Justia California Court of Appeals Opinion Summaries

The case concerns a shooting in a Los Angeles park involving rival gangs. Jesus Guzman, associated with Lawndale 13, was accused of killing David Najera, a member of Muertos 13, after an altercation between the gangs the previous night at a hookah bar. The prosecution argued that Guzman and his gang sought revenge for the prior incident, resulting in Najera’s death and the attempted murder of another Muertos member, Portillo. Evidence against Guzman included eyewitness descriptions, video footage, and information from a confidential reliable informant who identified Guzman by his gang moniker and linked his social media account to the crime.The Superior Court of Los Angeles County presided over Guzman’s trial. The jury convicted Guzman of second-degree murder and premeditated attempted murder, finding that a principal—but not Guzman himself—personally and intentionally discharged a firearm causing death. Guzman was sentenced to 22 years to life. The central issue on appeal was Guzman’s challenge to the police search of his social media account, arguing that the affidavit supporting the search warrant lacked sufficient probable cause and did not establish a link between his account and the crime.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the evidence obtained from Guzman’s social media account was properly admitted because, at a minimum, the good-faith exception to the exclusionary rule applied. The affidavit supporting the search warrant provided a reasonable basis for police to believe the warrant was valid, and it was reasonable to infer that the social media account would contain relevant evidence. The judgment of the trial court was affirmed. View "People v. Guzman" on Justia Law

The appellants, a family involved in the ballet community, brought a lawsuit against a former student who had publicly accused the family patriarch, her former ballet teacher, of sexual abuse committed in the 1970s and 1980s. The accusations were aired on a podcast, where the defendant discussed her own experiences and those of other named victims, alleging recurring abuse and a coverup at the dance studio. She also made disparaging remarks about the teacher’s wife and son, who had also been active in the studio. The teacher had previously been criminally charged with abuse of another student in the 1980s but was acquitted after trial.The Superior Court of Orange County reviewed the defendant’s anti-SLAPP motion, which argued that the plaintiffs’ slander claims arose from protected activity—statements made in a public forum on matters of public interest—and lacked merit. The trial court found that, while some statements attributed to the defendant were not accurately alleged, those that did accuse the teacher of criminal conduct were privileged under section 47.1 of the California Civil Code, which provides a qualified privilege for sexual assault survivors speaking out without malice. The trial court also found that statements about the wife and son did not accuse them of crimes and therefore did not constitute slander per se.The Court of Appeal of the State of California, Fourth Appellate District, Division Three, affirmed the trial court’s order granting the anti-SLAPP motion. The appellate court held that the defendant’s statements were protected as they were made in connection with an issue of public interest, and plaintiffs did not establish a probability of prevailing. The court interpreted section 47.1 broadly to cover statements about other alleged victims and clarified that malice requires wrongful intent beyond emotional response. The order striking the complaint was affirmed, and the matter remanded for determination of attorney fees. View "Sellars v. Rose" on Justia Law

Apria Healthcare provides home healthcare products and services, employing delivery drivers through third-party agencies and licensed vocational nurses directly. Travis Smith and Uriel Arauz, both former employees, commenced a class action against Apria in Sutter County Superior Court alleging wage and hour violations on behalf of similarly situated employees. Proposed interveners Angela Tisdale and Terrance Pratt are former delivery drivers and named plaintiffs in a separate, related federal action against Apria for similar wage and hour claims, covering delivery drivers hired after the class certification date in another Los Angeles County action.The Sutter County Superior Court preliminarily approved a settlement in the Smith action, which conditionally certified a class and found the settlement fair. Tisdale and Pratt, concerned about a collusive “reverse auction” settlement that might undermine the rights of putative class members in their federal action, filed an ex parte application to intervene in the Smith action after the court’s preliminary approval and class notice. Their application was supported by evidence of their early awareness and concern over the settlement process, but was filed several months after those concerns were first raised.The Court of Appeal of the State of California, Third Appellate District, reviewed the trial court’s denial of the intervention application. The appellate court held that Tisdale and Pratt’s application was untimely, noting that they knew or should have known of risks to their interests well before filing, and their delay prejudiced the settlement process and the original parties. The court affirmed the trial court’s order denying intervention, concluding that the untimeliness of the application defeated both mandatory and permissive intervention. Respondents were awarded costs on appeal. View "Smith v. Apria Healthcare" on Justia Law

The defendant was convicted by a jury of ten counts of lewd and lascivious acts on a child under the age of fourteen and sentenced to sixty years in prison. In 2025, he was diagnosed with metastatic kidney cancer and experienced severe health complications. The California Department of Corrections and Rehabilitation (CDCR) recommended recall of his sentence and compassionate release under Penal Code section 1172.2, initially proposing that he reside with his sister. However, parole restrictions prevented this plan, and CDCR later suggested transitional housing, but details about this arrangement and subsequent medical care were lacking.The Sacramento County Superior Court reviewed CDCR’s compassionate release recommendation. At a hearing, testimony revealed that the defendant’s health had recently improved, and the original postrelease plan with his sister was not viable. The trial court found that CDCR had not submitted an adequate postrelease plan, as required by section 1172.2, subdivision (h), and denied the recommendation. The court did not make a finding on whether the defendant’s illness qualified for the statutory presumption favoring recall and resentencing and stated it need not decide whether the defendant posed an unreasonable risk if released.On appeal, the California Court of Appeal, Third Appellate District, considered whether the trial court erred by denying compassionate release based solely on the lack of a qualifying postrelease plan. The appellate court held that section 1172.2 expressly requires CDCR to include a postrelease plan with its recommendation and that the trial court’s denial on these grounds complied with the statute’s plain language. The appellate court further found that substantial evidence supported the trial court’s determination and affirmed the order. View "People v. Chism" on Justia Law

J.O. has been under a conservatorship since 2016, with the San Joaquin County Public Conservator serving as his conservator and represented by County Counsel. In December 2023, Judge Guy Castillo began presiding over most mental health cases in the San Joaquin County Superior Court. Starting in May 2024, County Counsel adopted a practice of filing “blanket” motions under Code of Civil Procedure section 170.6 to disqualify Judge Guy Castillo from all cases involving the Public Conservator. On July 10, 2024, County Counsel filed both a petition to extend J.O.’s conservatorship and a section 170.6 motion; the motion was initially denied as premature. J.O. subsequently sought to have the Public Conservator removed and his sister appointed. County Counsel filed another section 170.6 motion, which was granted, removing Judge Guy Castillo from J.O.’s case. J.O. objected, arguing the blanket challenges were improper and aimed at forcing Judge Guy Castillo’s reassignment following her admonishment of County Counsel’s attorney; Judge Guy Castillo was later reassigned.The San Joaquin County Superior Court overruled J.O.’s objection, relying on Solberg v. Superior Court, which permitted blanket section 170.6 challenges. The California Court of Appeal denied writ relief. The Supreme Court of California granted review, overruling Solberg in part, and held that blanket abuses of section 170.6 could unconstitutionally interfere with core judicial functions and are subject to as-applied separation-of-powers challenges. The Supreme Court established a burden-shifting procedure to evaluate whether such challenges are made in bad faith and remanded the matter to the Court of Appeal for further proceedings.The Court of Appeal of the State of California, Third Appellate District, determined the case was not moot and issued a writ directing the Superior Court to vacate its order granting County Counsel’s section 170.6 motion. The court ordered a hearing consistent with the Supreme Court’s procedure to determine whether County Counsel’s motion was made in bad faith. View "J.O. v. Super. Ct." on Justia Law

The defendant was convicted of arson in January 2022 and sentenced to two years in prison. In February 2025, a petition was filed alleging that the defendant had violated Vehicle Code section 14601.2, subdivision (a), but the petition did not specify what was being revoked. At a hearing, the court described the matter as a parole issue, summarily revoked the defendant’s parole supervision, and declined to release him from custody. The defendant was later allowed to represent himself and denied the parole violation, though he admitted to the underlying misdemeanor. At a subsequent hearing, after the defendant’s conviction for the misdemeanor, the court found him in violation of parole “by operation of law,” revoked and reinstated parole, and imposed a jail sentence.The Superior Court of Sonoma County presided over these proceedings. The defendant appealed, arguing that there was insufficient evidence to support the finding that he was on parole at the time of the alleged violation. The prosecution did not introduce evidence at the hearing to show that the defendant was actually on parole when the alleged violation occurred. The prosecution argued on appeal that references to the proceedings as parole revocation proceedings, and the defendant’s acknowledgment of the hearing, were sufficient.The California Court of Appeal, First Appellate District, Division Five, reviewed the matter. It held that to establish a parole violation, the prosecution must prove, by a preponderance of the evidence, that the defendant was on parole at the time of the alleged violation, even if the defendant does not specifically raise the issue before the hearing. Because the prosecution failed to present any evidence of parole status at the time of the violation, the Court of Appeal reversed the order revoking and reinstating parole and imposing jail time. View "People v. Fuller" on Justia Law

Several school districts brought lawsuits against major social media companies, alleging that the companies’ platforms caused a mental health crisis among students. The districts claimed that these harms disrupted their educational missions, required additional spending on mental health and disciplinary services, and led to property vandalism, particularly through social media “challenges.” The complaints described features of the platforms as intentionally designed to maximize youth engagement and addictive use, which allegedly resulted in widespread student mental health issues and direct costs to the schools.The Superior Court of Los Angeles County consolidated the cases for demurrer briefing and ruled on complaints from school districts in California, Florida, Washington, and Rhode Island. The districts asserted claims for negligence and public nuisance under the laws of their respective states. In response, the social media defendants argued that the districts’ injuries were derivative of student harms, not cognizable under the legal theories pled, and that the claims were barred by doctrines such as the economic loss rule and federal immunity. The trial court sustained the defendants’ demurrer in its entirety, finding no legal basis for the claims and denying leave to amend, except for Vancouver School District’s challenge regarding leave to amend.On appeal, the Court of Appeal of the State of California, Second Appellate District, Division Two, reviewed the trial court’s rulings de novo. The court affirmed the judgment, holding that the economic loss rule barred recovery for the school districts’ purely financial harms in negligence and that the alleged disruptions to educational missions and property were either not cognizable or shielded by federal immunity under Section 230. The court also found the public nuisance claims insufficiently pled under the respective state laws, especially lacking allegations that an entire community’s health was affected equally. Accordingly, the appellate court affirmed the dismissal of all claims. View "Social Media Cases" on Justia Law

Two individuals who use a rideshare company’s smartphone application alleged that the company engaged in a deceptive pricing scheme. They claimed the company publicly advertises that the price displayed to consumers before a ride is “the price [the consumer will] pay at the end of the ride.” However, plaintiffs asserted that this displayed price is only an estimate and that the company frequently charges more than the advertised price. Plaintiffs sought an injunction to prevent the company from advertising prices lower than what consumers actually pay and requested restitution or disgorgement of any excess amounts paid.The Superior Court of California, City and County of San Francisco, reviewed the company’s motion to compel arbitration under its user agreement. That agreement required arbitration of individual claims and included a class action waiver, but also stated that if the waiver was unenforceable, claims subject to the waiver would proceed in court. Plaintiffs argued that the waiver violated California law (as interpreted in McGill v. Citibank, N.A.), since it barred them from seeking public injunctive relief. The trial court agreed, finding that the relief sought was public in nature and that the agreement did not require severance of plaintiffs’ requests for individual relief into arbitration.The California Court of Appeal, First Appellate District, Division Five, affirmed the trial court’s order. The appellate court held that plaintiffs sought public injunctive relief because their requested injunction would benefit all potential users of the platform, not simply themselves or a discrete group. The court further held that the arbitration agreement was ambiguous regarding whether only the injunctive request should proceed in court or whether all relief should. Applying the contra proferentem rule, the court construed the ambiguity against the company and concluded the entire action must remain in court. The order denying arbitration was affirmed. View "Bogguess v. Uber Technologies" on Justia Law

The defendant was convicted in 2011 of first degree murder, multiple sexual offenses, and related crimes stemming from incidents in July 2008. A jury found him guilty and determined that he personally and intentionally discharged a firearm causing great bodily injury or death. Additional findings included three prior prison terms. He was originally sentenced to 78 years to life in prison. Following a change in the law eliminating one-year sentence enhancements for prior prison terms, the defendant petitioned for resentencing. The trial court resentenced him to 77 years to life, removing the prior prison term enhancements but retaining all other aspects of the sentence, including the gun enhancement.After the resentencing, the defendant argued that the trial court should have dismissed the gun enhancement under Penal Code section 1385(c), specifically referencing the Racial Justice Act (RJA). He contended that applying the enhancement would result in a discriminatory racial impact. In the Alameda County Superior Court, the trial judge found that dismissing the enhancement would endanger public safety and that none of the mitigating factors, including those based on racial bias, were established. The defendant’s evidence of racial bias was based on a statistical report and a claim of bias by the original sentencing judge, but the trial court found these claims insufficient under the RJA.On appeal, the California Court of Appeal, First Appellate District, Division Three, held that the defendant failed to present evidence meeting the RJA’s requirements. Specifically, he did not show that he received a longer sentence than similarly situated individuals of other races in the same county, nor did he provide comparator cases or adequate statistical evidence. The appellate court affirmed that to trigger section 1385(c)(2)(A), a defendant must satisfy the RJA’s standard, which the defendant did not. Accordingly, the judgment was affirmed. View "People v. Savoy" on Justia Law

A consumer used an online platform to book short-term accommodations, paying through the platform’s payment processor. The payment processor, a subsidiary of the platform, collected, held, and later disbursed guest payments to hosts after the guest’s check-in. The platform’s terms specified that the payment processor acted as a collection agent for the host and retained any interest earned on guest funds held before disbursement. The platform did not claim to act as an escrow agent or company and explicitly disclaimed any broader agency relationship with users.The consumer sued in the Superior Court of San Francisco City and County, alleging that the defendants unlawfully operated as escrow agents without complying with California’s Escrow Law and engaged in unfair business practices, in violation of the state’s unfair competition law (UCL). The complaint also included claims under the Consumers Legal Remedies Act and for unjust enrichment. The trial court sustained the defendants’ demurrer to the operative complaint without leave to amend, finding that the plaintiff failed to allege facts sufficient to establish that the defendants acted as escrow holders or conducted escrow transactions as defined by law. Judgment was entered for the defendants.On appeal, the Court of Appeal of the State of California, First Appellate District, Division Three, reviewed the trial court’s order de novo. The appellate court held that the plaintiff’s complaint did not allege facts showing that the defendants acted as escrow agents under California law, as there was no indication that any party expected or intended an escrow relationship, or that the transactions had the irrevocability and fiduciary duties characteristic of escrow arrangements. The court affirmed the trial court’s judgment, holding that the complaint failed to state a cause of action under the UCL for unlawful or unfair business practices, and that amendment would not cure the defects. View "Edson v. Airbnb Payments, Inc." on Justia Law