Justia California Court of Appeals Opinion Summaries

A patient at Coalinga State Hospital challenged a policy and regulation that permitted hospital staff to x-ray and open all incoming mail outside the presence of patients. He argued that this policy conflicted with certain provisions of the Welfare and Institutions Code and regulations, which he claimed guaranteed patients the right to receive unopened correspondence. The patient, who is civilly committed as a sexually violent predator (SVP), alleged his mail had been opened and contents withheld without his permission, and he sought a judicial declaration concerning his rights under state law.The Superior Court of Fresno County sustained a demurrer filed by the Department of State Hospitals Coalinga and its Hospital Police Chief. The court concluded that the statutory rights cited by the patient, specifically those in Welfare and Institutions Code section 5325, applied only to individuals committed under the Lanterman-Petris-Short (LPS) Act, not to SVPs. The court also found that the regulation authorizing inspection of mail for non-LPS patients did not conflict with the statute, as they applied to different populations. The patient's amended petition was dismissed without leave to amend.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the lower court’s judgment. The appellate court held that Welfare and Institutions Code section 5325 confers mail rights only to LPS patients and that sexually violent predators, as non-LPS patients, are governed by separate regulations under title 9, section 884, which specifically allows for the inspection of their mail. The court found no irreconcilable conflict between the statute and the regulation and concluded that the Department of State Hospitals has authority to adopt regulations necessary for institutional security. The judgment dismissing the patient’s amended petition was affirmed. View "Seeboth v. State Dept. of State Hospitals" on Justia Law

A longtime high school teacher working for a public school district declined to comply with a COVID-19 vaccine mandate based on his sincerely held religious beliefs. After he requested a religious exemption, the district granted the exemption but placed him on an indefinite unpaid leave of absence, stating that no other accommodation would avoid an undue burden given his direct contact with students and staff. The district denied his requests for alternative accommodations, such as masking, weekly testing, or remote teaching, citing operational and safety concerns during the pandemic. The teacher remained on unpaid leave for approximately a year before finding employment at another school without a vaccine mandate. He later resigned from the original district.The teacher filed suit in the Superior Court of Los Angeles County, asserting three claims under the Fair Employment and Housing Act (FEHA): religious discrimination, failure to prevent discrimination, and retaliation. The district moved for summary judgment, arguing that placing the teacher on unpaid leave was a reasonable accommodation and did not constitute discrimination or retaliation. The court found that the district had met its burden to show that unpaid leave was the only reasonable accommodation available for unvaccinated teachers without causing undue hardship and granted summary judgment for the district on all claims.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that, under FEHA, unpaid leave can be a reasonable accommodation for an employee's religious beliefs if no other accommodation avoids undue hardship to the employer. The court found that the district had explored accommodations and reasonably determined that alternative measures would pose an undue burden. The appellate court affirmed the trial court’s judgment in favor of the district. Costs were awarded to the district. View "Smith v. Burbank Unified School Dist." on Justia Law

The plaintiffs, including a residents association, an affordable housing advocacy group, and several former residents, challenged actions taken by the City of Stanton over approximately 17 years regarding a low-income neighborhood comprised of fourplexes. The City gradually acquired most of the properties using redevelopment funds, allowed units to deteriorate and become uninhabitable, left many vacant units unrented, and demolished several fourplexes, which effectively removed substantial low-income housing from the market. Despite plans for redevelopment and affordable housing construction, little progress was made, and the City failed to replace demolished units or update relocation plans for displaced residents.The case was initially reviewed by the Superior Court of San Diego County. Plaintiffs filed a verified petition for writ of mandate and complaint for declaratory and injunctive relief, asserting that the City violated statutory obligations by not adopting a replacement housing plan, failing to provide replacement housing, and neglecting to adopt or update a relocation plan. The defendants demurred, claiming the petition was uncertain and insufficiently pled. The trial court sustained the demurrer without leave to amend, citing ambiguity and failure to identify actions triggering statutory duties.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court found that the petition was not uncertain and that plaintiffs had alleged sufficient facts to state causes of action under the Community Redevelopment Law and the California Relocation Assistance Act. Specifically, the court held that plaintiffs adequately alleged violations for not adopting a replacement housing plan, not providing replacement housing within statutory periods, and not maintaining a compliant relocation plan. The judgment was reversed, and the case was remanded with instructions to overrule the demurrer. View "Tina-Pacific Residents Assn. v. City of Stanton" on Justia Law

A criminal defendant was charged with multiple counts of theft. At arraignment, his attorney and the prosecution stipulated to setting bail at $50,000, with the requirement that, upon posting bail, the defendant would be placed on GPS monitoring through the bail bond company. The trial court adopted this agreement, specifying that GPS monitoring was required and at the defendant’s expense. United States Fire Insurance Company, through its agent, posted the bail bond, but it appears that GPS monitoring was not arranged. The defendant was released, later failed to appear in court, and the court forfeited the bond and issued a bench warrant.After forfeiture, the Superior Court of Orange County entered summary judgment against the surety for $50,000. United States Fire Insurance Company moved to set aside the judgment, arguing that the defendant’s release without GPS monitoring constituted a unilateral change to the bail contract, voiding the bond. The trial court denied the motion, finding that arranging GPS monitoring was the responsibility of the bail bond company, and not the sheriff’s department or jail, and that there was no change to the terms of the bond after its execution.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the denial of the motion to set aside summary judgment under the abuse of discretion standard. The appellate court held that substantial evidence supported the trial court’s finding that the bail bond company was responsible for ensuring GPS monitoring as a condition of release. The court distinguished this case from People v. Lexington National Ins. Corp., concluding there was no unilateral change to the bond terms. The appellate court affirmed the trial court’s order, holding that the trial court did not abuse its discretion, and awarded costs on appeal to the respondent. View "People v. U.S. Fire Ins. Co." on Justia Law

A licensed psychologist faced disciplinary action after being convicted in 2018 of insurance fraud related to a workers’ compensation claim. The Board of Psychology issued an accusation in 2019 based on the conviction and also alleged dishonesty in her 2007 license application for failing to disclose a 1984 conviction. Following a two-day evidentiary hearing in 2020, the Board found cause to discipline her solely for the insurance fraud conviction, dismissed the charge related to the 1984 conviction, and placed her on probation for five years with various conditions, holding the probation in abeyance during periods when she was not practicing in California.After moving out of state and returning, the psychologist petitioned the Board in 2023 for early termination of her probation. The Board held an evidentiary hearing in 2024, found she failed to provide clear and convincing evidence of rehabilitation—citing her lack of insight and responsibility for the insurance fraud conviction—and denied the petition. The Board noted her probation had been tolled due to her absence and non-practice. She then sought judicial review of both the 2021 probation decision and the 2024 denial of early termination in the Superior Court of Sacramento County.The Superior Court denied her petition, finding the challenge to the 2021 decision untimely and concluding the 2024 denial was supported by substantial evidence. On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. The Court held that the trial court properly applied the substantial evidence test to review the Board’s denial of early termination, as this was analogous to review of an agency’s decision on reinstatement rather than discipline. The Court found the Board did not abuse its discretion and rejected arguments regarding procedural unfairness and relevance of the 1984 conviction. The judgment was affirmed. View "Bombardini v. Board of Psychology" on Justia Law

Three adjacent residential parcels in Los Gatos were subject to a lot line adjustment application in 2023, submitted by the owners’ architect. One parcel had an existing house, while two were unimproved and nonconforming with zoning requirements. The adjustment sought to resolve nonconformities, including minimum lot size and street frontage. As a condition, the Town required an offer of dedication for a cul-de-sac easement to provide new access and satisfy frontage requirements. The Town accepted this dedication, resulting in a mapped cul-de-sac extension.The Town’s development review commission approved the adjustment, and subsequent appeals by an adjacent homeowner, Alison Steer, were denied by the planning commission and Town Council. Steer argued the approval was discretionary, not ministerial, due to the Town’s acceptance of the dedication, which she claimed triggered the need for environmental review under the California Environmental Quality Act (CEQA). The Town filed a notice of exemption, stating the approval was ministerial and thus exempt from CEQA. Steer then filed a petition for writ of mandate in the Santa Clara County Superior Court, alleging CEQA violations. The trial court denied the petition, reasoning that the dedication was for zoning compliance and the Town lacked discretion to refuse it, making the approval ministerial.The Court of Appeal of the State of California, Sixth Appellate District, reviewed the case. It held that while lot line adjustments are typically ministerial, this approval included a discretionary element—the Town’s acceptance of the property dedication for the cul-de-sac. The court found that the Town had discretion to accept, modify, or reject the dedication, which made the project discretionary for CEQA purposes. Accordingly, the court reversed the trial court’s judgment and remanded with instructions to grant the petition for writ of mandate, concluding the Town violated CEQA by relying on the ministerial exemption. View "Steer v. Town of Los Gatos" on Justia Law

The plaintiff was employed as a wealth advisor for a bank and alleged that a coworker, who was an investment strategist, sexually harassed and assaulted her during a business trip. The alleged harasser, though considered influential and holding a senior title, was not designated as a supervisor of the plaintiff and had no authority over her employment, such as hiring, firing, or evaluating performance. However, he did supervise support staff known as associates. After the incident, the plaintiff reported the alleged harassment and assault to the bank, her supervisor, and law enforcement. The bank conducted an internal investigation and concluded that her allegations regarding the sexual assault and harassment were unsubstantiated, but found that coworkers had used her phone without consent and violated other company policies.The plaintiff filed suit in the Superior Court of Los Angeles County against the bank and several individuals, asserting a cause of action for sexual harassment under the Fair Employment and Housing Act (FEHA). The bank moved for summary judgment, arguing it could not be strictly liable because the alleged harasser was not the plaintiff’s supervisor and, alternatively, that it was not negligent because it had responded promptly and appropriately to her complaints. The trial court granted summary judgment for the bank, finding strict liability did not apply and that the bank was not liable under the negligence standard.The Court of Appeal of the State of California, Second Appellate District, Division Four, reviewed the case. The main holding was that, under FEHA, strict liability does not apply to an employer for sexual harassment committed by a supervisor who does not supervise the plaintiff, even if the alleged harasser supervises other employees. The court affirmed the judgment, declining to extend strict liability in such circumstances and also determined the plaintiff forfeited her negligence and ratification arguments on appeal. View "Doe v. Wells Fargo Bank, N.A." on Justia Law

A man was employed by a company and took parental leave in early 2023. Upon his return, he alleged that the company retaliated against him for taking leave, denied him a comparable position, interfered with his right to additional leave, and ultimately terminated him. He also claimed that a superior repeatedly questioned him about his remaining leave. In February 2024, he filed a lawsuit in the Superior Court of Los Angeles County, asserting claims related to parental leave rights, whistleblower retaliation, wrongful termination, and unfair competition. Notably, he did not initially assert a claim for sex-based harassment, though he was aware of facts that could support such a claim.When the company moved to compel arbitration based on an employment agreement, the man opposed the motion, focusing solely on the validity of the arbitration agreement and not raising the possibility of a sexual harassment claim or the applicability of the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA). The Superior Court compelled arbitration. Subsequently, the man added a sexual harassment claim in arbitration and then filed a second lawsuit in Superior Court, seeking to invalidate the arbitration agreement under the EFAA and consolidate the two suits.The Superior Court consolidated the actions, invalidated the arbitration agreement based on the EFAA, and denied the company’s renewed effort to compel arbitration. The company appealed.The California Court of Appeal, Second Appellate District, Division Eight, held that the plaintiff waived the protections of the EFAA by knowingly withholding his sexual harassment claim and the EFAA argument during the initial litigation and opposition to the motion to compel arbitration. The court reversed the Superior Court’s orders, directed that arbitration be compelled, and awarded appellate costs to the company. View "Chin v. DoorDash, Inc." on Justia Law

In 2006, the defendant acted as a lookout during an attempted robbery committed by his associate, who shot and killed an off-duty Los Angeles County Sheriff’s deputy. The defendant was charged with first degree murder and attempted robbery. At trial in the Superior Court of Los Angeles County, the jury was instructed on the felony-murder rule and convicted him on both counts. The court sentenced him to 29 years to life, later reduced to 26 years to life after the sentence for attempted robbery was stayed.Years later, following legislative changes to the felony-murder rule under Senate Bill No. 1437, the defendant petitioned for resentencing under Penal Code section 1172.6, which allows relief for certain felony-murder convictions. However, the statute excludes defendants if the victim was a peace officer killed in the course of duty and the defendant knew or should have known the victim’s status. After a series of appeals, the California Court of Appeal, Second Appellate District, directed the trial court to hold evidentiary hearings to determine whether the slain deputy was acting as a peace officer within the meaning of the statute at the time of her death.After further hearings, the trial court found that the deputy was not a “modified” custodial deputy with limited authority but rather a fully trained deputy sheriff under section 830.1, subdivision (a), who retained peace officer authority, including while off duty. The California Court of Appeal, Second Appellate District, Division One, affirmed this finding, holding that section 830.1, subdivision (c) applies only to deputies hired, trained, and utilized exclusively or initially as modified custodial deputies, not to regular deputies assigned to custodial duties. Substantial evidence supported that the victim was a regular deputy with full peace officer authority. Therefore, the defendant was ineligible for resentencing relief under section 1172.6, and the trial court’s order denying the petition was affirmed. View "People v. Flint" on Justia Law

A teacher was employed by a public school district for three consecutive years, beginning in August 2019. At the time of hiring, she was told her position was created due to increased enrollment and that she would initially be classified as a temporary employee, with the expectation of later becoming probationary and eventually permanent. Throughout her three years, she consistently received temporary contracts, with district administrators repeatedly explaining this was due to COVID-19-related uncertainties and that all similarly situated teachers were also classified as temporary. After her third year, the district informed her that her contract would not be renewed, citing budget constraints and low enrollment.She filed a petition for a writ of mandate in the Superior Court of San Bernardino County, seeking reinstatement as a permanent employee, claiming she had been misclassified as temporary. The district defended its actions by arguing she was temporarily filling a position made available by two other teachers who were job-sharing, which it contended qualified as "leave" under Education Code section 44920. The superior court credited testimony that the teacher was hired due to increased enrollment, not as a replacement for the job-sharing arrangement, but nonetheless concluded she could be classified as temporary because the total number of temporary teachers did not exceed the number of teachers on leave (including those in job-share). The court denied her petition, and also indicated that laches would bar her claim, though it deemed the issue moot based on its primary ruling.The California Court of Appeal, Fourth Appellate District, Division One, reversed. It held that a voluntary job-sharing arrangement does not constitute a "leave of absence" under Education Code section 44920 and therefore does not justify classifying a replacement teacher as temporary. Since the teacher was not properly classified as temporary, she became probationary by default and, after two years, a permanent employee by operation of law. The court ordered her reinstatement with the appropriate seniority date and remanded for determination of lost compensation, also rejecting the district’s laches defense. View "Washington v. Alta Loma School Dist." on Justia Law