Justia California Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of three counts of first degree murder with a multiple-murder special circumstance, one count of attempted murder, and firearm enhancements for the shootings and attempted shootings of staff members at a hospital. After two penalty trials that resulted in hung juries, the third penalty jury returned a verdict of death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court’s denial of Defendant’s motion to recuse the district attorney’s office was not an abuse of discretion; (2) the trial court erred in its instructions to the jury, but the error was harmless; (3) retrial did not violate Defendant’s rights to due process and equal protection and the prohibition against cruel and unusual punishment; (4) Defendant was not deprived of the right to equal protection and trial by a representative jury because the jury included no Vietnamese-Americans; (5) although the prosecutor engaged in misconduct during the penalty phase, the improper questions did not influence the verdict; and (6) Defendant’s allegations of error in post-trial issues were without merit. View "People v. Trinh" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted premeditated murder, two counts of second degree robbery and arson causing great bodily injury. The jury returned a verdict of death. The Supreme Court vacated Defendant’s arson-murder special-circumstance finding but otherwise affirmed the judgment in its entirety, holding (1) the trial court did not err in restricting Defendant’s counsel’s questioning of prospective jurors during voir dire; (2) the evidence was insufficient to support the arson-murder special circumstance because the arson did not involve an inhabited structure or property; (3) the trial court did not abuse its discretion in dismissing a juror during the trial; (4) the trial court did not prejudicially err in its instructions to the jury; (5) the trial court did not err in refusing to declare a mistrial after the penalty jury initially declared it was deadlocked; and (6) Defendant’s challenges to the constitutionality of California’s death penalty scheme were without merit. View "People v. Debose" on Justia Law

Defendant was found guilty of failing to stop at a red traffic light at an intersection. Defendant's conviction was based on evidence generated by an automated traffic enforcement system (ATES), otherwise known as a red light traffic camera. Defendant’s conviction was upheld on appeal. At issue before the Supreme Court was whether the trial court properly admitted the ATES evidence over Defendant’s objections of inadequate foundation and hearsay. The Supreme Court affirmed, holding (1) sufficient evidence was submitted for the court to sustain a finding that the ATES evidence was adequately authenticated; and (2) ATES evidence does not constitute hearsay. View "People v. Goldsmith" on Justia Law