Justia California Court of Appeals Opinion Summaries

After being found not guilty of a crime by reason of insanity, C.F. was admitted to a state hospital, where he was treated with antipsychotic medication under a court order. When the Department of State Hospitals sought to renew the order authorizing involuntary medication, the trial court held an evidentiary hearing. C.F.’s counsel did not request a court reporter, though one could have been provided at no cost by simply submitting a form. Consequently, no verbatim record of the hearing was made, and C.F. did not attend, with his counsel waiving his appearance.The Superior Court of Napa County heard from the Department’s expert witness and found, by clear and convincing evidence, that C.F. lacked capacity to refuse treatment, granting the renewal for up to one year. C.F. appealed, arguing that he was denied effective assistance of counsel because his lawyer did not secure a record of the hearing. When C.F. later applied for a settled statement to reconstruct the hearing for appellate review, the trial court denied the request, finding he had waived his right to a record by not requesting a reporter.The Court of Appeal of the State of California, First Appellate District, Division Five, found that C.F.’s counsel’s failure to request a reporter constituted deficient performance, with no tactical explanation and resulting prejudice. The absence of a hearing record rendered meaningful appellate review impossible, amounting to a denial of due process and effective assistance of counsel. The appellate court reversed the trial court’s order and remanded for a new hearing, noting that if the Department seeks to renew the order after its expiration, the new hearing may be combined with any future renewal petition. View "People v. C.F." on Justia Law

A nursing student was required to complete clinical rotations at local hospitals as part of her coursework in 2017. She alleged that her supervisor, the director of the nursing program, subjected her to severe sexual harassment and retaliated against her when she rejected his advances by giving her a failing grade and refusing to discuss it. After the student reported these incidents, the district placed the supervisor on administrative leave and initiated an independent investigation. The investigation confirmed inappropriate conduct by the supervisor, who did not return to his position. The student later withdrew from the program and completed her degree out of state. Through counsel, she notified the district of her intent to pursue claims and sought damages.The Superior Court of San Bernardino County granted summary judgment for the community college district, holding that the student lacked standing under the Fair Employment and Housing Act (FEHA), failed to comply with the Government Claims Act for her non-FEHA claims, and that the district was not deliberately indifferent under the Education Code. The court also excluded the student’s attorney’s declaration due to a technical omission, and entered judgment for the district on all claims.The California Court of Appeal, Fourth Appellate District, Division Three, reversed the judgment. The court found the trial court abused its discretion by refusing to allow the attorney’s declaration to be corrected, which was a curable procedural defect. The appellate court held that a postsecondary student serving in a clinical capacity qualifies as an “unpaid intern” under FEHA, conferring standing. The court further found the student’s notice to the district satisfied the Government Claims Act requirements, and concluded that triable issues existed regarding whether the district acted with deliberate indifference. The court affirmed summary adjudication for the district only on the Civil Code cause of action, but otherwise denied summary judgment and remanded for further proceedings. View "Walton v. Victor Valley Community College District" on Justia Law

The case concerns a legal dispute between two individuals after one party filed a complaint alleging various claims such as breach of contract and misrepresentation. The defendant, representing himself, responded with a cross-complaint. The central procedural issue arose when the trial court granted an anti-SLAPP motion in favor of the plaintiff, dismissed the cross-complaint with prejudice, and awarded attorney’s fees to the plaintiff. The defendant challenged this outcome, asserting that procedural irregularities rendered the orders void, including claims about the improper filing and service of the anti-SLAPP order, as well as arguments about judicial disqualification and standing.After the trial court’s initial rulings, the California Court of Appeal, First Appellate District, Division Four, previously reviewed the matter in an earlier appeal and affirmed the trial court’s dismissal of the cross-complaint and the award of attorney’s fees. The court also determined that the plaintiff was entitled to additional attorney’s fees incurred on appeal, with the amount to be set on remand. On remand, the trial court awarded further fees to the plaintiff. The defendant again appealed, raising many of the same arguments previously rejected, as well as new procedural objections.In this second appeal, the California Court of Appeal, First Appellate District, Division Four, found all of the defendant’s arguments baseless and affirmed the attorney’s fee award. The court held that the defendant’s attempt to relitigate final decisions was frivolous and imposed sanctions against him for pursuing a meritless appeal. The court further ordered the defendant to pay the plaintiff’s reasonable attorney’s fees for the current appeal and imposed a $10,000 sanction payable to the clerk of the court, remanding the case for the trial court to determine the precise amount of attorney’s fees to be awarded. View "Zand v. Sukumar" on Justia Law

A former employee initiated a class action lawsuit against her prior employer, alleging violations of various California Labor Code provisions and other employment-related statutes. After the lawsuit was filed, the employer entered into individual settlement agreements with approximately 954 current and former employees, offering cash payments in exchange for waivers of wage and hour claims. The total settlement payments exceeded $875,000. The named plaintiff did not sign such an agreement, but many potential class members did.The Superior Court of San Bernardino County partially granted the plaintiff’s motion to invalidate these individual settlement agreements, finding them voidable due to allegations of fraud and duress. The trial court ordered that a curative notice be sent to all affected employees, informing them of their right to revoke the agreements and join the class action. The court, however, declined to require that the notice include language stating that those who revoked their settlements might be required to repay the settlement amounts if the employer prevailed. The court instead indicated that settlement payments could be offset against any recovery and that the issue of repayment could be addressed later.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the trial court’s order after the employer petitioned for writ relief. The appellate court held that, under California’s rescission statutes (Civil Code sections 1689, 1691, and 1693), putative class members who rescind their individual settlement agreements may be required to repay the consideration received if the employer prevails, but actual repayment can be delayed until judgment. The court instructed the trial court to revise the curative notice to inform employees that repayment may be required at the conclusion of litigation, and clarified that the trial court retains discretion at judgment to adjust the equities between the parties. The order of the trial court was vacated for reconsideration consistent with these principles. View "The Merchant of Tennis, Inc. v. Superior Ct." on Justia Law

A private individual brought a qui tam action under the California False Claims Act (CFCA) against two construction-related entities, alleging they submitted false claims to local government agencies in connection with airport construction projects. The plaintiff followed the statutory procedure by filing the complaint under seal in the Superior Court of Los Angeles County and mailing a copy to the Attorney General, as required by the CFCA. The complaint involved local (political subdivision) funds. The Attorney General, however, did not forward the complaint to the relevant local authorities and took no steps to intervene or extend the seal. After the 60-day sealing period expired without government action, the plaintiff served the defendants.The Superior Court of Los Angeles County sustained the defendants’ demurrer without leave to amend, holding that the plaintiff failed to comply with the CFCA’s sealing and service requirements. The trial court concluded the complaint should have remained under seal until the government notified the court of its decision to intervene, and that the plaintiff’s actions in unsealing and serving the complaint were premature. The court entered judgment dismissing the action with prejudice.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. It held that a qui tam plaintiff is not required to allege compliance with the CFCA’s sealing and service requirements to state a cause of action, nor does failure to comply automatically require dismissal. The court further held that the statutory scheme creates a default 60-day seal period, which lifts automatically unless the government requests an extension. Because the plaintiff filed the complaint under seal, served the Attorney General, and waited until after the seal lifted to serve the defendants, the plaintiff complied with the statute. The judgment was reversed and the case remanded with directions to overrule the demurrer. View "Albarghouti v. LA Gateway Partners, LLC" on Justia Law

A group of individuals who were victims of a Ponzi scheme obtained a default judgment for fraud against two corporations involved in the scheme. Unable to collect on this judgment, they each applied to the California Secretary of State for restitution from the Victims of Corporate Fraud Compensation Fund, which compensates victims when a corporation’s fraud leads to uncollectible judgments. The Secretary denied their claims, arguing primarily that the underlying fraud lawsuit had been filed after the statute of limitations had expired, making the judgment invalid for purposes of fund payment.The victims challenged the Secretary’s denial by filing a verified petition in the Superior Court of Orange County, seeking an order compelling payment from the fund. The Secretary maintained that the statute of limitations barred the underlying fraud claim, but the trial court disagreed. The court held that because the defendant corporations had defaulted and thus waived the statute of limitations defense in the original lawsuit, the Secretary could not raise that defense in the current proceeding. The trial court ordered payment from the fund to the victims in the amounts awarded in the underlying default judgment.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, affirmed in part and reversed in part. The appellate court clarified that under the statutory scheme, neither the Secretary nor the trial court may relitigate the merits of the underlying fraud claim, including whether it was time-barred. The court held that the trial court’s inquiry is limited to whether the claimant submitted a valid payment claim under the specific statutory requirements; it cannot revisit defenses such as the statute of limitations. However, the court found error in the trial court’s failure to cap payments at $50,000 per claimant as required by statute, and remanded the case for correction of this aspect of the order. View "Dion v. Weber" on Justia Law

Two attorneys, each at different times, represented the same clients in a personal injury case, with both attorneys retained under written contingency fee agreements. After the clients achieved a settlement, both attorneys claimed attorney liens on the settlement proceeds, but could not agree on the amounts due to each under their respective agreements. The dispute centered on approximately $62,000 in withheld settlement funds, after a third law firm (not a party to this action) had been paid.After negotiations failed, one attorney filed a declaratory relief action in the Superior Court of El Dorado County against the other attorney and the clients, seeking a judicial determination of the parties’ rights to the withheld settlement proceeds. The opposing attorney responded by moving to dismiss on the theory that the validity and amount of his lien had to be adjudicated first in a separate action before any action could proceed on the other lien. The trial court agreed, finding that the first attorney’s lien was “senior,” and dismissed the claim as to the competing attorney, holding that the proper procedure required the first attorney to have his lien determined before the other attorney’s claim could be heard.On appeal, the Court of Appeal of the State of California, Third Appellate District, reversed the dismissal. The appellate court held that an attorney may bring a single declaratory relief action against both the clients and a competing attorney lien claimant to resolve the validity, amount, and priority of competing attorney liens on the same settlement proceeds. The court rejected the notion that one attorney’s claim must be resolved in a separate action before the other’s. The matter was remanded for further proceedings. The appellate court’s judgment thus allows simultaneous adjudication of competing attorney liens in a single declaratory relief action. View "Jacobs v. Papez" on Justia Law

A former participant in a Zen Buddhist center’s residential training programs asserted wage-and-hour claims against the center and two of its leaders, arguing he was owed various wages and penalties for work performed during his time in the center’s programs. The center operates multiple facilities, offers residential programs, and generates income from guest activities and commercial events. The plaintiff undertook tasks such as guesthouse cleaning, kitchen work, gardening, and guest cooking, receiving modest stipends and room and board. After leaving the center, he filed his claims, alleging unpaid minimum and overtime wages and other statutory violations.The Labor Commissioner held in favor of the plaintiff and found the center, as well as the two individual leaders, liable for significant amounts. The center and the individuals appealed to the Superior Court of California, County of San Francisco. The trial court denied the plaintiff’s motion to dismiss the individual appeals on the ground that only the center, not the individuals, was required to post an appeal bond. The trial court subsequently granted summary judgment for the defendants, holding that the “ministerial exception” of the First Amendment barred the plaintiff’s wage-and-hour claims due to the religious nature of the organization and the plaintiff’s role as a minister.On appeal, the California Court of Appeal, First Appellate District, Division Two, reversed the summary judgment. The court held that the ministerial exception does not categorically bar wage-and-hour claims by ministers against religious organizations in the absence of evidence that adjudicating the claims would require resolving ecclesiastical questions or interfere with religious autonomy. The court affirmed the trial court’s denial of the motion to dismiss the individual appeals, holding that only the employer (the center) was required to post the statutory undertaking, not the individual leaders. The judgment was thus reversed in part and affirmed in part. View "Ehrenkranz v. S.F. Zen Center" on Justia Law

The case centers on a challenge to a provision in the Los Angeles Administrative Code, section 8.33, which grants the mayor special powers upon declaring a “local housing and/or homelessness emergency.” In July 2023, the mayor declared such an emergency, and the city council subsequently renewed it. The emergency declaration was later lifted in November 2025. During the period the declaration was in place, Fix the City, Inc. contended that section 8.33 was invalid because it conflicted with the California Emergency Services Act (CESA) and another provision in the city’s code, arguing that the city had acted illegally during the emergency.The Superior Court of Los Angeles County reviewed Fix the City’s claims for writ and declaratory relief, which sought to vacate the emergency declaration and any resulting directives, as well as a declaration that section 8.33 was void for conflicting with CESA and local law. The city responded with a demurrer, asserting that section 8.33 was a proper exercise of municipal authority and did not conflict with CESA or the city’s own code. The superior court agreed, finding that CESA did not apply to charter cities unless there was a clear legislative directive, and that section 8.33 was not inconsistent with other city code provisions. The court sustained the demurrer without leave to amend, and Fix the City appealed.The California Court of Appeal, Second Appellate District, Division One, affirmed the lower court’s judgment. The appellate court held that CESA does not preempt section 8.33 because the two do not conflict; section 8.33 is a valid exercise of the city’s home rule powers over municipal affairs. Additionally, section 8.33 did not violate other provisions of the city’s administrative code. The denial of leave to amend was also upheld. View "Fix the City, Inc. v. City of Los Angeles" on Justia Law

J.S. sought a domestic violence restraining order (DVRO) against her former fiancé, D.A., alleging ongoing abuse that included physical violence and threatening communications while D.A. was incarcerated. J.S. described several incidents of abuse during their relationship and stated that she was fearful of further harm upon D.A.’s eventual release from prison. After J.S. filed for a DVRO, the Superior Court of San Diego County issued a temporary restraining order, and scheduled an evidentiary hearing to decide on a permanent order. D.A., still incarcerated, responded to the court by requesting an opportunity to appear telephonically at the hearing, citing his inability to attend in person.The Superior Court of San Diego County continued the initial hearing but did not address D.A.’s request to appear telephonically. At the rescheduled hearing, D.A. was not present, and the court did not document any attempt to facilitate his participation or check his custody status. Based on J.S.’s testimony and the evidence on file, the court issued a five-year DVRO against D.A. Afterward, D.A. filed motions seeking discovery, an expert, and assistance for telephonic appearance, but there was no indication the court acted on these filings. D.A. then appealed, arguing he was denied meaningful access to the court.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that the trial court abused its discretion by not considering and ruling on D.A.’s request for telephonic appearance, depriving him of his right to meaningful access to the courts as an indigent inmate in a bona fide civil action. The appellate court reversed the judgment and remanded for further proceedings, ordering the trial court to ensure D.A. is provided with meaningful access. The temporary restraining order remains in effect pending further proceedings. View "J.S. v. D.A." on Justia Law