Justia California Court of Appeals Opinion Summaries

A fatal accident occurred in 2016 when a bicyclist, Jonathan Tansavatdi, collided with a turning truck at an intersection in the City of Rancho Palos Verdes. The bicycle lane on Hawthorne Boulevard ended before the intersection, forcing cyclists to share the roadway. Jonathan’s mother, Betty Tansavatdi, sued the City, alleging that the intersection constituted a dangerous condition of public property and that the City failed to adequately warn of this danger.The Superior Court of Los Angeles County initially granted summary judgment for the City based on the affirmative defense of design immunity under Government Code section 830.6. The trial court found the City had established all elements of design immunity regarding the absence of a bicycle lane. On appeal, the California Court of Appeal affirmed the finding of design immunity but remanded the case for consideration of the failure to warn claim. The California Supreme Court, in Tansavatdi v. City of Rancho Palos Verdes (2023) 14 Cal.5th 639, held that design immunity does not categorically preclude failure to warn claims and remanded the matter, leaving open whether design immunity applies if warnings were part of an approved design.Upon remand, the City renewed its motion for summary judgment, arguing that all warning signs and markings at the intersection were part of the 2009 approved design plans. The California Court of Appeal, Second Appellate District, held that when a public entity has provided some warning of a dangerous condition as part of an approved and reasonable design, complaints about the adequacy of that warning fall within the scope of design immunity. The court affirmed summary judgment for the City and upheld the award of expert fees, finding the City’s section 998 settlement offer valid. View "Tansavatdi v. City of Rancho Palos Verdes" on Justia Law

The defendant was convicted after jury trials in 2011 and 2012 of attempted murder, evading an officer, unlawfully taking a vehicle, and shooting at an inhabited dwelling. Each count included enhancements for gang involvement and firearm use, and he was sentenced to a total of 46 years and eight months to life in prison. Following direct appeal, the judgment was modified to reflect life with the possibility of parole on two counts, with a minimum parole eligibility of 15 years, and otherwise affirmed.Years later, the defendant filed a petition for recall and resentencing under California Penal Code section 1170, subdivision (d)(1), arguing that as a juvenile at the time of the offense and having served over 15 years, his lengthy sentence was effectively a life without parole (LWOP) term. He relied on appellate decisions holding that juvenile offenders sentenced to de facto LWOP terms should be eligible for relief under section 1170, subdivision (d)(1), on equal protection grounds. The Los Angeles County Superior Court reviewed the petition, considered recent appellate decisions and parties’ arguments, and denied the petition.The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. Applying de novo review, it held that the defendant’s sentence did not constitute the functional equivalent of LWOP, as he was eligible for youthful offender parole under section 3051 at age 41. The court determined that section 1170, subdivision (d)(1) only applies to explicit LWOP sentences for juveniles and does not violate equal protection by excluding those sentenced to lengthy indeterminate terms. It affirmed the trial court’s denial of the petition. View "People v. Cortez" on Justia Law

The defendant was convicted after he broke into a high school barn at night and killed a goat and a pig owned by students participating in an agricultural program. Surveillance footage showed someone entering the barn, carrying an axe, and later leaving with a wheelbarrow containing the dead pig. The next day, the deceased goat was found in the barn and the pig’s carcass was discovered hanging from a tree near the defendant’s living area at a nearby homeless encampment. The students who owned the animals testified to their emotional attachments and the distress caused by the incident.The Superior Court of San Benito County found the defendant guilty of two counts of animal cruelty, vandalism, burglary, unlawful possession of ammunition, possession of methamphetamine and drug paraphernalia, and two counts of misdemeanor child abuse for causing emotional harm to the student animal owners. The defendant was sentenced to an aggregate term of 11 years and six months in prison. On appeal, he argued that the trial court erred by not instructing the jury on the statutory exception permitting the killing of animals used for food, that his counsel was ineffective for not requesting such an instruction, and that the evidence was insufficient to support his convictions for animal cruelty related to the pig and for child abuse.The Court of Appeal of the State of California, Sixth Appellate District, affirmed the judgment. The court held that the Penal Code section allowing the “right to kill all animals used for food” does not apply to killing another person’s animal without the owner’s consent. The defendant’s conduct fell outside the statutory exception, and the evidence was sufficient to support all convictions. The court also found no instructional error or ineffective assistance of counsel. The judgment of the Superior Court was affirmed. View "People v. Madruga" on Justia Law

Following significant property damage due to a rainstorm in January 2023, several local government entities in Merced County, including the City of Merced and a school district, filed suit against the California Department of Fish and Wildlife (CDFW). They alleged that the CDFW’s restrictions on cleaning and maintaining waterways contributed to flooding that caused the damage. Subsequent to this initial complaint, other parties—including homeowners, businesses, and insurers—filed related actions against CDFW, the City, and the County. These cases were ultimately consolidated in Merced County Superior Court.After consolidation, CDFW became the sole nonresident defendant in the case. In late 2025, CDFW sought to transfer the venue out of Merced County, citing Code of Civil Procedure sections 394 and 397, which generally allow for venue changes to guard against local prejudice in actions involving local government plaintiffs and nonresident defendants. The plaintiffs opposed the motion, and the Superior Court of Merced County ruled that venue was proper in Merced County under Government Code section 955.3, which specifically governs actions brought by local agencies against the State of California. The court also found CDFW’s motion untimely.CDFW then petitioned the Court of Appeal of the State of California, Fifth Appellate District, for a writ of mandate to overturn the trial court’s denial of the motion to transfer venue. The Court of Appeal denied the petition, holding that Government Code section 955.3 expressly provides that such actions may be tried in the county where the local government plaintiff is situated, notwithstanding any other provision of law. The court concluded that section 955.3 supersedes section 394 and that the Attorney General’s ability to seek a venue change under section 397 is limited to a pre-answer motion, which was not made here. The stay previously issued was lifted, and costs were awarded to the real parties in interest. View "Dept. of Fish & Wildlife v. Super. Ct." on Justia Law

A.H., a minor and tribal citizen, was placed under the guardianship of his paternal grandmother following his parents’ inability to care for him. Over the years, multiple child welfare referrals were made due to Guardian’s failure to meet A.H.’s medical and educational needs. The Riverside County Department of Public Social Services (DPSS) initiated dependency proceedings, and the Soboba Band of Luiseno Indians (the Tribe) intervened because of concerns about Guardian’s mental health and her ability to care for A.H. The juvenile court ordered Guardian to undergo a psychological evaluation for case planning purposes after findings of inadequate care and missed medical appointments for A.H.In the Superior Court of Riverside County, the Tribe repeatedly requested access to Guardian’s psychological evaluation, arguing it was necessary for monitoring A.H.’s welfare and developing an appropriate case plan. Guardian objected, asserting privacy rights and noting the evaluation had not been filed with the court. The juvenile court denied the Tribe’s request, stating the evaluation was for case planning only and not for sharing with the Tribe. The Tribe then appealed, relying on state and federal law, including Welfare and Institutions Code section 827 and the Indian Child Welfare Act (ICWA).The Court of Appeal of the State of California, Fourth Appellate District, Division Two, reviewed the case. It held that the Tribe, as an intervening party and member of A.H.’s multidisciplinary personnel team, is presumptively authorized to access Guardian’s psychological evaluation under section 827, subdivisions (a)(1)(K) and (f). The court found that neither privacy laws nor the psychotherapist-patient privilege barred disclosure, given the evaluation was court-ordered and necessary for A.H.’s best interests. The court reversed the juvenile court’s denial and directed release of the evaluation to the Tribe. View "In re A.H." on Justia Law

Homeowners jointly owning a residence in Sherman Oaks purchased a comprehensive, all-risk homeowners insurance policy from an insurer. In 2019, construction on a neighboring upslope property paused before completion of a retaining wall. During a subsequent rainstorm, runoff was diverted by the incomplete wall, causing water, mud, and debris to damage the insured property, rendering it uninhabitable. The homeowners filed a claim with their insurer, which initially denied coverage based on an earth movement exclusion, then reopened the claim after the homeowners contested the denial. Although insurer representatives allegedly told the homeowners the loss was covered, the insurer ultimately denied the claim, citing multiple policy exclusions including inadequate construction, weather, and acts or decisions exclusions.The homeowners sued the insurer in the Superior Court of Los Angeles County for breach of contract, breach of the implied covenant of good faith and fair dealing, intentional infliction of emotional distress (IIED), and fraud based on the denial of their claim and representations made during the investigation. The insurer moved for summary judgment, arguing that policy exclusions precluded coverage as a matter of law and that the evidence did not support the fraud claim. The trial court concluded that the loss was subject to one or more policy exclusions, that estoppel could not create coverage where it did not exist, and that no triable issues remained as to the other causes of action. The court granted summary judgment in favor of the insurer.On appeal, the California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s judgment. The court held that all possible efficient proximate causes of the homeowners’ loss triggered exclusions in the policy, that estoppel could not create coverage, and that the evidence did not support the fraud or bad faith claims in the absence of coverage. View "Linsao v. First American Property & Casualty Ins. Co." on Justia Law

In 2025, the Santa Clara County Board of Supervisors faced significant federal funding cuts for healthcare and social services due to the passage of H.R. 1 by Congress. Anticipating a loss of over $1 billion in funding within five years, the Board declared an emergency and resolved to place a general sales tax measure (Measure A) on the ballot for a special election. The proposed tax was intended to offset the funding shortfall and maintain critical county services. The Board unanimously passed a resolution and urgency ordinance with detailed findings about the impacts of H.R. 1, the necessity for immediate action, and the risks of waiting for the next general election.Plaintiffs, county residents, filed a preelection complaint and petition for writ of mandate in the Santa Clara County Superior Court. They challenged the sufficiency of the emergency declaration under article XIII C, section 2 of the California Constitution and Proposition 218, and the format and impartiality of the ballot question and analysis. After expedited proceedings, the trial court found the emergency declaration valid, denied the writ petition on that ground, and directed modifications to some ballot language. Measure A was subsequently approved by voters.The Court of Appeal of the State of California, Sixth Appellate District, reviewed the case. It held that the “cases of emergency” clause in article XIII C, section 2 should be interpreted according to its ordinary meaning, permitting local governments to declare emergencies broadly when unforeseen circumstances require immediate action. The court found the Board’s emergency declaration reasonable and supported by legislative findings. Any error in the trial court’s evidentiary rulings was not prejudicial. The court declined to review the ballot language and impartial analysis issues as moot and not of broad public interest. The order denying the writ of mandate and judgment was affirmed. View "Holtz v. Moreles" on Justia Law

Two individuals applied for employment with a public school district in Los Angeles. One applicant had a prior misdemeanor conviction for battery, and the other for misdemeanor grand theft; both convictions had been expunged under California’s statutory procedure. Despite the expungements, the school district rejected both applicants, asserting that its duty to protect students required it to consider nearly any criminal conviction, regardless of expungement.Each applicant brought a separate lawsuit in the Superior Court of Los Angeles County. The trial courts, after considering motions for summary judgment, ruled in favor of the applicants. The courts found that the district had violated California Labor Code section 432.7 (the “Nondisclosure Statute”) by inquiring into and utilizing the expunged misdemeanor convictions as a basis for denying employment. The district appealed, and the cases were consolidated before the reviewing court.The California Court of Appeal, Second Appellate District, Division Eight, undertook an independent review of the relevant statutes. The court determined that the basic prohibition of Labor Code section 432.7 barred the district from asking about or using expunged convictions, and that none of the statutory exceptions relied on by the district applied. Specifically, the court found that no law required the district to seek or act upon the types of expunged misdemeanor convictions at issue. The court rejected the district’s arguments that it was entitled to broader exceptions, explaining that the statutory text and legislative history supported a narrow reading of the exceptions. The Court of Appeal affirmed the judgments in favor of the applicants, holding that the district’s actions violated the Nondisclosure Statute and awarding costs to the respondents. View "A.S. v. Los Angeles Unified School Dist." on Justia Law

The case involved a personal injury claim filed by the plaintiff against the defendants in Los Angeles County Superior Court. The main issue was whether the action was "brought to trial" within the statutory period required by California law, which mandates dismissal if a civil case is not brought to trial within five years (plus a COVID-19 emergency extension). As the deadline approached, several panels of prospective jurors were assembled and sworn in by the trial court, and the court conducted hardship excusals. However, the parties did not begin their voir dire examination of the sworn juror panels before the deadline expired.The Superior Court of Los Angeles County dismissed the action with prejudice under Code of Civil Procedure section 583.360, concluding the matter was not "brought to trial" by the deadline. The trial court reasoned that jury selection had not sufficiently commenced because the parties had not yet started their voir dire examination of the juror panels. The plaintiff appealed this dismissal.The California Court of Appeal, Second Appellate District, Division One, reviewed the case. The appellate court held that, consistent with Stueve v. Nemer, a civil action is "brought to trial" when a panel of prospective jurors assembles in the courtroom for voir dire and is sworn in accordance with Code of Civil Procedure section 232, subdivision (a). The court determined that the action was timely "brought to trial" on the date the panels were sworn, regardless of whether the parties' examination of the jurors had begun. The court reversed the judgment of dismissal, finding it was error to dismiss the case since the statutory requirements were met when the jury panels were assembled and sworn before the deadline. The plaintiff was awarded costs on appeal. View "Wilson v. Johnson" on Justia Law

Owners of residential property in Indian Wells, California, challenged a city ordinance that placed a 29-night minimum stay requirement on short-term rentals (STRs), effectively banning them. In response to property owners in common interest developments (CIDs) who wanted to permit STRs, the city enacted an ordinance allowing CIDs to vote to opt out of the minimum stay requirement, provided certain conditions were met. The plaintiffs, who owned property in a CID, sought a permit to operate an STR after their CID certified an opt-out vote, but the city denied the permit. The plaintiffs argued the opt-out procedure conflicted with California Civil Code section 4740, part of the Davis-Stirling Common Interest Development Act, which protects owners from prohibitions on rentals adopted after they acquire title. They also asserted the city had unconstitutionally delegated legislative authority to private parties.The Superior Court of Riverside County found in favor of the plaintiffs, concluding that the city’s opt-out procedure was preempted by section 4740 and conflicted with statutory voting requirements for amending CID governing documents. The trial court ruled the city had a duty to issue an STR permit and awarded attorney fees to the plaintiffs. The city appealed, arguing that section 4740 was not implicated and the delegation was permissible.The Court of Appeal of the State of California, Fourth Appellate District, Division Two, reviewed the case. It held that the city’s opt-out provision was not preempted by section 4740, as a vote to opt out did not amend CID governing documents or prohibit rentals, and compliance with both laws was possible. The court further held that the delegation of authority to CID members was constitutional and did not violate due process. It also determined the city had not acted arbitrarily or capriciously in enacting the ordinance. The court reversed the judgment and the postjudgment award of attorney fees, ordering costs in favor of the city. View "Parsons v. City of Indian Wells" on Justia Law