Justia California Court of Appeals Opinion Summaries

An employee who worked for a company from May 2021 until his termination in January 2024 signed an arbitration agreement at the start of his employment. This agreement required any employment-related disputes to be resolved through binding arbitration on an individual basis, with a waiver of class and collective actions. In November 2024, the employee notified the Labor and Workforce Development Agency (LWDA) of alleged Labor Code violations by his employer. After the LWDA did not respond within the statutory period, he became authorized to pursue a civil action for penalties under the Private Attorneys General Act (PAGA), acting as a proxy for the state. He subsequently filed a complaint in Stanislaus County Superior Court asserting only nonindividual PAGA claims—claims on behalf of other aggrieved employees and not for his own individual recovery—for various Labor Code violations.The employer responded by filing a motion to compel arbitration, arguing that PAGA required the inclusion of individual claims and that the arbitration agreement should apply. The Superior Court denied this motion, noting procedural irregularities and emphasizing that binding precedent allowed PAGA actions consisting solely of nonindividual claims. The court referenced a split in authority on whether PAGA actions could be limited to nonindividual claims, but ultimately relied on decisions holding such actions permissible, especially after recent statutory amendments.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the trial court’s decision. The appellate court held that, under the version of PAGA effective July 1, 2024, an aggrieved employee may bring a PAGA action consisting only of nonindividual claims and that these claims are not subject to arbitration, even if an arbitration agreement exists. The court further found that the statutory amendments did not require an employee to include individual claims, and that denying arbitration of nonindividual PAGA claims does not violate federal or state policy favoring arbitration. The denial of the motion to compel arbitration was affirmed. View "Castillo v. Belkorp AG, LLP" on Justia Law

The plaintiff, a former employee, brought claims against her employer alleging discrimination and retaliation under the California Fair Employment and Housing Act (FEHA), as well as wrongful discharge and breach of contract. After the employer prevailed on a motion for summary judgment, the trial court entered judgment in its favor, stating that the employer as the prevailing party could recover costs upon filing a memorandum of costs. The employer submitted a memorandum seeking over $15,000 in costs, which the trial court approved in an amended judgment when the plaintiff did not timely object.Following this, the plaintiff appealed solely on the issue of costs, not contesting the dismissal of her claims. She argued that, under FEHA, a prevailing defendant may only recover costs if the court expressly finds the action was frivolous, unreasonable, or groundless, as required by Government Code section 12965, subdivision (c)(6). The employer countered that the trial court’s judgment sufficiently implied such a finding, and that the plaintiff had waived her objections by not responding earlier. The Court of Appeal examined whether the trial court followed the proper procedure for awarding costs in FEHA cases.The Court of Appeal of the State of California, First Appellate District, Division Four, held that a prevailing defendant in a FEHA case cannot be awarded costs absent an express finding that the plaintiff’s action was frivolous, unreasonable, or groundless. The court found no such finding in the record, and determined that the trial court appeared to have applied the general rule for cost awards, not the heightened FEHA standard. Therefore, the appellate court reversed the amended judgment as to costs and remanded for further proceedings to determine whether the employer is entitled to costs under the correct legal standard. The plaintiff was awarded costs on appeal. View "San Diego-Tomas v. Aspire Bakeries, LLC" on Justia Law

A homeowner applied for a permit to construct an accessory dwelling unit (ADU) on his property in the City of Palos Verdes Estates. He alleged that, despite statutes requiring ministerial approval of such permits within a specific time, the City unlawfully delayed the process for over three years by imposing discretionary reviews and additional requirements. As a result of these delays, the homeowner claimed to have suffered significant financial damages, including increased construction costs and diminished property value.The matter was first heard in the Superior Court of Los Angeles County. The City demurred, arguing that the statutes governing ADU permitting were not intended to protect the private financial interests of individual homeowners, but rather to address the public’s general interest in increasing housing supply. The trial court agreed, finding that the relevant statutes aimed to facilitate housing construction generally, not to protect homeowners from financial losses due to permitting delays. The court sustained the City’s demurrer, and judgment was entered in favor of the City.The California Court of Appeal, Second Appellate District, Division Four, reviewed the case. It held that the statutory duty to ministerially and promptly approve ADU permits was designed to confer a direct benefit on permit applicants, such as the homeowner in this case. The court reasoned that preventing delays for ADU applicants is not incidental but central to the statutory scheme. Consequently, the homeowner stated a valid cause of action under Government Code section 815.6 for damages resulting from the City’s failure to comply with its mandatory duty. The appellate court reversed the judgment of the Superior Court, allowing the claim to proceed. View "Shi v. City of Palos Verdes Estates" on Justia Law

A juvenile, C.M., was subject to delinquency and probation violation proceedings in Tehama County and Glenn County, respectively, after engaging in criminal conduct and violating probation. Both cases were initiated while C.M. was still 17 years old. During the proceedings, evidence emerged that C.M.’s parents resided in Mariposa County. By the time the courts considered transferring the cases, C.M. had turned 18. Both the Tehama County Superior Court and the Glenn County Superior Court found that C.M.’s legal residence was with his parents in Mariposa County and ordered the transfer of the respective cases to Mariposa County Superior Court for disposition.The Mariposa County Superior Court accepted the transfers, but Mariposa County appealed both orders. On appeal, Mariposa County argued that the transferring courts erred in determining Mariposa County as C.M.’s county of residence because C.M. was no longer a minor at the time of the transfer orders. Mariposa County also contended that the transferring courts failed to consider whether the transfer would be in C.M.’s best interest as required by California Rules of Court, rule 5.610(e).The California Court of Appeal, Third Appellate District, reviewed the statutory framework of Welfare and Institutions Code section 750 and relevant rules. The court concluded that, because C.M. was no longer a minor at the time of the transfer-out hearings, his residence could not be derived from that of his parents for the purposes of section 750. The court further held that, under the first clause of section 750, there was no basis for transferring the cases to Mariposa County because C.M. did not reside there at the relevant time. Accordingly, the Court of Appeal reversed both transfer-out orders. View "In re C.M." on Justia Law

Police officers observed Anthony Thomas commit two minor traffic violations but did not issue him a ticket. After Thomas parked his car legally in a parking lot and began to walk away, officers approached him, expressing suspicion about his actions and the vehicle. Due to an error in running the license plate, officers received a “no information” result, which increased their suspicion that the vehicle might be stolen. Although Thomas explained the car was his mother’s rental and this proved true, officers decided to impound the vehicle under a provision of the Vehicle Code that was inapplicable, as the car was legally parked with valid plates. Without verifying the vehicle’s status or giving Thomas an opportunity to arrange for someone to move it, officers arrested him on an outstanding misdemeanor warrant and conducted a search that uncovered a gun, leading to firearms charges.In the Superior Court of Los Angeles County, Thomas moved to suppress the gun evidence, arguing that the search was not a valid inventory search and lacked a true community caretaking purpose. The court denied the motion without making findings about the officers’ motivation for impoundment. Thomas then pleaded guilty, preserving his right to appeal the suppression issue.Upon review, the Court of Appeal of the State of California, Second Appellate District, Division Eight, found that the search did not qualify as a valid inventory search because the prosecution failed to show a legitimate community caretaking rationale. Instead, the officers’ actions indicated an investigatory purpose. The court held that the prosecution did not meet its burden to justify the warrantless search, and the inventory search exception could not be used as a pretext for investigating criminal activity. The order denying the suppression motion was reversed, and the case was remanded with instructions to grant the suppression motion. View "People v. Thomas" on Justia Law

In a marital dissolution case, both spouses filed cross-petitions for divorce and requested domestic violence restraining orders. The trial court issued a restraining order in favor of the wife and later considered allegations that the husband violated this order, ultimately finding him not guilty of contempt after a trial. Subsequently, the wife pursued contempt proceedings based on the same alleged violations, but the husband was again found not guilty. The wife then sought sanctions and attempted to subpoena the husband’s communications, while the husband moved for sanctions under Family Code section 271, arguing that the wife’s conduct—including her pursuit of the contempt action—unnecessarily delayed the litigation and increased costs.The Superior Court of San Diego County considered the husband’s motion and awarded him $50,000 in attorney fees and costs as sanctions under Family Code section 271. The court found that the wife’s actions, particularly her pursuit of the unsuccessful contempt proceeding and related subpoena, impeded resolution and increased litigation expenses. The wife challenged this order, arguing that the unilateral fee provision in Code of Civil Procedure section 1218, subdivision (a), which allows only the party initiating a contempt proceeding to recover attorney fees, barred any award to the husband. She also claimed that the husband’s motion for sanctions was untimely under California Rules of Court, rule 3.1702(b), since it was filed more than 180 days after the order dismissing the contempt action.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court’s order. The appellate court held that Family Code section 271 and Code of Civil Procedure section 1218, subdivision (a) serve distinct purposes and do not irreconcilably conflict, allowing both to be applied concurrently. The court also determined that the order dismissing the contempt proceeding was not a final “judgment” for purposes of rule 3.1702(b), so the motion for sanctions was timely. View "Arora v. Arora" on Justia Law

A 16-year-old minor was alleged in Riverside County to have committed attempted murder and assault with a deadly weapon, as well as personally inflicting great bodily injury. The minor admitted to the assault charge and to inflicting great bodily injury. The attempted murder charge was dismissed. Jurisdiction was transferred to Los Angeles County for disposition, where, upon completion of probation, the court terminated probation and ordered the minor’s juvenile record sealed under Welfare and Institutions Code section 786.The People objected to the sealing, arguing that although assault with a deadly weapon is not expressly listed in Welfare and Institutions Code section 707, subdivision (b), it should be interpreted as equivalent to assault by means of force likely to produce great bodily injury, an offense that is listed. The Los Angeles County Superior Court disagreed, finding that the offense adjudicated was not one expressly listed in section 707, subdivision (b), and sealed the record. The People sought review by filing a petition for writ of mandate in the California Court of Appeal, Second Appellate District, Division Five.The California Court of Appeal, Second Appellate District, Division Five, reviewed the statutory language, legislative history, and relevant case law. The court held that section 786 does not prohibit the dismissal of a juvenile petition and sealing of a record where the offense adjudicated was not expressly listed in section 707, subdivision (b). The court concluded that the juvenile court may seal records in such cases, and that conducting post-disposition hearings to determine whether an offense could have been charged under section 707, subdivision (b) is not required. The petition for writ of mandate was denied. View "People v. Superior Court" on Justia Law

A property management company in Los Angeles employed an individual from April 2023 to September 2024. As part of the hiring and onboarding process, the employee was required to sign an arbitration agreement that mandated all employment-related claims be resolved through binding arbitration and included a waiver of class and representative actions. The employee later filed a class action lawsuit against the employer, alleging wage-and-hour violations and unfair business practices.The employer responded by filing a motion in the Superior Court of Los Angeles County to compel arbitration of the employee's individual claims, dismiss the class claims, and stay the action. The employer made clear that the Federal Arbitration Act (FAA) did not apply and relied on California law. The employee opposed, arguing that under California Labor Code section 432.6, it is illegal for an employer to require an employee to sign an arbitration agreement as a condition of employment unless the agreement is enforceable under the FAA. The Superior Court denied the employer’s motion, finding that the arbitration agreement was required as a condition of employment, thus violating section 432.6, and that, since the FAA did not apply, the agreement was unenforceable under California law.On appeal, the Court of Appeal of the State of California, Second Appellate District, Division Four, affirmed the trial court’s order. The appellate court held that, under California law, an arbitration agreement required as a condition of employment in violation of section 432.6 is unenforceable unless it is otherwise enforceable under the FAA. Because the parties agreed the FAA did not apply and the agreement was required as a condition of employment, the employer could not enforce it. The court affirmed the denial of the motion to compel arbitration. View "Molina v. Triumph Residential Services, Inc." on Justia Law

The defendant was charged in San Bernardino County with multiple offenses, including felony marijuana cultivation under Health and Safety Code section 11358, subdivision (d)(3), misdemeanor possession of marijuana for sale, and felony receipt of proceeds derived from controlled substances. The prosecution alleged aggravating circumstances for the felony cultivation charges, such as illegal discharge of waste and causing substantial environmental harm. The defendant pled guilty to two counts of felony marijuana cultivation and one count of misdemeanor possession for sale. The trial court suspended imposition of sentence, granted probation for two years, and ordered a period of county jail time to be served by work release.After completing probation, the defendant moved to dismiss the convictions under Penal Code section 1203.4 and to reduce the felony convictions to misdemeanors under Penal Code section 17, subdivision (b). The Superior Court of San Bernardino County granted the dismissal but denied the motion to reduce the felonies, reasoning that the relevant statute did not permit the offenses to be treated as wobblers, but rather as straight felonies.On appeal, the California Court of Appeal, Fourth Appellate District, Division Two, reviewed the statutory language and its amendments following Proposition 64. The court concluded that Health and Safety Code section 11358, subdivision (d), uses permissive language (“may be punished”) indicating that the offense is a wobbler, not a straight felony. Therefore, the trial court erred as a matter of law in denying the defendant’s motion on the basis that it lacked discretion. The Court of Appeal reversed the trial court’s order and remanded the matter for the lower court to exercise its discretion as to whether to reduce the felony convictions to misdemeanors. View "People v. Baxter" on Justia Law

Douglas Smith, a long-term high school science teacher, refused to comply with his employer’s COVID-19 vaccination mandate due to his religious beliefs. The Burbank Unified School District granted his request for a religious exemption but placed him on indefinite unpaid leave, stating that no other accommodation could be provided without undue hardship. Smith requested alternative accommodations such as masking and weekly PCR testing, but the District denied these, citing concerns about health and safety for staff and students. After a year on unpaid leave, Smith found employment at a school without a vaccine mandate and eventually resigned from the District.The Superior Court of Los Angeles County reviewed Smith’s claims under the Fair Employment and Housing Act (FEHA), which included religious discrimination, failure to prevent discrimination, and retaliation. The District moved for summary judgment, arguing that unpaid leave was the only reasonable accommodation that did not pose an undue hardship, given the nature of Smith’s teaching responsibilities and the operational impacts of allowing unvaccinated teachers on campus. The trial court found that Smith established a prima facie case for religious discrimination, but concluded the District met its burden in showing that alternative accommodations were not feasible, and thus granted summary judgment in favor of the District.The Court of Appeal of the State of California, Second Appellate District, Division Eight, independently reviewed the summary judgment. It held that, under FEHA, unpaid leave can be a reasonable accommodation where other options pose an undue hardship, especially given the District’s obligation to protect health and safety during the pandemic. The Court affirmed the trial court’s judgment, specifying that the parties would bear their own costs on appeal. View "Smith v. Burbank Unified School Dist." on Justia Law