Justia California Supreme Court Opinion Summaries

In 2008, Brandon Clark fell ten feet while working as a carpenter for Employer. Clark’s workers’ compensation doctor prescribed various drugs to treat Clark’s injuries, and Clark’s personal doctor prescribed additional drugs. In 2009, Clark died from the “combined toxic effects of the four sedating drugs detected in his blood with associated early pneumonia.” Clark’s family sought workers’ compensation death benefits, arguing that the medications Clark was prescribed for his work-related injuries caused his death. The workers’ compensation judge awarded death benefits to the family. The Court of appeal reversed, concluding that there was insufficient evidence that the drugs Clark was prescribed for his work injuries contributed to his death. The Supreme Court reversed, holding (1) the Court of Appeal wrongly applied a higher proximate cause standard to this wrongful death case than the Legislature intended; and (2) substantial evidence supported the WCJ’s finding that two drugs, prescribed by the workers’ compensation doctor for Clark’s industrial injury, contributed to his death. View "South Coast Framing v. Workers’ Comp. Appeals Bd." on Justia Law

Defendant was charged with felony infliction of corporal injury in violation of Cal. Penal Code 273.5(a). The information further alleged that Defendant had suffered a prior conviction under section 273.5. At trial, Defendant stipulated to the prior conviction. The trial court accepted stipulation without advising Defendant of any trial rights or eliciting his waiver of those rights. A jury subsequently convicted Defendant of violating section 273.5(a) and found true the allegation that Defendant suffered a prior conviction. In light of the prior conviction, the trial court sentenced Defendant to a maximum term of five years. Defendant appealed, arguing that his stipulation to the prior conviction was invalid because it had the direct consequence of subjecting him to a longer prison term. The Court of Appeal affirmed the sentence. The Supreme Court reversed in part, holding that Defendant’s stipulation must be set aside, as (1) Defendant was entitled to be advised of his right to a fair determination of the truth of the prior conviction allegation; and (2) because the record did not affirmatively show that Defendant was aware of his right to a fair determination of the truth of the prior conviction allegation, Defendant’s stipulation must be set aside. View "People v. Cross" on Justia Law

The District Attorney filed a petition to declare sixteen-year-old R.V. (“Minor”) a ward of the juvenile court. When the juvenile court determined there was substantial evidence raising a doubt regrading Minor’s competency to stand trial, the court suspended proceedings and appointed a forensic psychologist to evaluate Minor. The expert’s report concluded that Minor was not competent to stand trial. The court rejected the expert’s opinion and concluded that Minor was competent to stand trial. The Court of Appeal affirmed, concluding that the juvenile court’s reasons for declining to accept the expert’s opinion were supported by substantial evidence in the record. The Supreme Court reversed, holding (1) under Cal. Welf. & Inst. Code 709, a minor is presumed competent and bears the burden of proving otherwise by a preponderance of the evidence; (2) a claim of insufficient evidence to support a juvenile court’s determination in a competency proceeding is reviewed deferentially under the substantial evidence test; and (3) the juvenile court under the circumstances could not reasonably have rejected the qualified expert’s opinion that Minor was not competent to proceed to trial. View "In re R.V." on Justia Law

Bayer AG and Bayer Corporation (collectively, Bayer) marketed Cipro, an antibiotic. In 1987, Bayer was issued a United States patent on the active ingredient in Cipro. Twelve years before the expiration of the patent, Barr Laboratories, Inc. filed an application to market a generic version of Cipro. Bayer responded with a patent infringement suit, and Barr counterclaimed for a declaratory judgment that the patent was invalid. In 1997, Bayer and Barr entered into a settlement agreement under which Bayer agreed to make a “reverse payment” to Barr in exchange for Barr dropping its patent challenge and consenting to stay out of the market. The settlement produced numerous state and federal antitrust suits. This case arose from nine such coordinated class action suits brought by indirect purchasers of Cipro in California. The complaint alleged that the Bayer-Barr reverse payment settlement violated the Cartwright Act, unfair competition law, an common law prohibition against monopolies. The trial court granted summary judgment for Bayer and Barr. The Court of Appeal affirmed. The Supreme Court reversed, holding that parties illegally restrain trade when they privately agree to substitute consensual monopoly in place of potential competition that would have followed a finding of invalidity or noninfringement. View "In re Cipro Cases I & II" on Justia Law

Plaintiff, a firefighter, sued Defendant, his employer, alleging disability discrimination in violation of the California Fair Employment and Housing Act (FEHA). The trial court granted summary judgment in favor of Defendant. Without making any finding that Plaintiff’s action was frivolous, unreasonable, or groundless, the trial court awarded Defendant its court costs. The court of appeal affirmed. The Supreme Court reversed, holding (1) Cal. Gov’t Code 12965(b) governs cost awards in FEHA actions, allowing trial courts discretion in awards of both attorney fees and costs to prevailing FEHA parties; and (2) the standard set forth in Christiansburg Garment Co. v. EEOC applies to discretionary awards of both attorney fees and costs to prevailing FEHA parties under section 12965(b), but a prevailing defendant should not be awarded fees or costs unless the plaintiff brought or continued litigating the action without an objective basis for believing it had potential merit. View "Williams v. Chino Valley Indep. Fire Dist." on Justia Law

After a jury trial, Defendant was convicted of the first degree murders of Mary Kopatz and Carley Kopatz. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress evidence of his videotaped interview with the police; (2) the trial court did not err in admitting a deceased witness’s prior consistent statement; (3) the victim impact evidence was neither unduly prejudicial nor so inflammatory that it invited the jury to make its penalty determination on a purely irrational basis; (4) Defendant was not prejudiced by a multiple-murder special-circumstance instruction and attendant verdict forms; and (5) Defendant’s challenges to the death penalty law failed. View "People v. Kopatz" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, with the special circumstance of torture, false imprisonment by violence, and conspiracy to commit murder. The jury recommended a sentence of death, and the trial court imposed that sentence. The Supreme Court affirmed the convictions but reversed the penalty judgment, holding that, during the penalty phase, the court violated Defendant’s federal constitutional rights to due process by excluding expert testimony about prison security measures for those sentenced to life without possibility of parole because Defendant was deprived of the opportunity to counter aggravating evidence and argument suggesting that he would be a dangerous life prisoner. View "People v. Smith" on Justia Law

Defendant, a second-strike offender, was convicted of eleven offenses arising from sexual assaults on two separate victims. At issue in this appeal was the trial court’s imposition of an alternative sentence under the One Strike law. The court sentenced Defendant to twenty-five years to life for each of his two rape convictions then doubled the minimum terms for the life sentences pursuant to the Three Strikes Law and added five-year prior serious felony enhancements to both. On the remaining counts, the court imposed determinate terms of seventeen years each - the sum of the middle term of six years, doubled pursuant to the Three Strikes Law - plus a five-year prior serious felony enhancement. Defendant’s alternative sentence totaled 229 years to life, which the court stayed in light its sentence original of 495 years to life. The Supreme Court granted review to determine whether the prior serious felony enhancement may be applied to the term imposed for each offense or only once to the determinate portion of the overall sentence. The Supreme Court vacated Defendant’s stayed sentence of 229 years to life and remanded for resentencing, holding that the prior serious felony enhancement may be added only once to multiple determinate terms imposed as part of a second-strike sentence. View "People v. Sasser" on Justia Law

In 2000, California voters enacted Proposition 39, which provides that school districts must share their facilities with charter schools so that charter school students have access to facilities “reasonably equivalent” to facilities available to other public school students. Two years later, the State Board of Education issued regulations on how to implement this requirement. This action concerned the meaning of a Board regulation that governs the allocation of classrooms to charter schools. In allocating classrooms to charter schools, the Los Angeles Unified School District used “norming ratios,” which purported to establish throughout the District a uniform student/teacher ratio in a given grade level. The California Charter Schools Association (CCSA) sought declaratory relief, contending that the District violated the regulation governing the allocation of classrooms to charter schools by, inter alia, using these norming ratios rather than counting classrooms in comparison group schools to determine the allocation of classroom facilities. The Supreme Court agreed with CCSA and held that the District’s use of norming ratios, rather than counting classrooms in comparison group schools, violated the applicable regulation. In responding to future facilities requests, the District must count classrooms in a manner that conforms to the regulation. View "Cal. Charter Schs. Ass’n v. L.A. Unified Sch. Dist." on Justia Law

After a jury trial, Defendant was found guilty of one count of willful, deliberate, and premeditated attempted murder and three counts of threatening to commit a crime resulting in death or great bodily injury. During trial, the court admitted certain out-of-court statements made by Defendant that formed the basis of the prosecution for making criminal threats. Defendant appealed, arguing that the trial court erred by not instructing the jury to consider Defendant’s out-of-court statements with caution, despite Defendant’s failure to request such an instruction. The Court of Appeal affirmed, concluding that any error in omitting the instruction was harmless in light of other instructions the jury received and the evidence presented. The Supreme Court affirmed, holding (1) the cautionary instruction is applicable when the out-of-court statements at issue are criminal threats, and the trial court is not required to give such an instruction sua sponte; and (2) the omission of the cautionary instruction in this case was harmless. View "People v. Diaz" on Justia Law