Justia California Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeal that a Department of Insurance regulation prohibiting bail bond agents from entering into agreements with jail inmates to be notified when individuals have recently been arrested and thus may be in need of bail bond services was facially invalid under the First Amendment, holding that the court of appeal erred in holding that the regulation was unconstitutional on its face.In declaring the regulation constitutionally invalid the court of appeal concluded that the regulation imposed burdens on the free speech rights of bail bond agents that were not adequately justified by the State's interests in deterring abusive bail solicitation practices. The Supreme Court reversed, holding that the regulation burdened a protected speech right, that intermediate scrutiny applied, and that the regulation passed constitutional muster. View "People v. Martinez" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the trial court's judgment concluding that the at-large method of electing city council members in the City of Santa Monica diluted Latino voters' ability to elect their preferred candidates and their ability to influence the outcome of council elections, holding that the court of appeals misconstrued the California Voting Rights Act of 2001, Cal. Elec. Code 14025 et seq. (CVRA).The superior court ruled in favor of Plaintiffs on their claims that the racially polarized voting in the City violated the CVRA. The superior court ruled in favor of Plaintiffs and ordered the City to conduct a special election using a seven-district map drafted by an expert who testified at trial. The court of appeal reversed, concluding that there had been no dilution of Latino voters' ability to elect their preferred candidates or their ability to influence the outcome of the election. The Supreme Court reversed, holding (1) a court presented with a dilution claim should undertake a searching evaluation of the totality of the facts and circumstances; and (2) because the court of appeal did not evaluate the dilution element of the CVRA under the proper standard, remand was required. View "Pico Neighborhood Ass'n v. City of Santa Monica" on Justia Law

The Supreme Court held that an employer's business entity agents can be held directly liable under the California Fair Employment and Housing Act (FEHA), Cal. Gov. Code 12900 et seq., for employment discrimination in appropriate circumstances when the business entity agent has at least five employees and carries out activities regulated by FEHA on behalf of an employer.Plaintiffs, on behalf of themselves and an alleged class, brought this action alleging claims under the FEHA, the Unruh Civil Rights Act, unfair competition law, and the common law right of privacy. Plaintiffs named as a defendant U.S. Healthworks Medical Group (USHW), who was acting as an agent of Plaintiffs' prospective employers. The district court dismissed all claims, concluding, as relevant to this appeal, that the FEHA does not impose liability on the agents of a plaintiff's employer. The federal district court of appeals certified a question of law to the Supreme Court, which answered that FEHA permits a business entity acting as an agent of an employer to be held directly liable as an employer for employment discrimination, in violation of FEHA, when the business entity has at least five employees and carries out FEHA-regulated activities on behalf of an employer. View "Raines v. U.S. Healthworks Medical Group" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeal affirming Defendant's convictions for, among other crimes, first degree murder and two counts of attempted, premeditated murder of a police officer and his sentence of life without the possibility of parole, holding that the trial court's erroneous concurrent intent instruction was prejudicial as to one attempted murder count.At issue was the proper standard of review when a defendant challenges a court's decision to instruct on a concurrent intent - or kill zone - theory as applied to an allegation of attempted murder. The Supreme Court reversed the court of appeals to the extent it affirmed one of Defendant's attempted murder convictions based on the concurrent intent theory, holding (1) the substantial evidence standard applies to giving or reviewing a concurrent intent instruction; (2) a concurrent intent instruction was not supported by substantial evidence; and (3) the error was prejudicial as to one of the attempted murder counts. View "People v. Mumin" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming Defendant's conviction of first-degree murder, holding that when the record contains substantial evidence of imperfect self defense, the trial court's failure to instruct on that theory amounts to constitutional error and is subject to review under the federal Chapman standard. See Chapman v. California, 386 U.S. 18 (1967).On appeal, Defendant argued that the trial court committed harmful error in denying his request for an instruction on imperfect self-defense. The court of appeals affirmed, concluding that the trial court erred but that the error was subject to the "reasonable probability" standard for evaluating prejudice set forth in People v. Watson, 46 Cal.2d 818 (1956) and that Defendant suffered no prejudice. The Supreme Court reversed, holding (1) the form of misconstruction in this case precluded the jury from making a finding on a factual issue necessary to establish the element of malice, thus qualifying as a federal error; and (2) the court of appeal's harmless error analysis did not comport with the standards for evaluating prejudice under Chapman. View "People v. Schuller" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that because certain statements fell within an exception to the hearsay requirement they automatically qualified for admission into evidence, holding that the court of appeals erred in concluding that it was not necessary to balance Defendant's confrontation interests against any countervailing government interests.Defendant was charged with inflicting corporate injury upon a person in a dating relationship and residential burglary. The prosecution moved to revoke Defendant's probation based on the same incident. At the criminal trial, the prosecution sought to admit the complaining witness's (N.S.) statements as recorded on a body-worn camera video, but the trial court ruled that the statements were inadmissible under the Confrontation Clause. The court subsequently dismissed the criminal proceeding. At the subsequent probation revocation the court ruled that statements within the first portion of the video qualified as spontaneous statements under Cal. R. Evid. 1240 and admitted N.S.'s statements without making an express finding of good cause for not securing N.S.'s live testimony. The court of appeal affirmed the order revoking Defendant's probation. The Supreme Court reversed, holding that the court of appeals erred in concluding that the statements automatically satisfied the minimum due process requirements necessary for their admission into evidence. View "People v. Gray" on Justia Law

In this challenge to "Measure Z," a Monterey County ordinance, the Supreme Court affirmed the decision of the court of appeal affirming the judgment of the trial court in favor of Plaintiffs on preemption grounds, holding that Cal. Pub. Res. Code 3106 preempts Measure Z.Plaintiffs - Chevron U.S.A. Inc. and other oil producers and mineral rights holders - brought six actions against the County challenging Measure Z, a local ordinance banning oil and gas wastewater injection and impoundment and the drilling of new oil and gas wells in the County's unincorporated areas. The trial court issued a writ of mandate directing the County to invalidate two prohibitions in the measure that applied to the County's unincorporated areas. The court of appeal affirmed on grounds of state preemption. The Supreme Court affirmed, holding that Measure Z contradicts, and therefore conflicts with and is preempted by, section 3106. View "Chevron U.S.A., Inc. v. County of Monterey" on Justia Law

The Supreme Court reversed the judgment of the court of appeal finding that Cal. Corp. Code 5142, 5233, and 5223 impose a continuous directorship requirement that would require dismissal of a lawsuit brought under the statutes if the plaintiff, a director of a nonprofit public benefit corporation, fails to retain a director position, holding that the statutes do not require continued service as a director as a condition for pursuing such a lawsuit.Sections 5142 and 5233 allow a director of a nonprofit public benefit corporation to bring an action to remedy a breach of a charitable trust or recover damages for self-dealing transactions by other directors, and section 5223 allows the trial court, "at the suit of a director," to remove any director guilty of malfeasance from office. At issue was whether the director of charitable corporation who loses that position after instituting a lawsuit against other directors under the director enforcement statutes also loses standing to maintain the lawsuit. The Supreme Court reversed the opinion of the court of appeal, holding that the statutes do not require a director-plaintiff at a nonprofit corporation to maintain the director position throughout litigation. View "Turner v. Victoria" on Justia Law

The Supreme Court held that, in disciplinary proceedings, private universities are not required to provide accused students the opportunity to directly or indirectly cross-examine the accuser and other witnesses at a live hearing with the accused student in attendance, either in person or virtually.The University of Southern California and its vice president of student affairs (collectively, USC) expelled Appellant after conducting an investigation and determining that Appellant violated USC's policy against engaging in intimate partner violence. Appellant filed a petition for a writ of administrative mandate, arguing that he was deprived of a fair trial under Cal. Code Civ. Proc. 1094.5. The court of appeals agreed, determining that USC's disciplinary procedures were unfair because they denied Appellant a meaningful opportunity to cross-examine critical witnesses at an in-person hearing. The Supreme Court reversed, holding that requiring private universities to conduct the hearing envisioned by the court of appeals was contrary to fair procedure caselaw. View "Boermeester v. Carry" on Justia Law

The Supreme Court reversed the judgment of the court of appeal finding evidence of Plaintiff's subsequent molestation was admissible into evidence in a trial claiming emotional distress damages from the conduct of a teacher at the Mountain View School District, holding that remand was required for the trial court to undertake proper proceedings under Cal. Evid. Code 1106 and 783.Plaintiff sued the District seeking to recover for sexual abuse committed when she was eight years old by her fourth-grade teacher. The District sought to introduce evidence that Plaintiff was subsequently molested a few years later by another person and that this subsequent molestation caused at least some of Plaintiff's emotional distress injuries and related damages. The appellate court found the evidence regarding the subsequent molestation admissible. The Supreme Court reversed and remanded the case, holding (1) section 1106 subdivision (e) may permit admission of evidence that would otherwise be excluded under subdivision (a), but such admissibility is subject to the procedures set out in section 783 and scrutiny under section 352; and (2) section 352, as applied under the circumstances, required special informed review and scrutiny defined to protect Plaintiff's privacy rights, which appear not to have been applied in this case. View "Doe v. Superior Court" on Justia Law