Justia California Court of Appeals Opinion Summaries

After a divorce in 1996, a father was ordered by the San Luis Obispo County Superior Court to pay both family and child support. Over the ensuing years, he failed to fully comply with the court’s orders, moved out of state and later out of the country, and was declared in contempt for his failure to pay support. Nearly two decades later, after the youngest child had reached the age of majority, the father and mother discussed resolving the outstanding child support arrearages, which, including interest, totaled approximately $545,000. The father agreed to pay half that amount, and made several payments, but when he requested that the mother sign a written accord and satisfaction releasing him from any remaining arrearages, she declined.The father then filed a request in the San Luis Obispo County Superior Court, seeking a ruling that there was an enforceable agreement to resolve the arrearages. The superior court denied his request, finding that the parties did not reach a final, binding agreement and that there was no bona fide dispute as to the amount owed. The court also concluded that any purported accord and satisfaction was unenforceable under California law.On appeal, the California Court of Appeal, Second Appellate District, Division Six, affirmed the superior court’s order. The appellate court held that, consistent with California’s strong public policy, parents are precluded from contractually waiving or forgiving past due child support arrearages, even after the child has reached the age of majority and there is no longer a current support order. The court further found substantial evidence supporting the trial court’s findings that there was no bona fide dispute regarding the amount owed, and no enforceable agreement was formed. The appellate court also rejected the father’s arguments for waiver and estoppel. The order was affirmed. View "Marriage of Allen" on Justia Law

Several plaintiffs brought suit against a court-appointed receiver and his company, alleging breach of fiduciary duty. The underlying facts involve a criminal prosecution against one of the plaintiffs, Simon Semaan, for insurance fraud. In connection with the prosecution, the criminal court issued a temporary restraining order that froze certain assets and appointed the receiver to manage them. Later, the court ordered the receiver to liquidate specific stock holdings “as soon as practicable.” The receiver did not immediately liquidate the assets, citing ongoing settlement negotiations and concerns about account closure requirements. Plaintiffs alleged that, as a result of the receiver’s delay, the value of the investment accounts declined, causing them over $1.1 million in damages.After the receiver was replaced, the plaintiffs filed a civil lawsuit for breach of fiduciary duty in the Superior Court of Orange County. The defendants responded with an anti-SLAPP motion, arguing the claims arose from protected activity and that quasi-judicial immunity applied. The trial court granted the anti-SLAPP motion. The court found that the receiver’s conduct occurred within the scope of his appointment, that the litigation privilege applied, and that the receiver was protected by quasi-judicial immunity.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court affirmed the trial court’s order. It held that a court-appointed receiver is protected by quasi-judicial immunity for discretionary acts and decisions performed in the course of carrying out court orders. The court found that the plaintiffs’ claims arose out of the receiver’s discretionary decisions as receiver, which are constitutionally protected activities under the anti-SLAPP statute. Because of this immunity, the plaintiffs failed to show that their claims had the minimal merit necessary to survive an anti-SLAPP motion. The court thus affirmed the order striking the complaint. View "Semaan v. Mosier" on Justia Law

The case concerns a criminal defendant charged with kidnapping his fiancée, L.S., for ransom or extortion. At the time of the alleged offense, L.S. was under a temporary conservatorship due to a probate court’s finding that she was “gravely disabled” as defined by the Lanterman–Petris–Short Act (LPS Act), and the San Bernardino County Public Guardian was appointed as her conservator. After the defendant subpoenaed L.S. to testify in his defense at the preliminary hearing, the Public Guardian moved to quash the subpoena, arguing that L.S. was incompetent to testify by virtue of the probate court’s grave disability finding.The Superior Court of San Bernardino County granted the motion to quash, ruling that the finding of grave disability was tantamount to a finding of incompetence to testify under Evidence Code section 701, and that the issue did not need to be relitigated. The defendant then petitioned for a writ of mandate, challenging the trial court’s legal conclusion.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The appellate court held that a finding of grave disability under the LPS Act does not by itself establish incompetence to testify under Evidence Code section 701. The standards for grave disability and testimonial competence are distinct, and incompetence to testify may not be presumed from a grave disability finding or an involuntary medication order. The appellate court directed the superior court to vacate its order granting the motion to quash, to enter a new order denying the motion, and to determine L.S.’s competence to testify under the correct legal standard. The previously ordered stay was vacated upon issuance of the remittitur. View "Esparza v. Super Ct." on Justia Law

A.B., a 42-year-old individual with a longstanding diagnosis of schizoaffective disorder, had been receiving mental health services in San Francisco since 2008, including numerous psychiatric hospitalizations and crisis interventions. He was previously under conservatorship, which ensured compliance with medication, but historically disengaged from treatment and decompensated when conservatorship ended. In October 2023, following a psychiatric incident at home involving paranoia and disruptive behavior, A.B. was hospitalized. His mother, who provided housing, testified to his history of aggression and repeated decompensation when not medicated, stating she would not allow him to live with her absent a conservatorship and mandatory medication order.The San Francisco County Superior Court initially appointed the public conservator and imposed an involuntary medication order. After a mistrial in April 2023, the parties resolved the matter by conservatorship without a medication order, but following further decompensation, the conservator sought renewal with an involuntary medication order. At the 2025 court trial, testimony from A.B.’s mother and treating psychiatrist indicated that A.B. lacked insight into his illness, would not reliably take medication without a legal mandate, and was unable to maintain shelter independently. Although A.B. testified that he now recognized his diagnosis and would comply with medication, the court credited the testimony of his mother and psychiatrist over his own.The California Court of Appeal, First Appellate District, Division Two, held that substantial evidence supported the trial court’s findings that A.B. was presently gravely disabled due to his mental disorder and unable to provide for his own shelter without medication, which he would not take absent a court order. The appellate court also affirmed the finding that A.B. was incompetent to give or withhold informed consent for psychotropic medication. The orders renewing the conservatorship and involuntary medication were affirmed. View "Conservatorship of A.B." on Justia Law

A jury found the defendant guilty of unlawfully taking or driving a vehicle, conspiracy to commit vehicle theft, and receiving stolen property after he was observed towing a motorhome from an unoccupied property using makeshift equipment taken from the premises. He did not have permission to move either the motorhome or the equipment. The charges included allegations of prior convictions relating to vehicle theft and strike priors. The defendant waived his right to a jury trial on the priors and stipulated to one prior strike in exchange for dismissal of the other two.The Superior Court of San Diego County sentenced the defendant to six years on count one (three years, doubled for the strike), four years on count two (stayed under Penal Code section 654), and one year on count four (to run concurrently). The defendant appealed, alleging a violation of the Racial Justice Act (RJA) due to the use of a dog analogy during voir dire and closing arguments, and asserting several sentencing errors, including the procedure for priors and the application of sentences.The California Court of Appeal, Fourth Appellate District, Division One, held that the defendant forfeited the RJA claim by failing to object at trial and that, even if considered on the merits, the dog analogy did not constitute racially discriminatory language under section 745. The court also found sentencing errors: there were no findings on the prior convictions supporting the enhanced sentence under Penal Code section 666.5, and the defendant did not personally admit the strike prior. The court remanded the matter for resentencing to include a court trial on the qualifying prior conviction and confirmation of the strike admission, but affirmed the judgment in all other respects. View "P. v. Gomez" on Justia Law

The case concerns a job applicant who, after accepting an offer of employment as a sales associate at a large retailer, received an investigative consumer report as part of the onboarding process. The applicant was presented with a lengthy disclosure form that identified multiple consumer reporting agencies rather than only the one that provided her report. She alleged that the employer failed to comply with specific requirements under California’s Investigative Consumer Reporting Agencies Act (ICRAA), including not identifying the agency actually conducting the investigation in a standalone document, and including extraneous information. She also claimed other technical violations related to the handling of her report.The Superior Court of San Diego County reviewed the matter after the employee brought suit for ICRAA violations. The employer moved for summary judgment, arguing the plaintiff lacked standing because she did not suffer any concrete injury or adverse employment action resulting from the alleged violations—she was hired and received the report. The trial court agreed, finding that the applicant had not shown injury, and entered judgment for the employer.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that under the plain language of ICRAA, a consumer need only show that a statutory violation occurred to have standing and to recover the statutory sum of $10,000; no further showing of injury or harm is required. The court distinguished California law from federal standards, emphasized relevant legislative history, and declined to follow interpretations requiring proof of concrete injury. The appellate court reversed the trial court’s judgment and directed that summary judgment be vacated. View "Parsonage v. Wal-Mart Associates" on Justia Law

The plaintiff leased and later purchased a 2013 vehicle from the defendant, which subsequently developed engine problems. After experiencing issues like rattling and crunching noises and receiving a safety recall notice, the plaintiff sought repairs and eventually requested that the defendant repurchase the car due to unresolved defects. The defendant did not respond to these repurchase requests.The plaintiff sued for violations under the Song-Beverly Consumer Warranty Act, breach of warranties, fraud by omission, and the Consumer Legal Remedies Act (CLRA). The Superior Court of San Diego County sustained the defendant’s demurrer to the CLRA claim without leave to amend, citing the plaintiff’s failure to file a required venue affidavit with the complaint. During discovery, the defendant repeatedly objected to producing documents related to engine defects and verified, under penalty of perjury, that no responsive documents existed. The plaintiff challenged the adequacy of the defendant’s document search and later discovered evidence indicating the defendant had produced such documents to a government agency in another matter. The trial court denied the plaintiff’s motions to compel and for terminating sanctions, accepted the defendant’s responses, and excluded key evidence at trial, which left the plaintiff unable to prove fraud.At trial, the jury found that a defect existed but concluded the defendant remedied it, resulting in a defense verdict. The trial court denied the plaintiff’s motions for a new trial and judgment notwithstanding the verdict, focusing on the plaintiff’s delay in discovering withheld documents and awarding costs to the defendant.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reversed and remanded. The court held that the defendant’s discovery misuse denied the plaintiff a fair trial, requiring a new trial and monetary sanctions to compensate for costs and attorney fees. It also directed that the plaintiff be given leave to amend the CLRA claim and vacated the award of prevailing-party costs to the defendant. View "Higginson v. Kia Motors America" on Justia Law

A local government prepared and certified a program-level Environmental Impact Report (EIR) as part of a comprehensive update to its general plan, including an updated housing element. The housing element identified 17 sites, including Site H, to accommodate the town’s projected regional housing needs. Site H was proposed to be rezoned for very high density residential use, increasing its development capacity. No specific housing project had been proposed for Site H or the other sites at the time of the general plan update.The Committee for Tiburon LLC filed a petition for a writ of mandate in Marin County Superior Court, challenging the adequacy of the EIR. The Committee argued the EIR was deficient under the California Environmental Quality Act (CEQA) because it failed to include a site-specific analysis of environmental impacts related to the potential high-density development of Site H. The petition also alleged the Town’s general plan was internally inconsistent and incompatible, and objected to the rezoning of Site H. The trial court agreed with the Committee and granted the petition, finding the EIR should have included a site-specific analysis for Site H.On appeal, the California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court held that when a local government updates its general plan and housing element, and no specific project is proposed for a listed site, CEQA does not require the EIR to include a site-specific environmental analysis for that site. The absence of project-specific details makes such analysis infeasible, and site-specific review can be deferred until a project is proposed. The court reversed the trial court’s judgment granting the writ, and remanded the matter for further proceedings on the issues of CEQA exemption for rezoning and general plan consistency. View "The Committee for Tiburon LLC v. Town of Tiburon" on Justia Law

Plaintiffs, who provided subadvisory investment services and loaned $1.5 million to FolioMetrix (personally guaranteed by two individuals), later engaged with defendants involved in a proposed merger of investment firms. Plaintiffs alleged that during merger negotiations, defendant Putnam promised to relieve the original borrowers of their obligations and personally assume the debt. Subsequent communications referenced intentions to transfer the loan liability to the new entity, but when plaintiffs sought a formal promissory note, defendants refused. Ultimately, defendants did not repay any portion of the loan.Plaintiffs filed suit in the Superior Court of the City and County of San Francisco in March 2019, alleging breach of contract, fraud, negligent misrepresentation, and breach of the covenant of good faith and fair dealing. At trial, the central dispute was whether defendants had agreed to assume the loan obligations under the promissory note. Plaintiffs argued that the agreement was formed through emails and conduct, while defendants denied any assumption of liability. The jury found in favor of defendants, determining no contract was formed and no promise was made to repay the loans. Following trial, the court awarded defendants attorney fees under Civil Code section 1717, based on a fee provision in the original promissory note, after reducing the requested amount.On appeal, the California Court of Appeal, First Appellate District, Division Five, addressed several issues. It ruled that the automatic bankruptcy stay did not preclude resolution of the appeal because the debtor (NAI) was the plaintiff rather than a defendant. The court rejected plaintiffs’ claims of error regarding jury instructions on contract formation, finding insufficient argument and no prejudice. It affirmed the attorney fee award, concluding the action was “on the contract” containing the fee provision, and held the fee amount was within the trial court’s discretion. The judgment and fee order were affirmed. View "Navellier v. Putnam" on Justia Law

James Mason Heaps, a gynecological oncologist at UCLA, was prosecuted for multiple charges arising from medical examinations involving seven former patients. The allegations included sexual battery by fraud, sexual exploitation, and sexual penetration of an unconscious person during gynecological exams. The jury ultimately convicted Heaps on several counts involving two victims, acquitted him on others, and was unable to reach verdicts on some charges. Sentencing followed with an aggregate prison term of 11 years.The Superior Court of Los Angeles County presided over the trial and subsequent jury deliberations. During deliberations, a note was sent by the jury foreperson expressing concerns that Juror No. 15 lacked sufficient English proficiency to participate and had prematurely decided the case. The judicial assistant, rather than the judge, addressed the note directly with the jurors—speaking in both English and Spanish—without notifying counsel or making a record of the exchanges. Defense counsel was not informed of the note or these communications, and the trial proceeded to verdict. On appeal, the settled statement process included testimony and declarations clarifying the sequence of events, but key details remained unclear.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the case. It held that the trial court’s failure to notify counsel about the jury’s note and the judicial assistant’s ex parte communications with the jury during deliberations deprived the defendant of his Sixth Amendment right to counsel at a critical stage. The appellate court found that the prosecution had not met its burden to demonstrate, beyond a reasonable doubt, that this constitutional error was harmless. As a result, the judgment was reversed and the case remanded for a new trial. View "P. v. Heaps" on Justia Law