Justia California Court of Appeals Opinion Summaries

In this case, consumers brought tort claims against a mattress retailer and manufacturer, alleging injuries suffered while sleeping on a defective mattress. The plaintiffs settled with the retailer and later dismissed their claims against the manufacturer, Tempur-Pedic North America, LLC, before filing a new lawsuit. The manufacturer then moved for costs as the prevailing party in the dismissed lawsuit. The trial court awarded some costs to the manufacturer, including costs for depositions that were noticed but did not occur. The consumers appealed this decision, arguing it was improper to award costs for depositions that did not occur.The Court of Appeal of the State of California Fourth Appellate District Division Two disagreed with the consumers and affirmed the trial court's decision. The appellate court held that there is no blanket exception to awarding costs for depositions that were noticed but did not occur. The court explained that the proper analysis focuses on whether costs were reasonably necessary to litigating a case when incurred, not whether the costs could have been avoided in retrospect. The court found that the trial court did not abuse its discretion in finding the costs were reasonably necessary. View "Garcia v. Tempur-Pedic North America, LLC" on Justia Law

In California, plaintiff Jasmine Moten appealed the trial court’s decision to grant an anti-SLAPP motion filed by defendant, Transworld Systems Inc. (Transworld). Moten had taken out a student loan which she later defaulted on, leading to Transworld, a debt collection company, servicing the loan. Transworld filed a debt collection action against Moten on behalf of National Collegiate Student Loan Trust 2007-3 (NCSLT 2007-3), to whom the loan had been assigned. Moten filed a class action lawsuit against Transworld, alleging that it did not have a valid legal claim as it had manufactured documents to prove ownership of the loan by NCSLT 2007-3. She claimed that these deceptive practices violated the Robbins-Rosenthal Fair Debt Collection Practices Act and the Federal Fair Debt Collection Practices Act, as well as Unfair Competition and Unlawful Business Acts and Practices. The trial court granted Transworld's anti-SLAPP motion, which led to Moten's appeal. The Court of Appeal for the State of California Fourth Appellate District Division Two reversed the trial court’s decision, ruling that the trial court erred in applying the litigation privilege to Moten's claims. The appellate court remanded the case back to the trial court to determine whether Moten has a probability of prevailing on her claims and to consider the public interest exception of Code of Civil Procedure section 425.17. View "Moten v. Transworld Systems Inc." on Justia Law

This case arose from a dispute between Gregory Garrabrants, the CEO of BofI Federal Bank (BofI), and Charles Matthew Erhart, a former internal auditor at BofI who acted as a whistleblower. Erhart copied, transmitted, and retained various documents he believed evidenced possible wrongdoing, some of which contained Garrabrants' personal and confidential information. Garrabrants sued Erhart for accessing, taking, and subsequently retaining his personal information. A jury awarded Garrabrants $1,502 on claims for invasion of privacy, receiving stolen property, and unauthorized access to computer data.However, the Court of Appeal, Fourth Appellate District, Division One, State of California, reversed the judgment and remanded the case. The court found that the trial court made prejudicial errors in its jury instructions. Specifically, the trial court erred in instructing the jury that bank customers have an unqualified reasonable expectation of privacy in financial documents disclosed to banks. The trial court also erred in instructing the jury that Erhart's whistleblower justification defense depended on proving at least one legally unsupported element. The instructions given for Penal Code section 496 misstated the law by defining “theft” in a manner that essentially renders receiving stolen property a strict liability offense. Furthermore, the special instruction on Penal Code section 502 erroneously removed from the jury’s consideration the foundational issue of whether Garrabrants “owned” the data about him residing in BofI’s computer systems such that he could pursue a civil action under the statute. The court concluded that, in light of the record evidence, there is a reasonable possibility a jury could have found in Erhart’s favor on each of Garrabrants’ claims absent the erroneous instructions, making them prejudicial. View "Garrabrants v. Erhart" on Justia Law

In the case before the Court of Appeal of the State of California Third Appellate District, a dispute arose from the marital dissolution proceedings of Daniel Gilbert-Valencia (husband) and Kate McEachen (wife). The husband argued that the family court erred in awarding 100 percent of the net proceeds from the sale of the parties’ quasi-marital property to the wife, excluding evidence of domestic violence perpetrated by the wife, and retroactively modifying the tax deductibility of spousal support payments made by the husband.The facts of the case reveal that the husband sold the house over the wife’s objections during the dissolution proceedings, believing it was his personal property. He used the net proceeds from the sale exclusively for personal purposes. The family court decided that the wife was a putative spouse, the house was quasi-marital property, and the husband had breached his fiduciary duty to the wife by selling the house and using the proceeds for personal purposes. Consequently, the court awarded 100 percent of the net proceeds from the sale of the house to the wife.The appellate court agreed with the husband's first two contentions. It held that the family court committed an error by awarding 100 percent of the net proceeds from the sale of the quasi-marital property to the wife without finding oppression, fraud, or malice by the husband. This decision was an abuse of discretion because it contradicted the requirement under Family Code section 1101 for such findings to justify an unequal division of community property.The appellate court also held that the family court erred in excluding a videotape that was documented evidence of the wife’s domestic violence. In addition, it found that the family court failed to consider the husband's request for a domestic violence restraining order, admitted into evidence with the wife's consent, when deciding on spousal support. This failure was deemed a reversible error.The appellate court reversed the family court's orders and remanded the case for reconsideration of the division of quasi-marital property and spousal support, and a decision on the tax deductibility of the husband's spousal support payments. View "Marriage of Gilbert-Valencia & McEachen" on Justia Law

This is an appeal before the California Court of Appeal, Fourth Appellate District, Division One regarding an attorney fees dispute between multiple charter school entities and two school districts. The case arose from a dispute over whether certain charter schools were operating within the geographic boundaries of the Grossmont Union High School District and San Diego Unified School District in violation of the California Charter Schools Act. After a series of litigation and appeals, the charter school entities, which included Diego Plus Education Corporation, Western Educational Corporation, Lifelong Learning Administration Corporation, and Educational Advancement Corporation, were successful in defending their right to operate the schools. They subsequently sought attorney fees pursuant to California Code of Civil Procedure section 1021.5. The trial court granted the motion and ordered the school districts to pay attorney fees amounting to $582,927. The school districts appealed this decision. The appellate court conditionally reversed the order for attorney fees and remanded the case, finding that the trial court did not properly evaluate whether the financial burden of private enforcement warranted an award of attorney fees under section 1021.5. The appellate court instructed the trial court to apply the proper legal standard on remand. View "Grossmont Union High School Dist. v. Diego Plus Education Corp." on Justia Law

The case concerns a dispute between Dominic and Eric Jr., the grandchildren of the settlor of the Lena Grace Hamilton Trust, and their aunt, LaDonna Green, the initial trustee of the trust. After the death of Lena Grace Hamilton, the trust's settlor, LaDonna informed Dominic and Eric Jr. that she was the sole beneficiary of the trust. However, Dominic and Eric Jr. believed the trust amendment that made LaDonna the sole beneficiary was forged. They filed a lawsuit alleging forgery and other claims more than a year after they received notice from LaDonna about the trust and its terms. The Court of Appeal of the State of California, Second Appellate District Division Four, held that Dominic and Eric Jr.'s lawsuit was an action to contest the trust under Probate Code section 16061.8. This section imposes a 120-day statute of limitations for bringing such an action, which starts running from the day the notification by the trustee is served. Since Dominic and Eric Jr.'s lawsuit was filed more than a year after they received the notification, the court ruled that their action was time-barred under section 16061.8. The court affirmed the decision of the Superior Court of Los Angeles County, which had sustained LaDonna's demurrer (a motion to dismiss) without leave to amend, effectively dismissing the lawsuit. View "Hamilton v. Green" on Justia Law

A California appellate court ruled on a case where a journalist, Arturo Castañares, sought access to video footage recorded by drones operated by the City of Chula Vista Police Department. Castañares filed a request under the California Public Records Act (CPRA) for video footage from all drone flights for a specific month. The City provided Castañares with all the information he requested except for the video footage, leading Castañares to file a lawsuit. The trial court ruled that the video footage was exempt from disclosure due to being classified as records of investigations and that the burden of redacting the footage outweighed the benefit of disclosing. Upon appeal, the appellate court found that the trial court erred in determining that all drone footage was exempt from disclosure under the CPRA. The court determined that the drone footage could be divided into three categories: footage that is part of an investigatory file, footage of investigations, and footage of factual inquiries. The first two categories are exempt from disclosure under the CPRA, while the third is not. The case was remanded for further proceedings, with the City asked to categorize the footage accordingly and argue why the catchall provision applies to the third category. View "Castanares v. Super. Ct." on Justia Law

In a dispute between Christopher Leahy and Jeffrey Peterson, the Court of Appeal, Fourth Appellate District Division One State of California, reversed and remanded a lower court's decision to renew a civil harassment restraining order for a second five-year period without requiring a demonstration of new harassment. Leahy, a police detective, had obtained the original restraining order against Peterson in 2014, followed by a five-year renewal in 2017, based on Peterson's stalking and harassment. In 2022, Leahy requested another five-year renewal, which was granted by the Superior Court of San Diego County.The court of appeal held that the lower court erred in its interpretation of section 527.6, subdivision (j)(1) of the Code of Civil Procedure, which allows for renewal of a civil harassment restraining order “without a showing of any further harassment since the issuance of the original order.” This provision, according to the court of appeal, does not authorize a second five-year renewal without a showing of new harassment. The court also clarified that constitutionally protected activity, such as filing a lawsuit, cannot constitute harassment under section 527.6. The case was remanded to the lower court to reconsider the renewal petition under the proper standard. View "Leahy v. Peterson" on Justia Law

This case concerns John HR Doe and other Doe plaintiffs, who alleged that William Babcock, a counselor at an elementary school in the Marysville Joint Unified School District, committed sexual misconduct causing them injury and damages. The Doe plaintiffs filed three separate lawsuits against the School District. The first two, filed in state court, were voluntarily dismissed. The third, filed in federal court, also alleged violations of federal law. The School District moved to dismiss the federal court action, claiming immunity under the Eleventh Amendment for most of the claims. The Doe Plaintiffs then voluntarily dismissed their federal court action and filed a third state court action.The School District demurred to the third state court complaint, arguing res judicata based on the plaintiffs' voluntary dismissal of the second action in federal court. The trial court sustained the demurrer and dismissed the complaint, ruling that the dismissal of the federal court action constituted res judicata. On appeal, the Doe plaintiffs contended that the federal court lacked subject matter jurisdiction to adjudicate the claims on the merits because the School District argued Eleventh Amendment immunity. They also argued that California state law controls, under which a second voluntary dismissal does not constitute res judicata.The Court of Appeal of the State of California, Third Appellate District, affirmed the trial court's decision. The appellate court found that the federal court did have subject matter jurisdiction over the plaintiffs' claims because it had jurisdiction over the federal law claims, with supplemental jurisdiction over the state-law claims. Moreover, the court held that res judicata applied because federal law determines the claim-preclusive effect of a federal court judgment in a federal question case, and under federal law, a second voluntary dismissal operates as an adjudication on the merits. The court rejected the plaintiffs' argument that California law should control, stating that states must accord federal court judgments the effect that federal law prescribes. As such, the Doe plaintiffs' third state court action was barred by res judicata due to their second voluntary dismissal in federal court. View "Doe v. Marysville Joint Unified Sch. Dist." on Justia Law

In the case between Lisa Stettner, Michele Zousmer and Mercedes-Benz Financial Services USA, LLC, the dispute centered on a vehicle turn-in fee that Mercedes-Benz charges at the end of their lease agreements. Stettner and Zousmer considered this fee to be taxable and filed a suit accusing Mercedes-Benz of violating California’s Unfair Competition Law and for declaratory relief.However, the Court of Appeal of the State of California Third Appellate District found that the plaintiffs did not exhaust their administrative remedies before bringing the lawsuit, which is a prerequisite for a taxpayer to challenge the validity of a tax in court. Moreover, the court ruled that the plaintiffs were not entitled to a judicial remedy because there was no prior legal determination resolving the taxability issue.The court also stated that the trial court was correct to deny the plaintiffs' request to amend their complaint to include a copy of the lease agreements. The court found that the definition of the vehicle turn-in fee in the lease agreements did not rectify the defects in the plaintiffs' first amended complaint. Therefore, the court affirmed the trial court’s order sustaining the demurrers. View "Stettner v. Mercedes-Benz Financial Services USA, LLC" on Justia Law