Justia California Court of Appeals Opinion Summaries

In 2021, a plaintiff filed a complaint against a public school district, alleging that she was repeatedly sexually assaulted by a teacher while attending middle and high school. The complaint asserted that the teacher’s abusive conduct was widely known within the school and that the district either knew or should have known about the abuse but failed to act, allowing the teacher to remain employed. The plaintiff brought claims for negligence and negligent hiring, retention, and supervision, relying on statutory provisions that exempt certain childhood sexual assault claims from the usual requirement to present a claim to the public entity before filing suit.The Superior Court of Los Angeles County reviewed the case after the school district moved for judgment on the pleadings. The district argued that the plaintiff’s claims were only possible due to Assembly Bill 218 (AB 218), which retroactively eliminated the claims presentation requirement for childhood sexual assault claims against public entities. The district contended that AB 218 violated the gift clause of the California Constitution by imposing liability for past acts where no enforceable claim previously existed. The trial court agreed, finding that AB 218 retroactively created liability and constituted an unconstitutional gift of public funds, and dismissed the complaint with prejudice.The California Court of Appeal, Second Appellate District, Division One, reviewed the trial court’s decision de novo. The appellate court held that AB 218 does not violate the gift clause because it did not create new substantive liability; rather, it removed a procedural barrier to enforcing pre-existing liability for negligence and negligent hiring, retention, and supervision. The court reversed the trial court’s order and remanded with directions to deny the school district’s motion for judgment on the pleadings. View "O.B. v. L.A. Unified School Dist." on Justia Law

A 16-year-old committed a violent home invasion, during which he raped, sodomized, and assaulted his former neighbor at knifepoint, then stole property from her home. He was convicted by a jury in 2002 of multiple counts, including forcible rape, oral copulation, sodomy, sexual battery, robbery, burglary, and related enhancements. His sentence was ultimately modified to a determinate term of 19 years, followed by a consecutive indeterminate term of 25 years to life, resulting in an effective sentence of 44 years to life.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d)(1)(A), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that, under equal protection principles as articulated in People v. Heard, he should be eligible for relief. The trial court denied the petition, finding that a 44-years-to-life sentence was not functionally equivalent to LWOP and thus did not qualify for resentencing under the statute.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which was developed in the Eighth Amendment context, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as required for equal protection claims. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those with lengthy term-of-years sentences that do not guarantee death in prison. The court affirmed the trial court’s denial of the petition, holding that section 1170(d)’s limitation to those sentenced to LWOP does not violate equal protection as applied to a juvenile nonhomicide offender sentenced to 44 years to life. View "People v. Baldwin" on Justia Law

Greg Wright was recorded on video robbing a gas station convenience store at gunpoint. The cashier, who was present during the incident, testified that Wright showed no signs of intoxication—he did not smell of alcohol, slur his words, or appear confused. The robbery was carried out efficiently, with Wright taking money, a lighter, and his own dollar before leaving. Police arrested Wright the next day and found a loaded pistol in his car. At trial, Wright represented himself and argued that he was too intoxicated to form the intent to rob, but the evidence from both the cashier and the surveillance video contradicted this claim.The Superior Court of Los Angeles County presided over the trial. The jury convicted Wright of robbery, possession of a firearm by a felon, and unlawful possession of ammunition, and found true the firearm use and prior conviction allegations. The trial court sentenced Wright to 36 years and four months to life, including enhancements for firearm use and prior convictions. Wright challenged the jury instructions regarding intoxication, the prosecutor’s closing argument, and the imposition of multiple punishments for related offenses, as well as the process for determining aggravating sentencing factors.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the trial court erred by using the term “specific intent” in the intoxication defense instruction, but found the error harmless given the overwhelming evidence that Wright was not impaired. The court also found any assumed prosecutorial error and cumulative error to be harmless. However, the appellate court agreed that sentencing errors occurred: multiple punishments for the firearm and ammunition offenses violated Penal Code section 654, and Wright was denied his right to a jury trial on aggravating sentencing factors as required by Erlinger v. United States. The convictions were affirmed, but the case was remanded for full resentencing. View "People v. Wright" on Justia Law

The defendant operated a dog breeding business from properties in Solano County, California. A nonprofit animal welfare organization brought suit against her, alleging violations of state and local animal welfare laws, including keeping more than the permitted number of dogs, failing to provide adequate care, and maintaining unsanitary conditions. The defendant was found to have violated several provisions of the Vallejo Municipal Code and the state’s Pet Breeder Warranty Act, including exceeding the four-dog limit, allowing dogs to run at large, and failing to provide proper nutrition, water, and veterinary care.The Superior Court of Solano County granted summary judgment for the plaintiff and issued a permanent injunction that, among other things, barred the defendant from owning any dogs and gave the plaintiff custody of all her dogs. On the defendant’s first appeal, the California Court of Appeal, First Appellate District, Division Five, upheld the findings of violations but found the injunction overbroad, particularly the provisions dispossessing the defendant of all dogs and granting the plaintiff full custody. The case was remanded for the trial court to modify the injunction.After remand, the trial court issued a modified permanent injunction, which limited the defendant to four dogs but also authorized the plaintiff to enter the defendant’s properties and seize any excess dogs without prior notice or hearing. The defendant appealed again, arguing that these provisions were overbroad and unconstitutional.The California Court of Appeal, First Appellate District, Division Five, held that the four-dog limit was appropriate and necessary given the defendant’s history and the circumstances. However, the court found that the provision allowing the plaintiff to seize excess dogs without notice or a hearing violated due process. The court reversed that part of the injunction and remanded for further proceedings, affirming the remainder. View "Caru Society for the Prevention of Cruelty to Animals v. Anthony" on Justia Law

Greg Wright was recorded on video robbing a gas station convenience store at gunpoint. The cashier, who was present during the incident, testified that Wright showed no signs of intoxication—he did not smell of alcohol, slur his words, or appear confused. Surveillance footage showed Wright acting purposefully and competently throughout the robbery, from his entry and interaction with the cashier to his escape. Wright, representing himself at trial, argued that he was too intoxicated to form the intent to rob, but the evidence at trial did not support this claim.The Superior Court of Los Angeles County tried the case before a jury, which convicted Wright of robbery, possession of a firearm by a felon, and unlawful possession of ammunition. The jury also found true the firearm use allegation and 13 prior convictions. The trial court sentenced Wright to 36 years and four months to life, including an upper-term enhancement for firearm use based on the finding that his prior convictions were “numerous.” Wright appealed, arguing, among other things, that the jury was improperly instructed on the intoxication defense and that there were errors in sentencing.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the trial court erred by using the term “specific intent” in the jury instruction on voluntary intoxication, as this term is ambiguous and not the correct mental state for robbery. However, the court found this error harmless because the evidence overwhelmingly showed Wright was not impaired. The court also found harmless error in the prosecutor’s closing argument and rejected the claim of cumulative error. On sentencing, the court agreed that Wright was improperly punished for both firearm and ammunition possession based on the same act and that he was denied his right to a jury trial on the aggravating factor for the upper-term sentence. The convictions were affirmed, but the case was remanded for resentencing. View "P. v. Wright" on Justia Law

A mobilehome park owner challenged the constitutionality of Civil Code section 798.30.5, which limits annual rent increases for certain mobilehome parks located within the jurisdictions of two or more incorporated cities in California. The statute, effective from January 1, 2022, to January 1, 2030, restricts rent increases to the lower of 3 percent plus the percentage change in the cost of living, or 5 percent, and limits the number of rent increases within a 12-month period. The owner alleged that the statute is facially unconstitutional because it lacks a procedural mechanism for property owners to seek rent adjustments to ensure a fair return, arguing this omission violates due process and results in an uncompensated taking.The Superior Court of Orange County granted the owner’s motion for judgment on the pleadings, finding that the absence of a process to seek exceptions to the rent ceiling violated due process and rendered the statute unconstitutional. The court rejected the owner’s takings argument but concluded that the statute’s plain language was undisputed and denied the State’s request for leave to amend its answer, determining that any amendment would be futile.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court held that the owner failed to demonstrate that the statute is facially unconstitutional, clarifying that a fair return adjustment mechanism is not required for all rent control laws to be constitutional, but may be necessary only if the law is confiscatory in its application. The court also found that the State’s general denial in its answer placed the owner’s standing to sue at issue, precluding judgment on the pleadings. Accordingly, the appellate court reversed the judgment in favor of the owner. View "Anaheim Mobile Estates v. State" on Justia Law

A mobilehome park owner challenged the constitutionality of a California statute that limits annual rent increases for certain mobilehome parks located within the jurisdictions of two or more incorporated cities. The owner argued that the statute is facially unconstitutional because it lacks a procedural mechanism allowing property owners to seek rent increases above the statutory cap to ensure a fair return, which the owner claimed is required by the California and U.S. Constitutions. The owner asserted that the absence of such a mechanism results in a violation of due process, equal protection, and the prohibition against uncompensated takings.The Superior Court of Orange County granted the owner’s motion for judgment on the pleadings, finding that the statute’s failure to provide a process for seeking exceptions to the rent cap violated due process and rendered the statute unconstitutional. The court rejected the owner’s takings argument but concluded that the legal issue was dispositive and denied the State’s request for leave to amend its answer. Judgment was entered in favor of the owner, and the State appealed.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court held that the owner failed to establish that the statute is facially unconstitutional, as the relevant legal precedents do not require a fair return adjustment mechanism in every rent control law. The court also found that the State’s general denial in its answer placed the owner’s standing at issue, precluding judgment on the pleadings. The court reversed the judgment of the trial court, holding that the absence of a fair return adjustment mechanism does not, by itself, render the statute facially unconstitutional, and that the State’s answer raised material issues that should have prevented judgment on the pleadings. View "Anaheim Mobile Estates v. State" on Justia Law

In 1996, California voters enacted Proposition 218, adding article XIII D to the California Constitution, which includes section 6(b)(3). This section mandates that governmental fees or charges imposed on property must not exceed the proportional cost of the service attributable to the parcel. Plaintiffs, representing a class of single-family residential (SFR) customers of the City of San Diego, challenged the City's tiered water rates, claiming they violated section 6(b)(3) by exceeding the proportional cost of delivering water.The Superior Court of San Diego County ruled in favor of the plaintiffs, finding that the City's tiered rates did not comply with section 6(b)(3). The court concluded that the City failed to show that its tiered rates were based on the actual cost of providing water at different usage levels. The court found that the City's tiered rates were designed to encourage conservation rather than reflect the cost of service, and that the City's use of peaking factors and other methodologies lacked supporting data.The Court of Appeal of the State of California, Fourth Appellate District, Division Two, reviewed the case. The court affirmed the lower court's decision, holding that the City did not meet its burden of proving that its tiered rates complied with section 6(b)(3). The appellate court found that substantial evidence supported the trial court's findings that the City's tiered rates were not cost-proportional and that the City's methodologies were not adequately supported by data. The court also addressed the issue of class certification, finding that the class was properly certified and that the plaintiffs had a common interest in challenging the City's rate structure.The appellate court directed the trial court to amend the judgment to allow the City to satisfy the refund award pursuant to newly enacted Government Code section 53758.5, which requires agencies to credit refund awards against future increases in or impositions of the property-related charge. The court denied the plaintiffs' request for attorney fees on appeal without prejudice, allowing the trial court to determine the entitlement to such fees. View "Patz v. City of S.D." on Justia Law

An 18-year-old defendant assisted his employer, a drug dealer, in abducting a drug addict at gunpoint. The victim, who had previously sold drugs for the dealer under threat, was lured to a parking lot, forcibly taken to the dealer’s home, and subjected to prolonged violence and threats in an attempt to extort $100,000. The victim was beaten, tied up, threatened with death, forced to ingest or absorb drugs, and ultimately locked in a closet with the door screwed shut. After approximately 28 hours, a SWAT team rescued the victim. The defendant was present throughout the ordeal, actively participated in the violence, and threatened the victim and his family.A jury in the Superior Court of Orange County convicted the defendant of aggravated kidnapping with bodily harm and a firearm enhancement. The court imposed a mandatory sentence of life without the possibility of parole (LWOP) plus a 10-year firearm enhancement, and also imposed a $300 parole revocation fine. The defendant appealed, arguing that the LWOP sentence was unconstitutional as applied to 18-year-olds under both the Eighth Amendment of the United States Constitution and the California Constitution, and that the parole revocation fine was improper because he was ineligible for parole.The California Court of Appeal, Fourth Appellate District, Division Three, held that binding precedent from the United States Supreme Court and the California Supreme Court does not extend the constitutional protections against LWOP sentences for juveniles to offenders who were 18 at the time of the crime. The court also found that the sentence was not grossly disproportionate under the California Constitution, given the defendant’s conduct and criminal history. However, the court agreed that the parole revocation fine was improper and ordered it stricken. The judgment was affirmed as modified. View "P. v. Christensen" on Justia Law

In 2016, California voters approved Proposition 57, which amended the California Constitution to allow the Department of Corrections and Rehabilitation (the department) to award credits for good behavior and rehabilitative or educational achievements. The department adopted regulations to award credits beyond statutory limits and to use credits to advance indeterminately-sentenced inmates’ minimum eligible parole dates. The Criminal Justice Legal Foundation and several family members of crime victims challenged these regulations through a petition for writ of mandate.The Superior Court of Sacramento County denied the writ in part and granted it in part, invalidating the department’s regulations to the extent they allowed the use of credits to advance an indeterminately-sentenced inmate’s minimum eligible parole date. Both the department and the petitioners appealed the decision.The California Court of Appeal, Third Appellate District, reviewed the case. The court held that Proposition 57 properly removed statutory restraints on the department’s authority to award credits, allowing the regulations to supersede contrary statutes. However, the court also held that the department may use credits to advance indeterminately-sentenced inmates’ minimum eligible parole dates only if permitted by existing law, as Proposition 57 is silent on this issue. The court remanded the matter to the trial court with directions to modify the writ of mandate and enter a modified judgment. View "Criminal Justice Legal Foundation v. Department of Corrections and Rehabilitation" on Justia Law