Justia California Court of Appeals Opinion Summaries

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

A taxpayer challenged a California school district’s use of a “lease-leaseback” arrangement with a contractor for constructing a new middle school. The plaintiff alleged the $36 million construction contract violated California’s competitive bidding statutes and conflict of interest laws. The district had selected the contractor from a prequalified pool and entered into preconstruction agreements, then executed lease-leaseback contracts for the project. The project was funded entirely by the proceeds of bonds approved by local voters, not by contractor-provided financing.Previously, the Superior Court of Fresno County dismissed the complaint, but on the first appeal, the California Court of Appeal, Fifth Appellate District, held that the plaintiff had stated claims for both competitive bidding and conflict of interest violations. After further proceedings and another appeal, the California Supreme Court confirmed that the validation statutes did not bar the action, and the case proceeded to a bench trial. The trial court found the lease-leaseback arrangement qualified for the statutory exception to competitive bidding and rejected the conflict of interest claim, concluding the contractor was not an “officer” or “employee” for purposes of the conflict of interest statute.On appeal, the California Court of Appeal, Fifth Appellate District, held that the conflict of interest claim was properly rejected because the contractor did not act as an officer or employee of the district. However, the court concluded that the competitive bidding exception did not apply because the project was financed by public bonds, not by the contractor. The court held that the proper remedy under Education Code section 17406(d)—enacted after the initial appeal—was to require the contractor to disgorge its net profit ($236,129), not the full contract amount. The judgment was reversed in part, and the trial court was directed to enter judgment requiring the contractor to refund its profit to the district. View "Davis v. Fresno Unified School Dist." on Justia Law

While working for her employer, Jennifer Slamer suffered respiratory injuries due to exposure to a disinfectant produced by a third party. Her employer settled her claim for workers’ compensation benefits through an administrative proceeding. Subsequently, Jennifer and her spouse sued the manufacturer of the disinfectant, her employer, and related entities for damages stemming from her workplace injuries. After several pretrial motions, the employer and its affiliates were dismissed from the lawsuit with prejudice. The Slamers continued their case against the manufacturer and ultimately settled with it before the matter was submitted to the jury. The entire action was voluntarily dismissed with prejudice after the settlement.During the litigation, the employer paid workers’ compensation benefits to Jennifer and filed lien notices seeking reimbursement from any judgment or settlement obtained by the Slamers. After the settlement and dismissal, the employer moved in the Superior Court of San Bernardino County for reimbursement of the benefits it had paid, arguing it was entitled to recover these funds from the settlement proceeds. The Slamers opposed, contending the court could not order reimbursement after the settlement proceeds had been disbursed and the action dismissed, and further disputed the amount sought. The trial court granted the employer’s motion and ordered the Slamers to reimburse the full amount of the lien plus interest.On appeal, the Court of Appeal, Fourth Appellate District, Division One, held that once the Slamers voluntarily dismissed the entire action with prejudice, the trial court lost subject matter jurisdiction and could not rule on the reimbursement motion. The court concluded the order requiring reimbursement was void and reversed it, directing the trial court to enter a new order denying the motion for lack of jurisdiction. The decision did not resolve other arguments raised by the Slamers or address potential alternative remedies for the employer. View "Slamer v. Southern Cal. Permanente Medical Group" on Justia Law

During the 1978–1979 school year, a public high school student alleged that he was sexually abused on multiple occasions by his science teacher, who had recently been hired by the district. The student, then 16 years old, reported that the teacher “groomed” him, leading to sexual conduct that occurred off campus. The student did not disclose the abuse until it was revealed during a parent-teacher conference at his home, after which his mother called law enforcement. He subsequently ceased attending the high school and finished the semester through independent study.Years later, the student filed suit against the school district, alleging negligent hiring, supervision, and retention of the teacher, as well as negligent supervision of him as a minor. He claimed that the district’s administrators and supervisory employees knew or should have known about the teacher’s dangerous propensities or had received complaints regarding her conduct. The Superior Court of Riverside County granted summary judgment in favor of the school district, finding there was no evidence that its supervisory personnel had actual or constructive knowledge of the teacher’s dangerous tendencies before or during the abuse. The student appealed, arguing that the lack of district records or evidence of its policies from 1978 precluded summary judgment and that the district failed to prove it properly vetted or supervised the teacher.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case de novo and affirmed the trial court’s judgment. The court held that the district met its initial burden by showing there was no evidence of actual or constructive knowledge of the teacher’s dangerous propensities among supervisory personnel. The plaintiff failed to raise a triable issue of material fact, as he provided no admissible evidence that the district knew or should have known of the risk prior to the abuse. The absence of historical records regarding hiring or supervision did not create a triable issue. The judgment for the district was affirmed. View "N.K. v. Palm Springs Unified School District" on Justia Law