Justia California Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeal affirming the conclusion of the State Department of Health Care Services that the costs of outreach and education activities aimed at Medicaid-eligible patients were categorically nonreimbursable, holding that the chief administrative law judge's ruling was an abuse of discretion.Health care providers entitled to government reimbursement, including federally qualified health centers (FQHCs), for reasonable costs related to the care of Medicaid beneficiaries are required to offer outreach and education activities to members of underserved communities. The FQHC operator in this case sought reimbursement for the outreach and education costs, but the Department determined that the costs were nonreimbursable. The court of appeal affirmed. The Supreme Court reversed, holding that the Department's determination rested on a misunderstanding of relevant legal principles governing the reimbursement of medical provider costs. View "Family Health Centers of San Diego v. State Dep't of Health Care Services" on Justia Law

The Supreme Court held that under California's Motor Carriers of Property Permit Act, Cal. Veh. Code 34600 et seq., a commercial automobile insurance policy does not continue in full force and effect until the insurer cancels a corresponding certificate of insurance on file with the Department of Motor Vehicles (DMV).Insured was driving a truck covered by his policy with Insurer when he collided with a car, killing its driver. The driver's parents sued Insured for wrongful death, and Insured tendered his defense to Insurer. Insurer settled the claim for its policy limits and then sued Insured's former insurer (Defendant) for declaratory relief, equitable contribution, and equitable subrogation. The trial court held that Defendant's policy remained in effect on the date of the collision because one of Defendant's cancellation notices was rejected by the DMV as incomplete. The Court of Appeals for the Ninth Circuit certified a question of law to the Supreme Court, which answered that the Act does not require a commercial auto insurance policy to remain in effective indefinitely until the insurer cancels the certificate of insurance on file with the DMV. View "Allied Premier Insurance v. United Financial Casualty Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeal concluding that the actions of Defendants Lonnie Mitchell and Louis Mitchell were sufficient to demonstrate that each proximately caused the victim's death, regardless of who actually shot the victim, holding that Defendants' deadly actions in this case constituted proximate cause consistent with the holding in People v. Sanchez, 26 Cal. 4th 834.In Sanchez, the Supreme Court upheld the first-degree murder conviction of a defendant who had engaged in a shootout that left an innocent bystander dead. At issue in this case was whether Sanchez's analysis of "substantial concurrent cause" permitted Defendants' convictions. The Supreme Court affirmed, holding that the trial court, consistent with Sanchez, properly instructed the jury on substantial concurrent causation with respect to the victim's death. View "People v. Carney" on Justia Law

The Supreme Court held that an aggrieved employee who has been compelled to arbitrate claims under the Private Attorneys General Act of 2004 (PAGA), Cal. Lab. Code 2698 et seq., that are "premised on Labor Code violations actually sustained by" Plaintiff maintains statutory standing to pursue PAGA claims arising out of events involving other employees in court.The Supreme Court reversed the judgment of the court of appeals holding that the trial court properly found, among other things, that PAGA claims are not subject to arbitration, holding (1) to have PAGA standing, a plaintiff must be an "aggrieved employee" - i.e., one who was employed by the alleged violator and against whom one or more of the alleged violations was committed; and (2) when a plaintiff brings a PAGA action composed of both individual and non-individual claims, "an order compelling arbitration of the individual claims does not strip the plaintiff of standing to proceed as an aggrieved employee to litigate claims on behalf of other employees under PAGA." View "Adolph v. Uber Technologies, Inc." on Justia Law