Justia California Court of Appeals Opinion Summaries

JHVS Group, LLC and its members, Jasanjot Singh and Harshana Kaur, purchased a 66.4-acre pistachio orchard from Shawn Slate and Dina Slate for approximately $2.6 million. The Slates agreed to carry a loan for $1,889,600, and JHVS made a $700,000 down payment. The agreement included provisions for interest payments and additional payments coinciding with expected crop payments. JHVS alleged that the Slates and their brokers, Randy Hayer and SVN Executive Commercial Advisors, misrepresented material facts about the property, including water rights and the value of the 2022 crop. JHVS claimed the actual value of the crop was significantly lower than represented, and they fell behind on payments, leading the Slates to record a notice of default.JHVS filed a lawsuit in the Superior Court of Madera County, raising seven causes of action, including breach of fiduciary duty, negligence, intentional fraud, negligent misrepresentation, breach of contract, rescission based on fraud or mutual mistake, and injunctive relief to stop the foreclosure process. JHVS filed a motion for a preliminary injunction to prevent the foreclosure sale, arguing that the Slates and Hayer had lied about water restrictions and misrepresented the crop's value. The trial court granted the preliminary injunction after the defendants did not appear or file a response.The California Court of Appeal, Fifth Appellate District, reviewed the case and found that the trial court lacked fundamental jurisdiction over the Slates because they were never served with the summons and complaint. The appellate court determined that the trial court's order was void as to the Slates due to the lack of proper service and reversed the preliminary injunction order with respect to the Slates. The case was remanded for further proceedings consistent with the appellate court's opinion. View "JHVS Group, LLC v. Slate" on Justia Law

The case involves the San Diego City Attorney filing a complaint against Experian Data Corp. for violating the unfair competition law (UCL) by failing to promptly notify consumers of a data breach as required by Civil Code section 1798.82(a). The City Attorney sought civil penalties and injunctive relief. The UCL claim is subject to a four-year statute of limitations, and the key issue is whether the discovery rule can delay the accrual of this non-fraud civil enforcement action.The Superior Court of Orange County initially overruled Experian's demurrer, which argued the complaint was time-barred. The court found the complaint did not show on its face that the UCL claim accrued before March 6, 2014. However, the court later granted Experian's motion in limine to exclude evidence relating to civil penalties, concluding the discovery rule did not apply to the UCL claim because it was a non-fraud claim and an enforcement action seeking civil penalties. The court also denied the City Attorney's motion for reconsideration and motion to file a Third Amended Complaint.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case and concluded that the discovery rule can apply to delay the accrual of the UCL claim. The court found that the nature of the claim, the enforcement action seeking civil penalties, and the involvement of a governmental entity did not preclude the application of the discovery rule. The court noted that the discovery rule has been applied to various types of claims, including those involving civil penalties and enforcement actions by governmental entities.The appellate court reversed the trial court's orders granting Experian's motion in limine and denying reconsideration. The case was remanded for the trial court to reconsider the application of the discovery rule and determine when the UCL claim accrued based on the actual or constructive knowledge of the relevant actors. The trial court was also directed to reconsider the City Attorney's request to file a Third Amended Complaint. View "People v. Experian Data Corp." on Justia Law

LVNV Funding, LLC (LVNV) filed a debt collection lawsuit against Yolanda Rodriguez (Rodriguez). Rodriguez cross-complained, alleging identity theft and violations of the federal Fair Debt Collection Practices Act (FDCPA) and the California Rosenthal Fair Debt Collection Practices Act (Rosenthal Act). Rodriguez discovered that LVNV had sued the wrong person, as the debt was incurred by a different Yolanda Rodriguez with a different date of birth and Social Security number. LVNV dismissed its suit after this was demonstrated, but Rodriguez continued with her cross-claim, arguing that the FDCPA and Rosenthal Acts are strict liability statutes that penalize false or misleading debt collection actions unless they fit within a narrow “bona fide error” defense.The Superior Court of Fresno County granted LVNV’s anti-SLAPP motion to strike Rodriguez’s cross-complaint, concluding that Rodriguez could not establish a probability of prevailing on the merits because there was nothing false, deceptive, or misleading about the debt collection action. The court found that even the “least sophisticated debtor” would have recognized the address on the documentation was not hers, and there was “nothing inherently false about the complaint” merely because it was served on the wrong Yolanda Rodriguez.The Court of Appeal of the State of California, Fifth Appellate District, reversed the trial court’s decision. The appellate court held that the FDCPA creates a strict liability cause of action for attempts to collect a debt that misrepresent or falsely present the “character” or “amount” of a debt owed, including cases of mistaken identity. The court found that Rodriguez’s claims had minimal merit, satisfying the second prong of the anti-SLAPP analysis. The appellate court remanded the case for further proceedings consistent with its opinion. View "LVNV Funding v. Rodriguez" on Justia Law

Plaintiffs, residents of Wisconsin, filed two class action complaints against Experian Information Solutions, Inc. under the Fair Credit Reporting Act (FCRA). They alleged that Experian failed to include a required statement in the "Summary of Rights" portion of their consumer reports, violating 15 U.S.C. § 1681g(c)(2)(D). Plaintiffs sought actual, statutory, and punitive damages. Experian removed the cases to federal court, where Plaintiffs moved to remand, arguing they lacked standing under Article III of the U.S. Constitution because they did not suffer a concrete harm. The federal court agreed and remanded the cases to state court.In state court, Experian moved for judgment on the pleadings, arguing Plaintiffs lacked standing under Wisconsin law and that their FCRA claim did not fall within the statute's "zone of interests." Plaintiffs contended California law should apply and that they had standing under it. The trial court, referencing the recent Limon v. Circle K Stores Inc. decision, which required a concrete injury for standing in California state courts, granted Experian's motion. Plaintiffs appealed, arguing Limon was wrongly decided.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the trial court's decision. The appellate court found Limon persuasive, holding that Plaintiffs lacked standing because they did not allege a concrete or particularized injury. The court noted that under both California and federal law, an informational injury without adverse effects is insufficient to confer standing. Consequently, the judgment in favor of Experian was affirmed. View "Muha v. Experian Information Solutions" on Justia Law

The case involves the People of the State of California, represented by the San Diego City Attorney, who filed a complaint against Kaiser Foundation Health Plan, Inc. The complaint alleged that Kaiser violated the unfair competition law (UCL) and false advertising law (FAL) by failing to maintain and update accurate health plan provider directories (PDs) as required by California Health and Safety Code section 1367.27. The People claimed that Kaiser’s inaccuracies in PDs misled consumers and harmed competitors.The Superior Court of San Diego County granted Kaiser’s motion for summary judgment, exercising its discretion to abstain from adjudicating the action. The court reasoned that the legislative framework did not impose an accuracy requirement but rather outlined procedural steps for maintaining PDs. The court concluded that adjudicating the People’s claims would require it to assume regulatory functions and interfere with policy judgments already made by the Legislature and the Department of Managed Health Care (DMHC).The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case and concluded that the trial court abused its discretion by applying the doctrine of judicial abstention. The appellate court found that section 1367.27 sets forth clear mandates for PD accuracy, which the trial court could enforce through its ordinary judicial functions. The appellate court held that the People’s enforcement of these statutory requirements would not interfere with the DMHC’s regulatory functions and that the trial court’s abstention was based on a mistaken view of the law. Consequently, the appellate court reversed the judgment and remanded the matter with directions to deny Kaiser’s motion for summary judgment. View "P. ex rel. Elliott v. Kaiser Foundation Health Plan" on Justia Law

In November 2014, the plaintiff purchased a recreational vehicle (RV) from a dealership, with the defendant bank financing the purchase. The sales contract inaccurately reflected the downpayment as $19,100 in cash instead of $1,000 in cash and $18,100 in trade-in value. The plaintiff later discovered issues with the RV and filed a lawsuit in February 2017, alleging violations of the Automobile Sales Finance Act (ASFA) due to the incorrect downpayment disclosure.The Superior Court of Fresno County reviewed the case and concluded that the four-year statute of limitations for written contracts applied, rather than the one-year statute for statutory penalties. The court granted summary adjudication in favor of the plaintiff against the dealership for violating the ASFA, and the dealership's liability was extended to the bank under the Federal Trade Commission’s holder rule. The court entered judgment requiring the bank to accept the return of the RV and pay the plaintiff $42,263.64.The California Court of Appeal, Fifth Appellate District, reviewed the case and determined that the rescission and restitution remedy under the ASFA is a penalty. The court concluded that the one-year statute of limitations for actions upon a statute for a penalty or forfeiture applied. The court noted that the ASFA imposes strict liability without regard to actual damages or fault, and the legislative history indicated the remedy was intended as a penalty. Consequently, the appellate court reversed the trial court's decision and remanded the case for further proceedings consistent with its opinion. View "Pompey v. Bank of Stockton" on Justia Law

The case involves a dispute between a taxpayers' association and a water district over the imposition of groundwater replenishment charges. The taxpayers' association alleged that the water district's charges violated constitutional provisions and unfairly benefited large agricultural businesses. The association sought a writ of mandate to stop the collection of these charges and to vacate the resolutions imposing them. They also claimed conversion, civil conspiracy, aiding and abetting, and violations of the Unfair Competition Law (UCL) against the water district's board members, general manager, and consulting firms.The Superior Court of Riverside County denied the defendants' anti-SLAPP motion, which sought to strike several causes of action on the grounds that they arose from protected activities. The court found that the public interest exemption to the anti-SLAPP statute applied. Additionally, the court sustained the defendants' demurrer to the first amended petition and complaint, finding the claims time-barred under the validation statutes. The court also awarded over $180,000 in attorney's fees to the plaintiffs, deeming the anti-SLAPP motion frivolous.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the public interest exemption did not apply because the relief sought could only be provided by the water district, not the individual defendants. The court found that the anti-SLAPP motion should have been granted for most causes of action, except for conversion and the writ of mandate against the general manager. Consequently, the fee award was reversed. The court also affirmed the demurrer ruling, as the claims against the individual defendants were not legally sufficient. The case was remanded for further proceedings consistent with these findings. View "Howard Jarvis Taxpayers Assn. v. Powell" on Justia Law

The plaintiff entered into a lease agreement with the defendant for a new vehicle, which later exhibited multiple defects. Despite several repair attempts, the issues persisted. The plaintiff then filed a lawsuit against the defendant, alleging violations of California’s Song-Beverly Consumer Warranty Act, seeking various forms of relief including replacement or restitution, damages, and attorney fees.The case proceeded to trial in the Los Angeles County Superior Court, where the jury found the defendant liable and awarded the plaintiff damages. However, the jury did not find the defendant’s violation to be willful, thus no civil penalties were awarded. Subsequently, both parties filed motions regarding costs and attorney fees. The trial court ruled in favor of the defendant, limiting the plaintiff to pre-offer costs and attorney fees, and awarding the defendant post-offer costs based on a prior settlement offer under California Code of Civil Procedure section 998.The California Court of Appeal, Second Appellate District, reviewed the case. The court addressed two main issues: whether a section 998 offer consisting of two simultaneous offers is valid, and whether an offer that promises to pay for statutory categories of damages with disputes resolved by a third party is sufficiently certain. The court concluded that simultaneous offers are generally invalid under section 998 due to the uncertainty they create for the trial court in determining whether the judgment is more favorable than the offer. However, since only one of the defendant’s two offers was invalid, the remaining valid offer was operative. The court affirmed the trial court’s decision, holding that the plaintiff was limited to pre-offer costs and attorney fees, and the defendant was entitled to post-offer costs. View "Gorobets v. Jaguar Land Rover North America, LLC" on Justia Law

Kenneth and Janet Lathrop purchased a motorhome from a dealer in California, manufactured by Thor Motor Coach, Inc. They later sued the dealer and Thor under the Song-Beverly Consumers Warranty Act and the Consumer Legal Remedies Act (CLRA), alleging defects in the motorhome and failure to perform necessary repairs. Thor moved to stay the action based on a forum selection clause in its warranty, which designated Indiana as the exclusive forum for disputes and included a jury trial waiver and an Indiana choice-of-law clause. Thor acknowledged these provisions were unenforceable under California law and offered to stipulate that California substantive rights would apply in an Indiana court.The Superior Court of Los Angeles County granted Thor’s motion to stay, finding the forum selection clause mandatory and not unreasonable. The court placed the burden on the Lathrops to show that enforcing the clause was unreasonable. The Lathrops appealed, arguing that the trial court applied the wrong standard and that Thor did not meet its burden to show that litigating in Indiana would not diminish their unwaivable rights under California law.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case and concluded that the trial court erred by placing the burden on the Lathrops instead of Thor. The appellate court held that Thor did not meet its burden to show that litigating in Indiana would not substantially diminish the Lathrops’ rights under the Song-Beverly Act and the CLRA. The court also found that enforcing the forum selection clause based on Thor’s proposed stipulation would violate California public policy and that the stipulation was insufficient to protect the Lathrops’ unwaivable statutory rights. Consequently, the appellate court reversed the trial court’s order granting the motion to stay and directed the trial court to deny the motion. View "Lathrop v. Thor Motor Coach, Inc." on Justia Law

Plaintiffs, who are users of Coinbase's cryptocurrency platform, filed a complaint against Coinbase, Inc. alleging violations of the Consumer Legal Remedies Act (CLRA), the California False Advertising Law (FAL), and the California Unfair Competition Law (UCL). They sought public injunctive relief, claiming Coinbase misrepresented its security features to the public. Coinbase's user agreement, which plaintiffs accepted, included an arbitration clause. Coinbase moved to compel arbitration, arguing the plaintiffs sought private injunctive relief, which is subject to arbitration.The San Francisco Superior Court denied Coinbase’s motion to compel arbitration, finding that the plaintiffs sought public injunctive relief, which is not subject to arbitration under California law. The court noted that the complaint exclusively sought public injunctive relief and did not request any relief that would solely benefit the plaintiffs or existing Coinbase customers. The court also referenced a related federal case, Aggarwal I, where plaintiffs sought individual relief, supporting the conclusion that the current complaint sought public injunctive relief.The California Court of Appeal, First Appellate District, reviewed the case de novo. The court affirmed the trial court’s decision, holding that the plaintiffs’ complaint indeed sought public injunctive relief. The court explained that public injunctive relief under the CLRA, FAL, and UCL is intended to prohibit unlawful acts that threaten future injury to the public, rather than redress individual wrongs. The court found that the plaintiffs’ allegations and requests for relief were aimed at preventing Coinbase from continuing its allegedly deceptive practices, which primarily benefit the public. Consequently, the arbitration provision in Coinbase’s user agreement could not compel arbitration of the plaintiffs’ claims for public injunctive relief. View "Kramer v. Coinbase, Inc." on Justia Law