Justia California Court of Appeals Opinion Summaries

An employee of an independent contractor was injured after falling through a skylight while working on equipment located on the roof of a warehouse. The warehouse owner had leased roof space and related access to a tenant (Verizon) expressly for the installation and maintenance of communications equipment. The tenant, in turn, hired a general contractor to perform work at the site, who then sent the injured employee to perform the task. The area where the accident occurred was not part of the leased roof section, but the employee accessed it while attempting to complete his assignment. It was undisputed that the general contractor, not the warehouse owner, was responsible for the means, methods, and safety of the work.After the accident, the injured worker brought a lawsuit against both the tenant and the warehouse owner in the Superior Court of Alameda County, asserting claims of negligence and premises liability. The warehouse owner moved for summary judgment, arguing that under the Privette doctrine, which generally shields those who hire independent contractors from liability for workplace injuries, it was not liable. The trial court denied the motion, ruling that because the warehouse owner was a landlord and not the entity that directly hired the independent contractor, the Privette doctrine did not apply. Summary judgment was granted in favor of the tenant on Privette grounds, and the plaintiff did not appeal that ruling.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court held that the Privette doctrine protects not only the party that directly hires an independent contractor but also applies to others in the “chain of delegation,” such as non-hiring landlords whose lease agreements contemplate the use of independent contractors for contracted work. The court directed the trial court to vacate its denial of summary judgment and to enter judgment for the warehouse owner, holding that the Privette doctrine barred the plaintiff’s claims. View "Schurman Family Company TIC v. Super. Ct." on Justia Law

A dispute arose from a vehicle lease agreement, leading Ari Law P.C. to file a Second Amended Complaint in May 2024 against BMW Financial Services NA, LLC and other defendants. Ari Law alleged breach of contract, breach of express and implied warranties, unfair business practices, fraud, and violations of the Rosenthal Fair Debt Collection Practices Act. The San Mateo County Superior Court sustained BMW FS’s demurrer as to counts 2, 3, and 6 (warranty claims and Rosenthal Act claim) without leave to amend. Despite this, Ari Law included these dismissed counts in a Third Amended Complaint filed in September 2024. BMW FS repeatedly requested Ari Law to withdraw the improper claims, but Ari Law refused. BMW FS then served Ari Law with a motion for sanctions under Code of Civil Procedure sections 128.5 and 128.7, initially noticing a hearing for January 17, 2025, and later re-serving and filing the motion with a hearing date of March 18, 2025.The trial court sustained BMW FS’s demurrer to the same counts without leave to amend, and after considering the sanctions motion, imposed monetary sanctions of $29,055 against Ari Law and its counsel. Ari Law challenged the sanctions order, arguing that the notice of motion did not comply with statutory requirements due to differing hearing dates and insufficient time for the safe harbor period. The trial court rejected these procedural objections, finding that Ari Law had adequate notice and opportunity to address the motion, and denied Ari Law’s motion for reconsideration.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. It held that the discrepancy in hearing dates between the served and filed notices did not invalidate the sanctions order, so long as the substance of the motion remained the same and the safe harbor provisions were strictly satisfied. The court affirmed the sanctions order, denied BMW FS’s request for sanctions on appeal, and awarded BMW FS costs. View "Ari Law v. Autonation.com" on Justia Law

A shareholder of a Delaware corporation with its principal place of business in San Francisco sought to inspect the company’s records under California Corporations Code sections 1600 and 1601. The shareholder, a California resident holding over 11% of the voting shares, requested access to various documents to evaluate his ownership interest and potential value, communicate with other shareholders, and investigate alleged mismanagement. The company denied the request, citing its status as a Delaware corporation and referencing a forum selection clause in its bylaws, which designated the Delaware Court of Chancery as the exclusive forum for internal affairs claims.Following the denial, the shareholder filed a petition for a writ of mandate in the San Francisco County Superior Court to compel inspection. Shortly thereafter, the company initiated a declaratory action in the Delaware Court of Chancery, seeking confirmation that Delaware law governed the shareholder’s inspection rights. The company then moved to stay the California proceedings, arguing the forum selection clause applied and was enforceable. The Superior Court granted the stay, finding that Delaware law governed interpretation of the clause, and that shareholder inspection rights constituted internal affairs under both Delaware and California law. The court further held that enforcing the clause did not violate California public policy, as Delaware law provided meaningful inspection rights.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. It agreed that the forum selection clause covered the inspection claim but held that enforcing the clause would violate California public policy. The court determined that California’s statutory inspection rights are unwaivable and more extensive than those provided under Delaware law. Because the company failed to show that Delaware law offered the same or greater rights, enforcement of the clause would impermissibly limit the shareholder’s statutory protections. The appellate court reversed the stay and remanded with instructions to deny the motion. View "Salamon v. Orchid Global" on Justia Law

A healthcare staffing company hired an employee as a travel nurse, requiring him to sign multiple agreements containing arbitration provisions with varying language. When the employee later accepted a temporary assignment at a hospital, he signed an additional agreement incorporating the employer’s most recent arbitration policy. After his assignment ended, the employee filed a class action lawsuit alleging wage and hour violations against the company.The company responded by filing a motion in the Superior Court of San Diego County to compel arbitration, relying on the arbitration provision from the employee handbook. The employee opposed, arguing that the handbook’s provision was superseded by the newer arbitration agreement incorporated into his most recent assignment. The court denied the motion, finding that the company had relied on the wrong agreement. The company then filed a second motion to compel arbitration, this time based on the updated agreement, but failed to provide the affidavit or explanation required by California Code of Civil Procedure section 1008 for renewed motions. The employee objected, contending that the second motion sought the same relief as the first and was subject to section 1008(b), which the company had not satisfied. The Superior Court agreed, ruled it lacked jurisdiction to consider the renewed motion, and denied it.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed whether the trial court properly applied section 1008(b) and whether the second motion was a renewed motion for the same relief. The appellate court held that the company’s second motion sought identical relief as the first—compelling arbitration of the same claims—regardless of which agreement formed the basis. Because the company failed to comply with section 1008(b), the trial court lacked jurisdiction, and the order denying the renewed motion was not appealable. Accordingly, the Court of Appeal dismissed the appeal. View "Hickenbottom v. Medical Solutions" on Justia Law

A California corporation that manufactures medical devices sought to connect two properties it owns, separated by a public street, into a single microgrid using its own private equipment. The microgrid would supplement its energy needs by drawing power from the local regulated utility when necessary. The company claimed it had obtained local approvals and that its microgrid complied with Public Utilities Code section 218, which defines when an entity is not considered a regulated "electrical corporation." However, Southern California Edison (SCE) declined to support the company’s plan, citing concerns about safety and operational control, and asserting that it had discretion to deny facility modifications or connections that could affect its distribution system.The California Public Utilities Commission (PUC) initiated a rulemaking process to develop a policy framework for microgrids, as mandated by Senate Bill No. 1339. In the fifth phase of this process, the PUC adopted tariffs for multi-property microgrids proposed by investor-owned utilities but declined to adopt the company’s proposed changes to SCE’s tariff rules. The PUC found that the company’s proposals could allow an unregulated entity to compel changes to, or control, regulated utility infrastructure, potentially compromising safety and reliability. The company’s application for rehearing was denied, with the PUC reiterating that the proposed rule changes conflicted with statutory requirements, including sections 218, 399.2, and 451.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the PUC’s decisions. The court held that the PUC had not abused its discretion, misinterpreted the statutes, or failed to proceed as required by law. It found that the PUC’s decisions were consistent with applicable law and legislative intent, particularly the priority given to safety and the requirement that regulated utilities maintain control over their distribution systems. The court affirmed the PUC’s decisions. View "Applied Medical Resources Corp. v. Public Utilities Commission" on Justia Law

The case concerns a petition filed by the Public Guardian of Santa Barbara County to establish a conservatorship under the Lanterman-Petris-Short (LPS) Act for K.L., who was alleged to be gravely disabled due to mental health disorders. K.L. was personally served with a written citation informing her of the proceedings. At a pretrial hearing, K.L. appeared remotely, and her attorney objected to the conservatorship, requesting a Zoom court trial. However, neither K.L. nor her attorney expressly waived the right to a jury trial, nor did the court or counsel explain the mechanics and significance of a jury trial or verify K.L.’s capacity to waive that right.The Superior Court of Santa Barbara County held a court trial, heard testimony, and found K.L. gravely disabled beyond a reasonable doubt. The court appointed the Public Guardian as conservator for one year, determined that the least restrictive placement was a locked psychiatric facility, and imposed various restrictions on K.L., including prohibitions on possessing firearms and operating a vehicle.Upon review, the Court of Appeal of the State of California, Second Appellate District, Division Six, examined whether K.L. was properly advised of her right to a jury trial and whether her waiver of that right was knowing and intelligent. The appellate court held that a written citation alone is insufficient to establish a valid waiver without evidence that the proposed conservatee was fully informed of the right and its implications. The court concluded that the record lacked affirmative evidence of such advisement or waiver and found the trial court’s error to be reversible. The order establishing the conservatorship was therefore reversed. View "Conservatorship of K.L." on Justia Law

Two families who had a long-standing personal and professional relationship worked together on real estate projects, with one family providing financing and the other managing remodeling. Their arrangement involved consolidating outstanding debts from two properties into a single promissory note secured by a deed of trust, with a substantial balloon payment due after one year. After disagreements arose about the scope of renovations for a particular property, their relationship deteriorated. Eventually, the financier purchased the property from the remodelers through an escrow process in which a portion of the purchase price was transferred back to the financier to satisfy the outstanding note.The Superior Court of Los Angeles County granted summary judgment in favor of the remodelers. The court found that the financier had been fully repaid through the escrow process and, as a result, suffered no damages. Additionally, the court held that a covenant not to sue, which had been negotiated as part of the property sale, barred the financier’s lawsuit. In a prior appeal regarding other parties, the California Court of Appeal affirmed a similar summary judgment due to the financier’s failure to cite record evidence. After the remaining cross-claims were dismissed, final judgment was entered for the remaining defendants.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case independently and affirmed the judgment. The court held that when undisputed evidence shows a debt has been repaid, subjective beliefs or unexplained testimony cannot create a triable issue of fact sufficient to defeat summary judgment. The court rejected the financier’s argument that the repayment was illusory or self-funded, as the objective record showed the debt was satisfied through the escrow transfer. The court also ruled that arguments regarding other forms of damages were forfeited because they were not raised in the trial court. Costs were awarded to the respondents. View "Buchheim v. Anaya" on Justia Law

The plaintiff suffered harm as a result of an incident at a Trader Joe’s store. Following a trial in the Superior Court of Stanislaus County, a jury found Trader Joe’s negligent and determined that its negligence was a substantial factor in causing injury to the plaintiff. The jury awarded damages of $23,509,165. After a post-trial motion, the court conditionally granted a new trial unless the plaintiff accepted a reduced award. The plaintiff accepted the remittitur, and an amended judgment was entered for $10,809,165.Trader Joe’s sought to appeal the amended judgment. The deadline to file the notice of appeal was January 20, 2026. On that date, Trader Joe’s submitted its notice of appeal electronically, receiving confirmation of receipt. However, the Superior Court clerk later rejected the filing, citing a local rule and a court website provision that classified notices of appeal as documents that could not be filed electronically. After further attempts, the notice of appeal was eventually accepted and filed on February 17, 2026. The plaintiff then moved to dismiss the appeal as untimely.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case. It held that the local rule and related court website provisions barring e-filing of notices of appeal were inconsistent with state law, particularly California Rules of Court, rule 2.253. As such, the rule was invalid. The court further held that since Trader Joe’s had delivered the notice of appeal to the clerk electronically on the jurisdictional deadline, the notice was timely. The court denied the plaintiff’s motion to dismiss the appeal. View "Gharraee v. Trader Joe's Co." on Justia Law

Four individuals who were or are patients of a health care system brought a proposed class action against the system, alleging violations of the California Invasion of Privacy Act (CIPA) and the California Confidentiality of Medical Information Act (CMIA). They claimed the health care provider installed web tracking technologies, specifically Meta Pixel and Google Analytics, on its various websites, including a public health risk assessment (HRA) site and a password-protected patient portal. According to the plaintiffs, these tools tracked users’ activities, collected their data—including personally identifiable information, health-related communications, and protected health information—and transmitted it to Meta and Google, who then used the data for advertising purposes.The Superior Court of Los Angeles County denied the plaintiffs’ motion for class certification in its entirety. The court found that the proposed subclasses—patients who logged into the patient portal and those who submitted HRA forms—were not ascertainable, that individual issues predominated over common ones, and that a class action was not the superior or manageable method. It reasoned that determining whether the tracking technologies’ transmissions constituted “contents” under CIPA or “medical information” under CMIA would require individualized inquiries into each user’s data. The court also concluded plaintiffs had abandoned their CIPA claim under section 632.On appeal, the California Court of Appeal, Second Appellate District, affirmed in part, reversed in part, and remanded. The appellate court held that the HRA form subclass and the CIPA claim for the patient portal subclass met the requirements for class certification, as key liability questions could be resolved with common proof. However, it affirmed the denial of class certification for the CMIA claim for the patient portal subclass and agreed that plaintiffs forfeited their CIPA section 632 claim. The court found class action treatment was superior and manageable for the certified subclasses. View "Doe v. Adventist Health System/West" on Justia Law

Lakeshore Investments loaned over $1.7 million to NOW Solutions, Inc., secured by a promissory note and collateral agreement. When NOW Solutions defaulted, the parties amended the payment terms multiple times, eventually adding Vertical Computer Systems as a co-debtor. Despite these amendments, NOW Solutions fell behind on payments again, and Lakeshore filed a lawsuit for breach of contract. During litigation, the parties entered into a settlement agreement: NOW Solutions and its parent agreed to pay $450,000 in three installments, with a provision that failure to pay would entitle Lakeshore to a stipulated judgment of $1.5 million plus interest.After defendants defaulted on the final installment and failed to cure their default, Lakeshore requested entry of the $1.5 million judgment in Los Angeles County Superior Court. Defendants objected, arguing the amount was an unenforceable penalty. The Superior Court granted Lakeshore’s request without making specific findings beyond confirming the default.On appeal, the California Court of Appeal, Second Appellate District, Division Eight, considered whether the $1.5 million stipulated judgment was a valid liquidated damages provision or an unenforceable penalty under Civil Code section 1671. The appellate court held that, because the $1.5 million amount bore no reasonable relationship to the damages that could have been anticipated from breach of the settlement, it constituted a penalty and was unenforceable. The court reversed the trial court’s order and remanded with instructions to determine the actual damages suffered by Lakeshore as a result of the breach. The court awarded costs on appeal to the defendants. View "Lakeshore Investment LLC v. Now Solutions, Inc." on Justia Law