Justia California Supreme Court Opinion Summaries

A person identified as O.R. appealed the decision of the Los Angeles County Superior Court to place his child, N.R., under the jurisdiction of the Los Angeles County Department of Children and Family Services (the Department) based on allegations of substance abuse. The Supreme Court of California reviewed two issues concerning the interpretation of the Welfare and Institutions Code section 300, subdivision (b)(1)(D), which allows for jurisdiction over a child in cases where the parent’s substance abuse results in an inability to provide regular care for the child and causes or could cause the child serious physical harm or illness.First, the court clarified the term “substance abuse” as used in the statute. It rejected O.R.’s argument that “substance abuse” must be shown through a medical diagnosis or by meeting the criteria for a substance use disorder as outlined in the Diagnostic and Statistical Manual of Mental Disorders (DSM). The court held that “substance abuse” in this context should be given its ordinary meaning, which refers to the excessive use of drugs or alcohol. The court cautioned that to establish dependency jurisdiction, the abuse must render the parent unable to provide regular care for the child and either cause the child serious physical harm or illness, or place the child at substantial risk of such harm or illness.Second, the court rejected the so-called “tender years presumption,” which holds that substance abuse by a parent is prima facie evidence of an inability to provide regular care and a substantial risk of serious physical harm when the child is very young. The court held that this presumption is not supported by the language of the statute or the legislative intent, and improperly simplifies the analysis required under section 300(b)(1)(D). Instead, the court held that the government must establish each element of the statute separately, without shifting the burden to the parent to rebut a presumption created by a finding of substance abuse.The court reversed the decision of the Court of Appeal and remanded the case for further proceedings consistent with its opinion. View "In re N.R." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Petitioner's petition for relief and resentencing under the new procedure set forth in Senate Bill No. 1437 (former Cal. Penal Code 1170.95, subd. (a); now Cal. Penal Code 1172.6, subd. (a)), holding that the trial court erred.Petitioner was convicted of first degree murder and sentenced to life imprisonment without the possibility of parole. Twelve years later, the Legislature enacted Senate Bill 1437 narrowing or eliminating certain forms of accomplice liability for murder. Petitioner petitioned for relief and resentencing under the new procedure, but the trial court denied the petition for failure to state a prima facie case. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court erred in rejecting Petitioner's prima facie showing and should have proceeded to an evidence hearing on Petitioner's resentencing petition. View "People v. Curiel" on Justia Law

The Supreme Court reversed the judgment of the court of appeal declining to remand this case for resentencing in light of a new law that was enacted after Defendant had been sentenced but while his appeal was still pending, holding that the court of appeal erred.At issue was Senate Bill No. 567, which created a presumption that the sentencing court shall entered a lower term sentence when, inter alia, a "psychological, physical, or childhood trauma" contributed to the offense and set forth the circumstances when a sentencing court may depart from the lower term presumption. Defendant was found guilty of false imprisonment by violence or menace and sentenced to seven years and four months in prison. While Defendant's appeal was pending, Senate Bill 567 was passed, amending Cal. Pen. Code 1170, subd. (b)(6) & (A). The Supreme Court remanded this case for resentencing, holding that the court of appeal erred by finding that the record clearly indicated that the trial court would not have imposed a lower term sentence if it had been aware of the scope of its discretionary powers under the current section 1170 at the time Defendant was sentenced. View "People v. Salazar" on Justia Law

The Supreme Court held, in response to a request by the United States Court of Appeals for the Ninth Circuit, that Cal. Publ. Util. Code 1759 bars a lawsuit that seeks damages resulting from public safety power shutoffs (PSPS) events where the suit alleges that a utility's negligence in maintaining its grid necessitated shutoffs but does not allege that the shutoffs were unnecessary or violated the regulations of the California Public Utilities Commission (PUC).To reduce the risk that its utility infrastructure would ignite a wildfire during extreme weather conditions Pacific Gas and Electric Company (PG&E) conducted a series of emergency power shutoffs that Plaintiff alleged were necessitated by PG&E's negligence in maintaining its power grid. Plaintiff filed a class action complaint against PG&E requesting class damages of $2.5 billion. At issue before the Supreme Court was whether section 1759 barred this lawsuit. The Supreme Court answered the question in the positive, holding that allowing suit under the circumstances here would interfere with the PUC's comprehensive regulatory and supervisory authority over PSPS. View "Gantner v. PG&E Corp." on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court determining that because of racially polarized voting, the at-large method of election had impaired Latino voters' ability to elect candidates of their choice or to influence the outcome of an election, holding that the court of appeal misconstrued the California Voting Rights Act of 2001 (CVRA), Cal. Elec. Code 14025 et seq.The trial court in this case concluded that the at-large method of electing city council members in the City of Santa Monica diluted Latinos' ability to elect their preferred candidates and their ability to influence the outcome of council elections and, as a remedy, ordered the City to conduct a special election using a map drafted by an expert who testified at trial. The court of appeal reversed. The Supreme Court reversed and remanded the case, holding (1) a court presented with a dilution claim should undertake a searching evaluation of the totality of the facts and circumstances; and (2) remand was required for the court of appeal to evaluate the dilution standard of the CVRA under this standard. View "Pico Neighborhood Ass'n v. City of Santa Monica" on Justia Law

The Supreme Court held that persons facing involuntary commitment under the Sexually Violent Predator Act (SVP Act), Cal. Welf. & Inst. Code 6600 et seq., have a due process right to a timely trial but that whether pretrial delay violates that right depends in the first instance on the reasons for the delay. See Barker v. Wingo (1972), 407 U.S. 514, 531.In 2005, Petitioner was determined to be an SVP and committed to the state hospital for two years. The next year, the applicable statute was amended to provide for indefinite commitment instead of renewable two-year terms. Before Petitioner's term ended, the State filed a recommitment petition seeking indefinite commitment under the new version of the statute. Petitioner later filed a motion to dismiss the petition to extend commitment, arguing that the "excessive delay" in his case violated his due process right to a timely trial. The trial court denied the motion to dismiss, after which Petitioner filed an original petition for a writ of mandate. The court of appeal denied the writ petition. The Supreme Court affirmed, holding that Petitioner failed to establish a violation of his due process rights. View "Camacho v. Superior Court" on Justia Law

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