Justia California Court of Appeals Opinion Summaries

Marlon Quesada, a deputy sheriff with the Los Angeles County Sheriff's Department, was not promoted to sergeant despite taking the sergeant's examination in 2017 and 2019, scoring in band two and band one, respectively. Quesada had a mixed employment record, including two suspensions for misconduct and a 2015 investigation that was terminated due to a statute of limitations. Quesada claimed the Department improperly considered this time-barred investigation during the promotion process, which he argued was illegal.The Superior Court of Los Angeles County denied Quesada's petition for a writ of mandate, which sought to compel the Department to promote him and provide back pay and other damages. The trial court rejected Quesada's argument for a burden-shifting approach, similar to that used in discrimination cases, and found that Quesada did not establish that the Department's decision was illegal.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the trial court's decision, holding that the standard approach to civil litigation applies, where the plaintiff bears the burden of proving the elements of their claim by a preponderance of the evidence. The court declined to adopt a burden-shifting approach, noting that Quesada's case did not involve discrimination based on race or membership in a historically oppressed group. The court also found substantial evidence supporting the Department's decision, including Quesada's mediocre performance evaluations and past misconduct. The court concluded that Quesada's policy arguments did not justify a departure from the standard legal approach. View "Quesada v. County of L.A." on Justia Law

Julian Rodriguez, a former employee of Lawrence Equipment, Inc., filed a lawsuit alleging various wage-and-hour violations under the California Labor Code. Rodriguez claimed that Lawrence failed to pay for all hours worked, including overtime, did not provide adequate meal and rest breaks, issued inaccurate wage statements, and did not pay all due wages upon termination. He also sought civil penalties under the Private Attorneys General Act (PAGA). Rodriguez had signed an arbitration agreement with Lawrence, which led to the arbitration of his non-PAGA claims.The Superior Court of Los Angeles County ordered arbitration for Rodriguez’s wage-and-hour claims and stayed the PAGA claim. The arbitrator ruled in favor of Lawrence, finding that Rodriguez failed to prove any of the alleged Labor Code violations. The trial court confirmed the arbitration award and entered judgment for Lawrence. Subsequently, Lawrence moved for judgment on the pleadings, arguing that the arbitration award precluded Rodriguez from pursuing his PAGA claim due to lack of standing as an aggrieved employee. The trial court granted this motion and dismissed the PAGA claim.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the arbitration award, which found no Labor Code violations, precluded Rodriguez from establishing standing under PAGA. The court applied the doctrine of issue preclusion, determining that the issues litigated in arbitration were identical to those required to establish PAGA standing. Since Rodriguez could not prove any Labor Code violations, he lacked standing to pursue the PAGA claim. The court affirmed the trial court’s judgment of dismissal. View "Rodriguez v. Lawrence Equipment, Inc." on Justia Law

Plaintiffs, former officers of the City of Perris Police Department or their surviving spouses, claimed that the closure of the Perris PD and their subsequent hiring by the Riverside County Sheriff’s Department resulted in a merger of the two departments under Government Code section 20508. They argued that this merger required Riverside County and the Public Employees Retirement System (CalPERS) to credit their service with the Perris PD as service with the Sheriff’s Department, entitling them to a more generous pension.The Superior Court of Riverside County found that section 20508 only applies when there is a merger of contracts between successive employing agencies and CalPERS. The court concluded that no such merger occurred because Riverside County did not assume any of the City’s municipal functions. Consequently, the service pensions for the Perris PD officers and the Sheriff’s Department deputies were calculated and paid out by CalPERS under separate contracts with the City and County, respectively. The court ruled in favor of the defendants, Riverside County and CalPERS.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that section 20508 requires an actual merger of the contracting agencies’ CalPERS contracts before the succeeding agency assumes any statutory obligations. The court found that the County did not assume the City’s municipal obligations but merely contracted to provide law enforcement services. Therefore, the requirements for a contract merger under section 20508 were not met. The court affirmed the trial court’s judgment, concluding that the County and CalPERS were not required to treat the former police officers’ service as service with the Sheriff’s Department. View "Petree v. Public Employees' Retirement System" on Justia Law

Jeannine Bedard, a Los Angeles Police Department (LAPD) officer, refused to comply with the City of Los Angeles’s COVID-19 vaccination mandate and did not sign a notice enforcing the mandate. Consequently, the Chief of Police sought to terminate her employment. The LAPD Board of Rights reviewed the proposed discipline, found Bedard guilty of failing to comply with conditions of employment, and upheld her discharge. The Board also found that the City violated Bedard’s due process rights by not providing sufficient time to respond to the charges and awarded her back pay, which the City did not pay.Bedard filed a petition for a writ of mandate in the Superior Court of Los Angeles County, arguing that the disciplinary action was procedurally and legally invalid and seeking reinstatement and back pay. The trial court found the termination justified but agreed that the City violated Bedard’s due process rights by giving her insufficient time to respond. The court awarded her back pay.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. Bedard argued that her termination was improper because it was based on her refusal to sign an allegedly illegal contract, was too harsh a penalty, and violated her due process rights under Skelly v. State Personnel Board. The appellate court affirmed the trial court’s decision, holding that Bedard’s refusal to comply with the vaccination mandate justified her termination. The court found substantial evidence supporting the trial court’s conclusion that Bedard’s termination was not solely based on her refusal to sign the notice but also on her refusal to comply with the vaccination requirement. The court also held that the appropriate remedy for the due process violation was back pay, not reinstatement. View "Bedard v. City of Los Angeles" on Justia Law

In March 2020, Eva Osborne sued Pleasanton Automotive Company, LOP Automotive Company LP, HAG Automotive Investments LP, and Bob Slap, alleging workplace misconduct including discrimination, retaliation, harassment, and wage violations. Osborne, who worked as Slap’s executive assistant, claimed Slap required her to perform personal tasks without proper compensation. In response, Slap filed a cross-complaint against Osborne in August 2022, alleging libel, slander, and other claims based on statements Osborne made in a letter to HAG’s HR director.The Alameda Superior Court granted Osborne’s special motion to strike Slap’s cross-complaint under California’s anti-SLAPP statute, concluding that Osborne’s statements were protected activity made in anticipation of litigation and were privileged under Civil Code section 47. The court found that Slap could not show his claims had minimal merit because the statements were privileged and he failed to demonstrate malice.The California Court of Appeal for the First Appellate District reviewed the case de novo and affirmed the trial court’s decision. The appellate court agreed that Osborne’s statements were protected under the anti-SLAPP statute and that the litigation privilege barred Slap’s claims. The court found that Osborne’s HR letter was sent in good faith contemplation of litigation, supported by her retention of counsel and subsequent legal actions. The court did not need to address Osborne’s alternative arguments regarding conditional privilege and malice, as the litigation privilege alone was sufficient to affirm the trial court’s ruling. View "Osborne v. Pleasanton Automotive Co., LP" on Justia Law

Terrence Richard, a brakeman for Union Pacific Railroad Company, fell from a train and broke his leg while working. He sued Union Pacific for negligence under the Federal Employers’ Liability Act (FELA). Richard claimed that the locomotive engineer’s mishandling of the train caused a surge that led to his fall. The trial court excluded the testimony of Richard’s expert, Richard Hess, a retired Union Pacific engineer, who would have testified that the engineer’s actions caused the surge. The jury found in favor of Union Pacific, concluding the company was not negligent.The Superior Court of Los Angeles County granted Union Pacific’s motion in limine to exclude Hess’s testimony, reasoning that Hess lacked the necessary qualifications and expertise. Hess had intended to testify that the delay between releasing the train brakes and engaging the throttle caused excessive slack action, leading to a surge at the rear of the train where Richard was working. The trial court’s exclusion of this testimony left Richard without an expert to support his claim of negligent train handling.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case and concluded that the trial court erred in excluding Hess’s testimony. The appellate court found that Hess’s extensive experience as a locomotive engineer qualified him to testify about the train handling practices and the potential dangers of the engineer’s actions. The exclusion of Hess’s testimony was deemed prejudicial because it deprived Richard of critical expert evidence to support his negligence claim. Consequently, the appellate court reversed the judgment for Union Pacific and remanded the matter for a new trial. View "Richard v. Union Pacific Railroad Co." on Justia Law

Blake Wentworth, a former professor at the University of California, Berkeley, sued the Regents of the University of California, alleging violations of the Fair Employment and Housing Act (FEHA) and the Information Practices Act (IPA). Wentworth claimed that the Regents failed to engage in the interactive process, provide reasonable accommodations, and invaded his privacy by leaking information about student complaints and his disability accommodations to the media.The Alameda County Superior Court granted summary adjudication in favor of the Regents on three of Wentworth’s causes of action under FEHA and IPA, denied his motion to compel discovery responses, and denied his request for a retrial on a cause of action for which the jury left the verdict form blank. The court also denied Wentworth’s post-judgment request for attorney’s fees and costs.The California Court of Appeal, First Appellate District, reviewed the case. The court affirmed the summary adjudication on the claims for failure to engage in the interactive process and provide reasonable accommodations, finding that the Regents had offered reasonable accommodations and engaged in the interactive process in good faith. However, the court reversed the summary adjudication of the invasion of privacy cause of action, finding that there were triable issues of fact regarding whether the Regents violated the IPA by leaking a letter about student complaints and disclosing information about Wentworth’s disability accommodation.The court also reversed the trial court’s denial of Wentworth’s motion for attorney’s fees and costs, remanding for further proceedings to determine whether Wentworth was the prevailing party under the IPA and whether he was entitled to fees under the catalyst theory. The court affirmed the trial court’s denial of Wentworth’s motion for a retrial on the personnel file cause of action, finding that Wentworth had forfeited his right to object to the verdict form by failing to raise the issue before the jury was discharged. View "Wentworth v. UC Regents" on Justia Law

The plaintiffs, employees of the State of California providing dental care to inmates, filed a lawsuit seeking compensation for time spent on pre- and post-shift safety and security activities. These activities included going through security and handling alarm devices. The defendants, including the State of California and related departments, filed a demurrer, arguing that these activities were not compensable under the Portal-to-Portal Act of the Fair Labor Standards Act (FLSA). The trial court sustained the demurrer without leave to amend, leading to the plaintiffs' appeal.The trial court ruled that the activities in question were not integral and indispensable to the plaintiffs' principal work of providing dental care, thus not compensable under the FLSA. The plaintiffs argued that the trial court improperly decided a factual question and that their claims were viable. The defendants maintained that the trial court's decision was correct and also argued that the plaintiffs' claims were precluded by the Memorandum of Understanding (MOU) governing their employment, that the relevant statutes did not apply to government employers, that the plaintiffs failed to exhaust contractual remedies, and that the claims were time-barred.The California Court of Appeal, First Appellate District, Division Two, concluded that the trial court erred in not accepting the plaintiffs' allegations as true for the purposes of the demurrer. The appellate court found that the plaintiffs had stated a claim for breach of contract and that the defendants' affirmative defense of failure to exhaust contractual remedies could not be resolved at the demurrer stage. The court also determined that the plaintiffs' contract claim was not time-barred. Consequently, the appellate court affirmed the trial court's decision in part and reversed it in part, allowing the breach of contract claim to proceed. View "Bath v. State" on Justia Law

Sergio Ramirez, a former police officer, was terminated by the City of Indio Police Department following an internal affairs investigation. Ramirez was initially placed on administrative leave after being charged with rape and sexual assault, though he was later acquitted of all criminal charges. Despite the acquittal, the internal investigation concluded that Ramirez had violated several departmental policies, leading to his termination. Ramirez appealed the decision through the administrative appeal process outlined in the Memorandum of Understanding (MOU) between the City and the Indio Police Officers’ Association.The arbitrator, after a full evidentiary hearing, recommended Ramirez's reinstatement with full back pay and benefits. However, the City Manager upheld the termination, citing Ramirez's poor judgment, dishonesty, and conduct unbecoming of an officer. Ramirez then petitioned the Superior Court of Riverside County for a writ of mandate, arguing that the City Manager should have deferred to the arbitrator's findings on the weight and credibility of the evidence. The Superior Court denied the petition, affirming the City Manager's decision.The Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the lower court's judgment. The court held that the MOU clearly vested the City Manager with the final authority to make disciplinary decisions, including the power to reject the arbitrator's advisory findings. The court found that the City Manager had conducted a thorough review of the arbitrator's recommendations and the evidence before making the final decision. The court also concluded that the administrative appeal process provided Ramirez with due process, as it included notice, an opportunity to respond, and a meaningful hearing. The judgment of the Superior Court was affirmed, upholding Ramirez's termination. View "Ramirez v. City of Indio" on Justia Law

A former employee, Liu, sued her employer, Miniso, alleging various employment-related claims, including sexual harassment, sex discrimination, and wage and hour violations. Liu claimed that she faced severe and pervasive harassment and discrimination based on her sexual orientation and gender identity, and that she was misclassified as an exempt employee, leading to unpaid wages and denied breaks. Liu also alleged that she was retaliated against for refusing to participate in illegal practices and for whistleblowing, which led to her constructive termination.The Superior Court of Los Angeles County denied Miniso's motion to compel arbitration of Liu's claims. Miniso argued that Liu's allegations of sexual harassment were insufficient to state a claim and that the arbitration agreement should be enforced for the non-sexual harassment claims. The trial court found that Liu had adequately stated a claim for sexual harassment and, based on the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), ruled that the arbitration agreement was unenforceable for all of Liu's claims.The California Court of Appeal, Second Appellate District, affirmed the trial court's decision. The appellate court held that under the EFAA, if a plaintiff's case includes at least one claim of sexual harassment, the entire case is exempt from arbitration at the plaintiff's election. The court emphasized that the EFAA's language invalidates arbitration agreements with respect to the entire case, not just the sexual harassment claims. This interpretation avoids the inefficiency of having separate proceedings for different claims and aligns with the legislative intent to protect plaintiffs from being compelled into arbitration for sexual harassment disputes. View "Liu v. Miniso Depot CA, Inc." on Justia Law