Justia California Court of Appeals Opinion Summaries

In the case of Planning and Conservation League et al., v. Department of Water Resources heard in the California Court of Appeal, Third Appellate District, the court considered whether the Department of Water Resources’ (department) approval of amendments to long-term contracts with local government agencies that receive water through the State Water Project violated various laws. The amendments extended the contracts to 2085 and expanded the facilities listed as eligible for revenue bond financing. Several conservation groups and public agencies challenged the amendments, arguing they violated the California Environmental Quality Act (CEQA), the Sacramento-San Joaquin Delta Reform Act (Delta Reform Act), and the public trust doctrine. However, the court held that the department did not violate CEQA, the Delta Reform Act, or the public trust doctrine, and therefore affirmed the trial court's judgment in favor of the department. The court found that the department used the correct baseline for its environmental impact report (EIR), properly segmented the amendments from related projects, and adequately considered the direct, indirect, and cumulative impacts of the amendments. The court also held that the department adequately described the project and considered a reasonable range of alternatives, and that recirculation of the EIR was not required. The court rejected arguments that the amendments violated the Delta Reform Act or the public trust doctrine, finding that they did not impact "water that is imbued with the public trust." The court concluded that the department acted within its authority in approving and executing the amendments. View "Planning and Conservation League v. Dept. of Water Resources" on Justia Law

In the case of Joshua Zamora Gonzales v. California Victim Compensation Board, the Court of Appeal of the State of California Second Appellate District Division Two affirmed a lower court ruling that upheld the California Victim Compensation Board's denial of compensation to Gonzales. Gonzales was previously convicted of a gang-related shooting but had his convictions overturned by the United States Court of Appeals for the Ninth Circuit due to insufficiency of evidence. Subsequently, he applied for compensation for the time he was wrongfully imprisoned. The Board denied his claim, finding that he failed to prove his factual innocence by a preponderance of the evidence. Gonzales then filed a petition for a writ of administrative mandamus, which was denied by the lower court. Upon appeal, the appellate court upheld the lower court's decision, concluding substantial evidence supported the Board's ruling that Gonzales failed to establish his factual innocence. View "Gonzales v. California Victim Compensation Bd." on Justia Law

In the case brought before the Court of Appeal of the State of California, First Appellate District, Division Three, the petitioners, First Amendment Coalition and KQED Inc., sought public access to certain records in the possession of the Attorney General and the Department of Justice, relating to peace officers and custodial officers. The records primarily pertained to instances of use of force, discharge of firearms, and sustained findings of dishonesty or sexual assault by an officer, which were considered nonconfidential under section 832.7(b) of the Penal Code.However, the Department withheld certain records citing exemptions under the California Public Records Act (CPRA) due to other state laws prohibiting their disclosure. The petitioners filed a motion for judgment compelling disclosure of these withheld documents but were denied by the trial court.The court, applying rules of statutory construction, concluded that section 832.7(b) of the Penal Code supersedes state law disclosure exemptions that conflict with its decree that records within its scope are not confidential and shall be made available to the public. As such, the court ordered a directive for the respondent court to vacate its judgment to the extent it denies the petitioners’ motion for judgment based on Government Code section 11183, which prohibits the disclosure of subpoenaed records. In all other respects, the petition for writ of mandate was denied. View "First Amendment Coalition v. Super. Ct." on Justia Law

In a case before the Court of Appeal of the State of California, the appellants, Stephon Anthony, Rafael Campbell, Samuel Flowers, and Anthony B. Price, were seeking relief from their first degree murder convictions on multiple grounds. The court found that the trial court was entitled to consider the jury's intent-to-kill findings at the prima facie stage, but that these findings did not preclude relief as a matter of law. The case was remanded for an evidentiary hearing under section 1172.6 of the Penal Code. Furthermore, the court agreed with the People that recent amendment of the gang statutes requires retrial or resentencing on gang-related special-circumstance and enhancement allegations. The court also ordered a remand to strike the multiple-murder special circumstance for Campbell, Flowers, and Price, and to reconsider sentencing on their Vehicle Code convictions in light of recent legislative changes. The court affirmed the trial court's decision not to strike the enhancements and prior strikes. View "P. v. Campbell" 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 this case, an accident occurred where Sara Spagnolini, a provider under the In-Home Supportive Services (IHSS) program, ran a stop sign and crashed into a car driven by Hanah Keren Samson Yalung. Yalung and four of her five children were seriously injured, and one child was killed. Yalung, individually and as an administrator of her deceased daughter's estate and guardian ad litem for her other children, sued the State of California, among others, for Spagnolini's negligence.The plaintiffs argued that the State was liable for Spagnolini's negligence as her employer or as a joint employer with Spagnolini's recipient under the IHSS program. The Superior Court of Tulare County, however, sustained the State's demurrer to the first amended complaint without leave to amend. The trial court did not find the statutory scheme made the State the employer or joint employer of IHSS providers for all purposes, noting that no cases held the State was an employer for purposes of vicarious liability.On appeal, the Court of Appeal of the State of California Fifth Appellate District affirmed the trial court's decision. The appellate court concluded that the IHSS statutes are incompatible with a finding of joint employment as a matter of law. The court found that while the State administers the IHSS program and has some oversight responsibilities, it does not control or direct the day-to-day tasks or activities of IHSS providers. Accordingly, the State could not be deemed an employer or joint employer for the purposes of vicarious liability. View "Yalung v. State of California" on Justia Law

This case involves a dispute over a tariff adopted by the Public Utilities Commission (Commission) of the State of California that affects the compensation utilities provide to customers for excess electricity generated by renewable energy systems. The tariff, known as the net energy metering (NEM) tariff, previously required utilities to purchase excess electricity from renewable systems at the same price customers pay for electricity. However, utilities complained that this overcompensated the owners of renewable systems and raised the cost of electricity for customers without renewable systems. In response, the California Legislature enacted a law requiring the Commission to adopt a successor tariff that promotes the continued sustainable growth of renewable power generation while balancing costs and benefits to all customers.Several environmental groups challenged the Commission's newly adopted successor tariff, asserting that it did not comply with various statutory requirements. The Court of Appeal of the State of California First Appellate District upheld the Commission's tariff. The court found that the Commission's successor tariff adequately served the various objectives of the law and was based on a reasonable interpretation of its statutory mandate. The court also found that the Commission's decision to value exported energy from renewable systems based on the marginal cost of energy to the utilities was a reasonable approach to fulfilling the law's requirement to balance the equities among all customers. The court rejected the plaintiffs' arguments that the Commission had failed to properly account for the costs and benefits of renewable energy, and that it had improperly favored the interests of utility customers who do not own renewable systems. The court also found that the Commission had properly fulfilled the law's requirement to include specific alternatives designed for growth among residential customers in disadvantaged communities. The court affirmed the decision of the Commission. View "Center for Biological Diversity v. Public Utilities Com." on Justia Law

The Zurich American Insurance Company sought a writ of mandate against the Workers’ Compensation Appeals Board (WCAB) and the California Insurance Guarantee Association (CIGA), in the Court of Appeal of the State of California. The issue at hand involved the interpretation of Labor Code section 5909, which states that if the WCAB does not act on a party’s petition for reconsideration of a decision by the workers’ compensation judge within 60 days, the petition is “deemed to have been denied.” CIGA filed a petition for reconsideration more than nine months past the filing date. The WCAB justified its late decision on the basis of an “administrative irregularity” that delayed CIGA’s petition. Zurich argued that the petition had already been denied by operation of law under section 5909. The Court of Appeal agreed with Zurich and held that the language and purpose of section 5909 showed a clear legislative intent to terminate the WCAB’s jurisdiction to consider a petition for reconsideration after the 60 days have passed. As a result, decisions on the petition made after that date are void as they exceed the agency’s jurisdiction. The Court of Appeal granted the writ of mandate, directing the WCAB to rescind its order granting CIGA’s petition for reconsideration and dismissing Zurich as a party defendant from the proceeding. View "Zurich Am. Ins. Co. v. Workers' Comp. App. Bd." on Justia Law

This case is a labor dispute between Palomar Health, a public healthcare district, and unions representing nurses and healthcare workers employed by Palomar Health. In 2021, during negotiations to renew their collective bargaining agreements, union organizers began a leafletting campaign outside Palomar Health’s main hospital and sought to meet with employees inside the hospital. Palomar Health responded by filing a complaint for trespass and unlawful picketing in San Diego Superior Court, seeking to ban the organizers from their facilities. The unions filed an unfair practice charge with the Public Employment Relations Board (PERB), asserting Palomar Health’s attempts to ban their representatives and the civil lawsuit violated the unions’ rights under the Meyers-Milias-Brown Act. The trial court overruled the unions’ demurrer and denied their motion to strike, maintaining jurisdiction of the state law claims. On appeal, the unions argued that the trial court lacked jurisdiction over the dispute as their activities were arguably protected by the Meyers-Milias-Brown Act and that jurisdiction fell exclusively under PERB. The Court of Appeal, Fourth Appellate District Division One State of California, agreed with the unions, finding that Palomar Health’s claims were preempted and therefore, the trial court lacked jurisdiction over the dispute. The trial court’s order overruling the demurrer was reversed and the matter was remanded with directions to enter an order sustaining the demurrer without leave to amend, and to dismiss the case on the grounds that it is subject to the exclusive jurisdiction of PERB. View "Palomar Health v. Nat. Nurses United" on Justia Law

The case concerns Junaid Manzoor, who pleaded guilty in 2006 to a felony violation of attempting to distribute harmful material to a minor. As a result of his conviction, he was required to register as a sex offender for life under former section 290 of the Penal Code. Almost 14 years later, the trial court granted his petition to reduce his conviction from a felony to a misdemeanor pursuant to section 17, subdivision (b) of the Penal Code. After the Legislature amended section 290 to provide for a tiered system of registration time periods, Manzoor filed a petition for relief from the registration requirements. The court summarily denied his petition. On appeal, Manzoor argued that due to the amendments to section 290, he was entitled to relief from the registration requirements because the reduction of his felony conviction to a misdemeanor placed him in "tier one" under the statute. The Court of Appeal of the State of California First Appellate District affirmed the trial court's order denying Manzoor's petition for relief. The court held that the reduction of Manzoor’s felony conviction to a misdemeanor did not qualify him for relief from the registration requirements, because subdivision (e) of section 17 of the Penal Code bars courts from granting such relief when the defendant was found guilty of an offense for which lifetime registration is required, and the amendments to section 290 do not reflect a legislative intent to create an exception to this rule. View "People v. Manzoor" on Justia Law