Justia California Court of Appeals Opinion Summaries

In 2018, a juvenile wardship petition alleged that E.J. committed several offenses, including assault with a deadly weapon other than a firearm. E.J. admitted to that charge as part of a negotiated disposition, and the juvenile court found the allegations true, dismissed the remaining counts, declared E.J. a ward of the court, and placed him on probation. In 2019, the court reduced the offense to a misdemeanor, terminated probation, discharged E.J. as a ward, and sealed the record. Despite these actions, E.J. remained subject to a statutory firearm prohibition until age 30 under Penal Code section 29820.In 2025, E.J. filed a motion in the Superior Court of San Bernardino County to terminate the firearm prohibition. The juvenile court denied the motion. E.J. appealed, arguing that Penal Code section 29820 was facially unconstitutional under the Second and Fourteenth Amendments, claiming it failed to align with the nation’s historical tradition of firearm regulation, improperly used age as a proxy for dangerousness, and did not provide a mechanism for individualized assessment regarding dangerousness.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that section 29820 is not facially unconstitutional. It found that firearm prohibitions based on juvenile adjudications for certain offenses are consistent with the historical tradition of firearm regulation and that the statute’s application based on prior adjudication—not age alone—does not offend the Second Amendment. The court also held that due process does not require an individualized assessment of dangerousness when the statute’s application is triggered solely by a prior adjudication. The court further found that any as-applied challenge was forfeited because it was not raised in the trial court or in E.J.’s opening brief. The order was affirmed. View "In re E.J." on Justia Law

A criminal complaint was filed against an individual in July 2024, alleging multiple counts of lewd acts, forcible lewd acts, and continuous sexual abuse of four minors, all of whom are his grandchildren. The prosecution also alleged a multiple victim enhancement. At an initial arraignment, the magistrate court set bail and imposed protective orders. Later, the prosecution moved to have the defendant held without bail, citing the danger he posed to the community. At a Humphrey hearing, the prosecution presented testimony and evidence suggesting repeated sexual abuse over many years, including admissions by the defendant. The magistrate court found this evidence reliable and determined that nonfinancial conditions of release would not protect the public or victims, ordering the defendant held without bail.The defendant challenged the no-bail order in the Superior Court of Fresno County through a petition for writ of habeas corpus. He argued the magistrate court abused its discretion, particularly in considering the prosecution’s request for remand without bail absent a change in circumstances, and asserted there was insufficient evidence to support a finding of substantial likelihood of great bodily harm. The superior court issued an order to show cause on these specific issues but ultimately denied the petition after considering the parties’ responses.Upon further review, the California Court of Appeal, Fifth Appellate District, was directed by the California Supreme Court to address whether Penal Code section 292 constitutes an impermissible legislative extension of the constitutional terms “acts of violence” and “great bodily harm,” and whether, absent section 292, clear and convincing evidence supported denial of bail. The appellate court held that section 292 is a valid legislative implementation, not an invalid extension, of the bail exception in article I, section 12 of the California Constitution. The court further found that substantial evidence supported the finding that the defendant’s release would pose a substantial likelihood of great bodily harm, and denied the petition for writ of habeas corpus. View "In re Bergstrom" on Justia Law

A county office established to oversee the sheriff’s department received a whistleblower complaint and, in conducting its investigation, issued subpoenas to certain sheriff’s employees seeking documents and testimony. The sheriff’s employees refused to comply, and both the sheriff’s office and the deputy sheriffs’ union asserted that the oversight office did not have authority to issue subpoenas related to whistleblower investigations. The oversight office then petitioned the Sonoma County Superior Court for an order enforcing the subpoenas and initiating contempt proceedings against the noncompliant parties.The Sonoma County Superior Court denied the oversight office’s request, finding that it did not have the authority to issue the subpoenas under the relevant laws and local ordinances. The oversight office appealed this denial, arguing that state law granted it subpoena power and that no labor agreement or local ordinance eliminated this authority.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. It first determined that the trial court’s order was appealable as a final judgment. On the merits, the appellate court held that section 25303.7 of the Government Code directly grants subpoena power to sheriff oversight entities created under that statute, and that the oversight office in question qualified as such an entity—even though it was not named “inspector general.” The court further held that the existence of a labor agreement between the county and the union did not eliminate the statutory subpoena authority and that any contrary provisions in the agreement could not override state law. The court also rejected arguments that the oversight office lacked authority to investigate the sheriff individually, and found that newly enacted law clarified that such entities have access to peace officer personnel records. The appellate court reversed the trial court’s order and remanded with instructions to enforce the subpoenas. View "Independent Office of Law v. Sonoma County Sheriff's Office" on Justia Law

The case concerns a dispute arising from a real estate transaction involving an 80-acre property in Livermore, California. Guinnane Construction Co., Inc. entered into a contract to purchase an interest in the property from the Petersons, after being assigned the DeLimas’ right of first refusal. Defendants, including Edmund Jin, his real estate agent Stephen Marc Chess, and Chess’s firm, interfered with this transaction by negotiating a purchase with the Petersons despite knowledge of the right of first refusal. The Petersons ultimately sold their interest to Jin, prompting Guinnane to file a successful specific performance action against the Petersons and the subsequent conveyance of the property interest to Guinnane.After prevailing in the specific performance action, Guinnane filed a new lawsuit in the Alameda County Superior Court against Jin, Chess, and Chess’s firm, seeking damages for inducement of breach of contract and intentional interference with contractual relations. Guinnane was awarded compensatory damages, including the attorney fees incurred in the specific performance action. Guinnane then sought to recover the attorney fees incurred in prosecuting this subsequent “tort of another” action against the defendants. The trial court, presided over by Judge Victoria Kolakowski, denied Guinnane’s motion for these additional fees.On appeal, the Court of Appeal of the State of California, First Appellate District, Division Two, reviewed whether, under the tort of another doctrine, Guinnane could recover attorney fees incurred in the action against the tortfeasors themselves. The court held that such fees are not recoverable under the tort of another doctrine, as it allows recovery only for fees incurred in litigation with third parties necessitated by the defendant’s tort, not for fees incurred in suing the tortfeasor. The court affirmed the posttrial order denying Guinnane’s motion for these attorney fees. View "Guinnane Construction Co., Inc. v. Chess" on Justia Law

A dispute arose over the parentage of a young child, Stella, after her birth in October 2021. One day after Stella was born, her mother, Priscilla, and Steven signed a Voluntary Declaration of Parentage (VDOP) listing Steven as her other parent. However, Priscilla had married another man, Gianni, in October 2020, about a year before Stella’s birth. Priscilla later sought to set aside the VDOP, arguing that because she was married to Gianni at the time, Gianni was Stella’s presumed parent under California Family Code section 7611. Priscilla provided a confidential marriage certificate as evidence of her marriage to Gianni.In response, Steven contended that Priscilla’s marriage to Gianni was invalid because the couple had not been “living together as spouses” before their marriage, a requirement under California law for confidential marriages. After an evidentiary hearing, the Superior Court of San Diego County found that Priscilla and Gianni had not cohabitated as spouses before their marriage, declared the marriage invalid, and denied Priscilla’s application to set aside the VDOP. Priscilla appealed from that order.The California Court of Appeal, Fourth Appellate District, Division One, determined that the order denying Priscilla’s application was not appealable, but exercised its discretion to treat the appeal as a petition for writ of mandate. The appellate court held that, under Family Code section 7611(b), a person may be a presumed parent if they attempted to marry the birth parent by a marriage solemnized in apparent compliance with the law, even if the marriage could be declared invalid. Here, the undisputed evidence showed that Gianni and Priscilla had attempted such a marriage, and Stella was born during it. Therefore, Gianni was Stella’s presumed parent when the VDOP was signed, rendering the VDOP void by law. The appellate court granted Priscilla’s petition and directed the trial court to set aside the VDOP. View "Steven N. v. Priscilla C." on Justia Law

A man on probation was investigated for allegedly diverting customer payments from his employer to himself. Law enforcement learned that, as a condition of his probation, he had agreed to allow searches of his person, residence, and electronic devices, but his probation terms specifically excluded “financial accounts or transactions” from warrantless searches. During the investigation, officers arrested him, seized his phone, and searched several banking applications, including Apple Pay. Information from Apple Pay revealed the existence of certain bank accounts, which led officers to obtain a warrant to search those accounts and gather further evidence.In the Superior Court of Orange County, the defendant moved to suppress the evidence obtained from the bank accounts and to quash the warrant, arguing that the Apple Pay search exceeded the scope of his probation terms and that the subsequent warrant was based on unlawfully obtained information. The prosecution argued the motion was more properly a motion to traverse the warrant, contending that Apple Pay was not a “financial account” and that the warrant was supported by probable cause. The trial court denied the suppression and quash motions.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. It held that the defendant’s motion should be treated as a motion to traverse the warrant, as the warrant affidavit omitted material information about the probation search limitations. The court found that Apple Pay is a “financial account” under the plain meaning of the probation terms. Because the information about the bank accounts was obtained through an unlawful search of a financial account, it was improperly included in the warrant application. The appellate court ordered the trial court to vacate its earlier order and grant the motion to suppress the evidence obtained from the bank accounts. View "Meiner v. Superior Court" on Justia Law

A group of local residents and environmental organizations opposed a California Department of Transportation (Caltrans) highway project in Humboldt County that would reconfigure a stretch of U.S. Highway 101 through Richardson Grove State Park, an area containing old-growth redwood trees. The opposition centered on concerns that the project would damage the trees and their root systems. Caltrans initially certified an Environmental Impact Report (EIR) for the project, concluding there would be no significant environmental impacts. Over the years, the challengers brought multiple legal actions, arguing that Caltrans’ environmental review failed to meet the requirements of the California Environmental Quality Act (CEQA).After the initial EIR was invalidated on appeal for not adequately analyzing impacts on redwood tree roots (Lotus v. Department of Transportation), Caltrans prepared an Addendum with new analysis and recertified the EIR. However, a second trial court judgment found Caltrans violated CEQA by not allowing public review of the Addendum, ordering that it be circulated for comment. Caltrans complied, and both previous writs were eventually discharged. The plaintiffs did not appeal the discharge orders. The present case arose from a third petition challenging the substantive adequacy of the Addendum and Caltrans’ compliance with CEQA.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court held that the lower court’s discharge of the initial writ (the Lotus writ) necessarily determined that Caltrans’ revised analysis complied with CEQA. Because the plaintiffs did not appeal that decision, the doctrine of res judicata barred them from relitigating the adequacy of the Addendum in this new action. The court affirmed the judgment denying the third petition, thus precluding further CEQA challenges to the Addendum’s substantive analysis of impacts on the redwoods. View "Bair v. Cal. Dept. of Transportation" on Justia Law

The case concerns the Department of Water Resources (DWR), a state agency with eminent domain authority, which sought entry onto private properties to perform environmental and geological studies as part of the planning for a potential water conveyance project in the Sacramento-San Joaquin Delta. DWR initiated a series of petitions under California’s precondemnation entry statutes, which authorize entities with eminent domain power to access property for investigative activities before deciding whether to acquire the property for a public project.Previously, the San Joaquin County Superior Court coordinated the petitions and permitted DWR to conduct environmental studies under certain conditions but denied entry for geological testing, reasoning that such actions constituted a taking requiring a classic condemnation action. The California Court of Appeal initially agreed, but the California Supreme Court reversed in Property Reserve, Inc. v. Superior Court (2016) 1 Cal.5th 151, holding that the precondemnation entry statutes provide a constitutionally valid process for precondemnation activities, so long as landowners can obtain a jury trial on damages. Following this, the trial court approved DWR’s authority for both environmental and geological tests, and additional entry orders were issued for the Delta Conveyance Project.The California Court of Appeal, Third Appellate District, reviewed whether DWR was required to have an authorized and funded project under Water Code sections 250 and 11580 before undertaking precondemnation entry and testing. The court held that these requirements apply only to classic condemnation proceedings, not to precondemnation entry activities. The court affirmed that DWR need only possess general eminent domain authority to utilize the precondemnation entry process, regardless of whether the activities might constitute a taking. The trial court’s entry order was affirmed. View "Dept. of Water Resources Cases" on Justia Law

A noncitizen defendant was charged in 2015 with serious felonies, including assault with intent to commit rape, following a single incident. He faced nearly certain deportation if convicted, as his charges qualified as “aggravated felonies” under federal immigration law. Initially represented by a public defender, the defendant later retained new counsel and proceeded to trial, ultimately being convicted on all counts in 2017. During plea negotiations, the prosecution required any deal to include prison time, sex offender registration, and a “strike,” but no immigration-safe plea was pursued. Notably, after the defendant changed attorneys, a federal appellate decision altered the immigration consequences for certain California offenses, making immigration-neutral pleas possible.After completing his sentence, the defendant filed a motion under California Penal Code section 1473.7 to vacate his conviction, arguing that he did not meaningfully understand the dire immigration consequences of conviction and would have sought an immigration-safe plea had he been properly advised. The Superior Court of Riverside County denied the motion, finding the defendant was ineligible for relief because his conviction was final before the current statutory amendment applied, and concluding he would not have accepted a plea in any event.On appeal, the Court of Appeal of the State of California, Fourth Appellate District, Division Two, reversed. The appellate court held that Penal Code section 1473.7 relief is available for final convictions, including those after trial, and found that the defendant did not meaningfully understand the immigration consequences. The court further held there was a reasonable probability he would have pursued an immigration-safe plea, and that such a plea would likely have been accepted by the prosecution and trial court. The appellate court remanded with instructions to grant the motion and vacate the conviction. View "P. v. Avena" on Justia Law

A group of teachers working in three schools within a California school district experienced chronic teacher vacancies, which the district addressed by employing long-term and rotating substitutes rather than permanent, qualified teachers. These schools faced heightened challenges, including high poverty rates, a large proportion of English learners, and low graduation rates. The teachers, acting under a statutory complaint procedure known as a “Williams complaint,” alleged the district’s staffing practices violated state law and demanded that the district cease its use of rolling substitutes, instead implementing processes to recruit, hire, and assign legally authorized teachers.After the district responded by acknowledging its non-compliance but claiming an inability to hire enough qualified teachers due to statewide shortages, the teachers unsuccessfully appealed to the district’s Board of Education. They then filed a petition for traditional mandate, declaratory, and injunctive relief in the Superior Court of Contra Costa County. At the hearing, the district asserted it had made all reasonable efforts to fill vacancies but was still unable to do so, and the trial court denied the writ, finding the district was not refusing to comply with the law but faced circumstances beyond its control.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court determined that the trial court’s denial of the writ was premature and erroneous because the district had not demonstrated it had exhausted all statutory options for filling teacher vacancies, including seeking waivers from relevant state agencies. The appellate court held that the doctrine of impossibility was not available to the district until all required steps had been tried and found wanting. The court issued a peremptory writ of mandate, directing the trial court to vacate its order and denying the petition, with instructions to comply with statutory requirements. View "West Contra Costa Unified School Dist. v. Super. Ct." on Justia Law