stand. View "Fluor Corp. v. Superior Court of Orange County" on Justia Law

Client advanced Attorney funds to cover attorney’s fees in litigation. After Client terminated the representation, Attorney refused to return the unearned attorney’s fees. Attorney demurred on the ground that the lawsuit was barred by Cal. Civ. Proc. Code 340.6(a), which sets forth a one-year limitations period for actions against an attorney for a “wrongful act or omission” arising in the performance of “professional services.” The trial court sustained the demurrer, concluding that section 340.6(a) applied to Client’s claims and that she filed her complaint more than one year after Attorney informed her that he would not return her money. The Court of Appeals reversed the trial court’s order sustaining Attorney’s demurrer. The Supreme Court affirmed, holding (1) section 340.6(a) applies to a claim when the merits of the claim will necessarily depend on proof that an attorney violated a professional obligation in the course of providing professional services; and (2) in this case, Client’s complaint could be construed to allege a claim for conversion whose ultimate proof at trial may not depend on the assertion that Attorney violated a professional obligation. View "Lee v. Hanley" on Justia Law

In 1998, Defendant pleaded not guilty by reason of insanity (NGI) to one count of lewd and lascivious conduct with a child and was committed to Napa State Hospital. In 2011, the Santa Clara County District Attorney petitioned to extend Defendant’s commitment a fourth time. Defendant opposed an extension of his commitment, and defense counsel requested a bench trial. After a bench trial, the trial court entered an order extending Defendant’s commitment. The Supreme Court reversed, holding (1) the trial court must advise an NGI defendant personally of his or her right to a jury trial and, before holding a bench trial, must obtain a personal waiver of that right from the defendant unless the court finds that the defendant lacks the capacity to make a knowing and voluntary waiver, in which case defense counsel controls the waiver decision; and (2) the trial court in this case erred in conducting a bench trial that extended Defendant’s commitment because the court did not advise Defendant of his right to a jury trial, did not obtain Defendant’s personal waiver of that right, and did not find substantial evidence that Defendant lacked the capacity to make a knowing and voluntary waiver. Remanded. View "People v. Tran" on Justia Law

In 2006, Defendant was declared a mentally disordered offender and committed to Atascadero State Hospital as a condition of parole. In 2011, the Santa Clara County District Attorney filed a third petition to extend Defendant’s commitment. Defendant opposed an extension of his commitment, and defense counsel requested a bench trial. After a bench trial, the trial court extended Defendant’s commitment. Defendant appealed, arguing that the trial court committed prejudicial error by failing to advise him of the right to a jury trial and by conducting a bench trial without first obtaining his personal waiver of that right. The Supreme Court reversed, holding that the trial court erred in conducting a bench trial that extended Defendant’s commitment, as (1) the statutory scheme that governs mentally disordered offender commitment proceedings expressly provides for advisement and waiver of the right to a jury trial; and (2) the trial court did not advise Defendant of his right to a jury trial in this case, did not obtain Defendant’s personal waiver of that right, and did not find that Defendant lacked the capacity to make a knowing and voluntary waiver. Remanded. View "People v. Blackburn" on Justia Law

The negligent driving of a third party driver caused another car to strike a magnolia tree planted on a center median owned and maintained by the City of Los Angeles. The collision with the tree resulted in the deaths or injuries of all of the car’s occupants. Plaintiffs sued the City under Cal. Gov't Code 835, under which a public entity may be held liable for injury proximately caused by a dangerous condition of its property if the risk of injury was reasonably foreseeable and the entity had sufficient notice of the danger to take corrective measures. Specifically, Plaintiffs asserted that the configuration of the roadway was a dangerous condition of public property. The trial court entered summary judgment in favor of the City, ruling that the magnolia tree did not constitute a dangerous condition of public property because it did not cause the accident that killed the decedents. The court of appeal affirmed, reasoning that Plaintiffs could not show that the magnolia tree contributed to the third party motorist’s criminally negligent driving. The Supreme Court reversed, holding that section 835 did not require Plaintiffs to show that the allegedly dangerous condition caused not only their decedents’ fatal injuries but also the third party conduct that precipitated the accident. Remanded. View "Cordova v. City of Los Angeles" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder and related charges. Defendant was sentenced to death for the murders. The Supreme Court struck the sentence enhancements under Cal. Penal Code 186.22(b)(1) from the sentences imposed for actively participating in a gang in counts 3, 5, 7, 10, and 14, and affirmed the judgment in all other respects, holding (1) no prejudicial error occurred with regard to Defendant’s convictions arising out of the murder of either victim; (2) no prejudicial error occurred with regard to Defendant’s conviction arising out of the shootings of two other individuals and the related charge of active participation in a gang on an aiding and abetting theory; (3) it was improper to add to each of Defendant’s convictions for the crime of gang participation a sentence enhancement for committing the crime for the benefit of a gang under section 186.22(b)(1); (4) no prejudicial error occurred during the guilt phase or penalty phase; (5) Defendant’s challenges to California’s death penalty law were without merit; and (6) no reversal was warranted due to the cumulative effect of nonprejudicial errors during guilt and penalty phase. View "People v. Nguyen" on Justia Law

A commercial general liability insurer initially refused to defend its insured against a third-party lawsuit but subsequently provided independent counsel under a reservation of rights (so-called Cumis counsel) to defend its insured in the third party suit. A court order required the insurer to pay defense costs but expressly preserved the insurer’s right to later challenge and recover payments for “unreasonable and unnecessary” charges by counsel. The insurer sought reimbursement, alleging that independent counsel “padded” their bills by charging fees that were, in part, excessive unreasonable and unnecessary. The trial court concluded that the insurer’s right to reimbursement, if any, was from its insureds, not directly from Cumis counsel. The Court of Appeal affirmed, concluding that reimbursement could not be obtained directly from Cumis counsel. The Supreme Court reversed, holding that, under the circumstances of this case, the insurer could seek reimbursement directly from Cumis counsel. View "Hartford Cas. Ins. Co. v. J.R. Marketing, LLC" on Justia Law

A police officer investigating an emergency call regarding a fight pulled behind Defendant’s parked vehicle and activated the emergency lights on his patrol car. The officer approached and spoke with Defendant, who was sitting behind the wheel of the vehicle, apparently intoxicated. Charged with felony driving under the influence, Defendant moved to suppress evidence of his physical condition, statements, and breath test results as the fruits of an unlawful search. The trial court denied the motion. The court of appeal affirmed. The Supreme Court affirmed, holding (1) the officer’s use of emergency lights in this situation constituted a detention of Defendant; and (2) Defendant’s brief detention was supported by reasonable suspicion. View "People v. Brown" on Justia Law

In this dispute over the sale of a car, Plaintiff filed a class action lawsuit against Defendant, alleging, inter alia, that Defendant violated the Consumer Legal Remedies Act by making false representations about the condition of the automobile. Defendant filed a motion to compel arbitration pursuant to an arbitration clause in the sale contract that had a class action waiver. The trial court denied the motion, concluding that the class waiver was unenforceable, and therefore, the entire arbitration agreement was unenforceable. After the trial court’s decision was filed, the United States Supreme Court in AT&T Mobility LLC v. Concepcion held that the Federal Arbitration Act (FAA) preempts California’s unconscionability rule prohibiting class waivers in consumer arbitration agreements. On appeal, the Court of Appeal declined to address whether the class waiver at issue was enforceable and instead held that the arbitration appeal provision and the arbitration agreement as a whole were unconscionably one-sided in favor of Defendant. The Supreme Court reversed, holding that the Court of Appeal erred as a matter of state law in finding the agreement unconscionable, as, in light of Concepcion, the FAA preempts the trial court’s invalidation of the class waiver on unconscionability grounds. View "Sanchez v. Valencia Holding Co., LLC" on Justia Law

At dispute in this case was an environmental impact report (EIR) certified by the Board of Trustees (Board) of the California State University (CSU) that concerned the Board’s project to expand the campus of San Diego State University (SDSU) to accommodate more than 10,000 additional students. The SDSU project will contribute significantly to traffic congestion off-campus in the City of San Diego. The Board declined to use any of its budgeted funds, or any of CSU’s financial resources, for off-site environmental mitigation, finding that mitigation was infeasible. The Court of Appeal directed the Board to vacate its certification of the EIR. The Supreme Court affirmed, holding that the EIR in this case did not comply with the California Environmental Quality Act where the Board erroneously assumed that a state agency may contribute funds for off-site environmental mitigation only through earmarked appropriations, to the exclusion of other available sources of funding. View "City of San Diego v. Bd. of Trs. of Cal. State Univ." on Justia Law