Justia California Supreme Court Opinion Summaries

An employee (Claimant) was asked by his employer to sign a written disciplinary notice regarding Claimant’s alleged misconduct. Claimant refused to sign the notice, claiming that he wished to consult with his union first and that he believed that signing would constitute an admission of guilt. Based on this incident, the employer terminated Claimant for insubordination. The Employment Development Department denied Claimant’s application for unemployment benefits, determining that Claimant’s refusal to sign the disciplinary notice constituted misconduct. The Unemployment Insurance Appeals Board reversed, finding that Claimant’s failure to sign the notice was “an instance of poor judgment” that did not disqualify Claimant from receiving benefits. The Supreme Court affirmed, holding that, even if Claimant’s refusal to sign the disciplinary notice justified his termination, Claimant did not commit misconduct within the meaning of California’s Unemployment Insurance Code. View "Paratransit, Inc. v. Unemployment Ins. Appeals Bd." on Justia Law

Defendants, two architectural firms, were the sole entities that provided architectural services for a collection of condominium units in San Francisco. The homeowners association sued several parties involving in the construction of the condominiums, including Defendants, alleging that negligent architectural design work performed by Defendants resulted in several defects. The trial court sustained a demurrer in favor of Defendants, determining that because the final decision regarding how the homes would be built rested with the owner, Defendants owed no duty to the future condominium owners. The court of appeal reversed, concluding that, under both the common law and the Right to Repair Act, Defendants owed a duty of care to the homeowners in this case. The Supreme Court affirmed, holding (1) an architect owes a duty of care to future homeowners in the design of a residential building where the architect is a principal architect on the project, and the duty of care extends to such architects even when they do not actually build the project or exercise ultimate control over construction; and (2) the complaint int his case sufficiently alleged the causal link between Defendants’ negligence and the condominium association’s injury. View "Beacon Residential Cmty. Ass’n. v. Skidmore, Owings & Merrill" on Justia Law

After a jury trial, Defendant was convicted of murder, rape, and kidnapping and sentenced to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in finding that Defendant was competent to stand trial; (2) the prosecutor did not improperly exercise a peremptory challenge to a prospective juror based on race; (3) during the guilt phase of trial, the trial court did not abuse its discretion in admitting crime scene and autopsy photographs and in instructing the jury; (4) no prejudicial error occurred during the penalty phase of trial; (5) the trial court did not err in denying Defendant’s motion for a new trial; and (6) Defendant’s challenges to California’s death penalty statute failed. View "People v. Sattiewhite" on Justia Law

After a jury trial, Defendant was convicted of kidnapping, committing two counts of lewd and lascivious acts on, and murdering a five-year-old girl. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding that the trial court (1) did not err in refusing to change venue from Orange County, as the record presented no reason to find a reasonable likelihood that Defendant did not receive a fair trial before impartial jurors; (2) did not err in denying Defendant’s request for additional peremptory challenges after he exhausted his statutory allotment of challenges because Defendant did not demonstrate that additional peremptory challenges were necessary to secure his right to a fair trial; (3) did not abuse its discretion in admitting evidence that Defendant had sexually molested three girls where Defendant had been charged with and acquitted of crimes concerning two of the girls; and (4) did not abuse its discretion in admitting photographs of the crime scene, evidence regarding the child pornography found on the computer to which Defendant had access, and victim impact evidence. View "People v. Avila" on Justia Law

Defendant published a daily newspaper and contracted with individual carriers to deliver the paper. Named plaintiffs were four newspaper carriers for Defendant. Plaintiffs sued on behalf of a putative class of carriers, alleging that Defendant wrongly treated its carriers as independent contractors when they were employees as a matter of law. The trial court denied class certification, concluding that alleged individual variations in how carriers performed their work presented unmanageable individual issues that precluded certification. The court of appeals reversed in part, concluding that proof of employee status would not necessarily entail a host of individual inquiries. The Supreme Court affirmed, holding (1) whether a common law employer-employee relationship exists turns principally on the degree of a hirer’s right to control how the end result is achieved; (2) whether the hirer’s right to control can be shown on a classwide basis will depend on the extent to which individual variations in the hirer’s rights concerning each putative class member exist, and whether such variations, if any, are manageable; and (3) the trial court in this case erred in rejecting certification based not on differences in Defendant’s right to exercise control but on variations in how that right was exercised. View "Ayala v. Antelope Valley Newspapers, Inc." on Justia Law

Plaintiff, an unauthorized alien, was injured while working for his employer (Defendant) and was later was laid off during Defendant’s seasonal reduction of workers. Plaintiff sued, alleging that Defendant violated the California Fair Employment and Housing Act (FEHA) by failing to provide reasonable accommodations for his disability and by retaliating against him for filing a workers’ compensation claim. During discovery, Defendant learned that Plaintiff had misrepresented to Defendant his eligibility under federal law to work in the United States. The trial court granted summary judgment for Defendant, and the Court of Appeal affirmed, holding (1) Plaintiff’s action was barred by the doctrines of after-acquired evidence and unclean hands; and (2) the application for those doctrines was not precluded by S.B. 1818, which extends state law employee protections and remedies to all individuals regardless of immigration status. The Supreme Court reversed, holding (1) S.B. 1818 is not preempted by federal immigration law; and (2) the doctrines of after-acquired evidence and unclean hands are not complete defenses to a worker’s claims under California’s FEHA. View "Salas v. Sierra Chem. Co." on Justia Law

Mary Ann Verdugo died after suffering a sudden cardiac arrest while shopping at a Target department store. Target did not have an automated external defibrillator (AED) in its store. Plaintiffs, Verdugo’s mother and brother, filed suit against Target Corporation, alleging that Target breached its duty of care to Verdugo by failing to have within its store an AED for use in a medical emergency. A federal district court dismissed the complaint for failure to state a cause of action, concluding that Target had no duty to have in its stores an AED for the use of its customers. When the matter came before the court of appeals, the court asked the California Supreme Court for guidance on the question of California tort law presented by this case. The Supreme Court answered that, under California law, Target’s common law duty of care to its patrons does not include an obligation to acquire and make available an AED for the use of its customers in a medical emergency. View "Verdugo v. Target Corp." on Justia Law

An Employee filed a class action complaint against his Employer. The Employee, however, had entered into an arbitration agreement with his Employer that waived his right to class proceedings. The Employee also sought to bring a representative action under the Labor Code Private Attorneys General Act (PAGA). The Court of Appeal concluded that the entire arbitration agreement, which included a PAGA waiver, should be enforced. The Supreme Court reversed, holding, as regards the class action complaint, (1) a state law that restricts enforcement of the waiver of the right to class proceedings in arbitration agreements on grounds of public policy or unconscionability is preempted by the Federal Arbitration Act (FAA); but (2) the class action waiver at issue in this case was unlawful under the National Labor Relations Act, and the Employer waived its right to arbitrate. With regard to the PAGA action, the Court held (1) the FAA does not preempt a state law that prohibits waiver of PAGA representative actions in an employment contract; and (2) an arbitration agreement requiring an employee to give up the right to bring representative PAGA actions is contrary to public policy and unenforceable as a matter of state law. View "Iskanian v. CLS Transp. Los Angeles, LLC" on Justia Law

Luis M., a juvenile, admitted that he had committed felony vandalism. The offense involved nine acts of graffiti at six locations. The juvenile court ordered restitution in the amount of $3,881.88, which was a crime prevention officer’s estimation of the amount the City spent to abate Luis’s acts of graffiti in 2011. The court of appeal directed the juvenile court to vacate its restitution order and to hold a new restitution hearing. The Supreme Court affirmed, holding that the juvenile court’s award was not based on sufficient evidence that the amount of claimed loss was a result of Luis’s conduct. View "Luis M. v. Superior Court" on Justia Law

Hartford Casualty Insurance Company issued a commercial general liability policy to Ultimate Support Systems, a company that sold the Ulti-Cart. The policy covered “personal and advertising injury,” which included claims arising out of publication of material that "disparages a person’s or organization’s goods, products or services.” Gary-Michael Dahl, the manufacturer of the Multi-Cart, sued Ultimate for patent and trademark infringement, false designation of origin, and damage to business, reputation, and goodwill. Hartford denied coverage on the ground that the suit did not allege that Ultimate had disparaged the Multi-Cart or Dahl. The Supreme Court affirmed, holding (1) a claim of disparagement requires a plaintiff to show a false or misleading statement that specifically refers to the plaintiff’s product or business and clearly derogates that product or business; and (2) because Dahl’s suit did not allege that Ultimate clearly derogated the Multi-Cart, there was no claim of disparagement triggering Harford’s duty to defend. View "Hartford Cas. Ins. v. Swift Distrib., Inc." on Justia Law