Justia California Court of Appeals Opinion Summaries

The Los Angeles College Faculty Guild, AFT Local 1521, sought to reverse the trial court’s denial of its motion to compel arbitration of three grievances against the Los Angeles Community College District. The grievances involved safety-related construction projects at Los Angeles City College, the termination of a faculty member at Pierce College, and the miscalculation of retirement benefits for a faculty member at Los Angeles Trade-Technical College.The Superior Court of Los Angeles County partially granted the motion to compel arbitration for the grievance related to backpay for the retirement benefits issue but denied the motion for the other grievances. The court found that the grievances were beyond the scope of the collective bargaining agreement and were preempted by the Education Code and other statutory requirements.The Court of Appeal of the State of California, Second Appellate District, Division Eight, affirmed the trial court’s decision. The appellate court held that the grievances related to construction projects and employment termination were not arbitrable because they were preempted by the Education Code and the Construction Bonds Act. The court also found that the grievance related to retirement benefits was partially arbitrable only concerning the backpay issue, as the Public Employees’ Retirement Law governed the reporting of service credits to CalPERS, and the arbitrator could not order injunctive relief beyond the scope of the collective bargaining agreement.The appellate court concluded that the Guild failed to demonstrate that the grievances were within the scope of representation as enumerated by the Educational Employment Relations Act and affirmed the trial court’s mixed ruling. View "L.A. College Faculty Guild v. L.A. Community College District" on Justia Law

Javier Hernandez, a farm laborer employed by Ceja Reyes, Inc., was injured in a vanpool accident while commuting home from work. Hernandez did not have a driver's license or own a car, and he used a vanpool arranged by another employee, paying $10 per day for the service. The vanpool was not provided by Ceja Reyes, and the driver at the time of the accident did not have a valid California driver's license. Hernandez sustained catastrophic injuries, including a right leg amputation, and filed a workers' compensation claim.A workers' compensation judge initially heard the case and concluded that Hernandez's claim was not barred by the going and coming rule, applying the special risk and dual purpose exceptions. Zenith Insurance Company, Ceja Reyes's workers' compensation insurer, denied the claim and filed a petition for reconsideration. The Workers' Compensation Appeals Board (the Board) denied the petition and adopted the judge's report, leading Zenith to file a petition for writ of review with the California Court of Appeal, Third Appellate District.The California Court of Appeal reviewed the case and determined that the Board's application of the special risk and dual purpose exceptions was erroneous. The court found that the special risk exception did not apply because the injury did not occur just outside the employer's premises and there was no relationship between the risk and the location of the premises or conditions over which the employer had control. Additionally, the dual purpose exception was deemed inapplicable as the commute did not provide an incidental benefit to the employer beyond the normal need for the employee's presence at work. Consequently, the court annulled the Board's order and remanded the case for further proceedings consistent with its opinion. View "Zenith Insurance Co. v. Workers' Comp. Appeals Bd." on Justia Law

The plaintiff filed a class action lawsuit against the defendants, alleging various wage and hour violations. The plaintiff sought class certification, which the trial court denied. The plaintiff's individual claims and representative claims under the Private Attorney General Act (PAGA) remained pending. The plaintiff appealed the denial of class certification, arguing it was appealable under the death knell doctrine, which allows immediate appeal of orders effectively terminating class claims.The Superior Court of San Bernardino County denied the plaintiff's motion for class certification, finding issues with the numerosity of subclasses, lack of typicality, predominance of individual inquiries, manageability, and superiority of class adjudication. The court noted that the PAGA claims were not subject to class certification and remained pending. The plaintiff filed a notice of appeal, asserting the order was immediately appealable under the death knell doctrine.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court concluded that the death knell doctrine did not apply because the PAGA claims were still pending when the notice of appeal was filed. The plaintiff's subsequent voluntary dismissal of the PAGA claims without prejudice did not retroactively make the class certification order appealable. The court held that the order denying class certification was not immediately appealable and dismissed the appeal for lack of jurisdiction. The court emphasized that any appeal of the class certification order must await the entry of a final judgment disposing of all claims. View "Reyes v. Hi-Grade Materials Co." on Justia Law

Pablo Arredondo Padron was hired by Hugo Osoy to install two skylights in Osoy’s home. The project was agreed to take 10 to 12 days, equating to 80 to 96 hours of work. Padron fell from a ladder and was injured before completing the project. He subsequently sued Osoy for negligence, premises liability, and breach of specific Labor Code sections, alleging that his work was part of a larger remodeling project and that Osoy was at fault for the accident.The Superior Court of Los Angeles County granted summary judgment in favor of Osoy, finding that Padron’s claims were exclusively covered by workers’ compensation. The court determined that Padron was a residential employee under Labor Code section 3351(d) and did not fall within the exclusion from workers’ compensation coverage set forth in section 3352(a)(8)(A), as he had contracted to work for more than 52 hours. The court also rejected Padron’s arguments that he could sue in tort under section 3706 due to Osoy’s alleged failure to secure workers’ compensation insurance.The California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s judgment. The appellate court held that Padron was not excluded from workers’ compensation coverage under section 3352(a)(8)(A) because he had contracted to work for more than 52 hours, regardless of the actual hours worked before his injury. The court also found that Osoy had secured workers’ compensation insurance as required by law, and thus, Padron could not pursue tort remedies under section 3706. The court concluded that Padron’s exclusive remedy was within the workers’ compensation system. View "Padron v. Osoy" on Justia Law

Christina DeBenedetti and Morgan Ensburg were involved in a marital dissolution case where the trial court assigned four of Morgan’s ERISA-governed retirement accounts to Christina through Qualified Domestic Relations Orders (QDROs). This assignment was to satisfy an award made against Morgan after the court found he breached his fiduciary duty to Christina, resulting in a loss of community property. The total amount ordered for reimbursement and attorney fees exceeded $2 million.The Superior Court of San Diego County initially issued QDROs dividing the community property interests in Morgan’s retirement accounts. After a trial on reserved financial disputes, the court found Morgan had mismanaged community property and awarded Christina $1,831,250 for her share of the lost assets and $230,000 in attorney fees. Christina later sought to enforce this award through new QDROs, which the trial court granted, assigning her 100% of Morgan’s remaining interests in the retirement plans.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. Morgan argued that the QDROs did not relate to “marital property rights” and violated ERISA’s purpose of protecting retirement income. He also claimed the QDROs were invalid under California law and that the trial court did not value the retirement accounts. The appellate court rejected Morgan’s contentions, holding that the QDROs related to marital property rights, complied with ERISA, and that California laws cited by Morgan were either preempted by ERISA or did not invalidate the orders. The court also found that Morgan’s argument regarding the valuation of the retirement accounts was not raised in the trial court and could not be considered on appeal. The appellate court affirmed the trial court’s orders. View "In re Marriage of DeBenedetti" on Justia Law

A former employee, Corbin Williams, worked as an insurance adjuster for Alacrity Solutions Group, LLC, from 2014 until January 2022. Williams typically worked 84-hour weeks but was not paid overtime, violating the Labor Code. In March 2023, over a year after his employment ended, Williams notified the California Labor & Workforce Development Agency of his intent to pursue a PAGA action for these violations. He then filed a lawsuit seeking civil penalties on behalf of other current and former employees but not on his own behalf.The Superior Court of Los Angeles County sustained a demurrer to Williams's complaint without leave to amend, finding the action time-barred. The court noted that Williams had not suffered any Labor Code violations within the one-year statute of limitations period before notifying the Agency, as his employment ended in January 2022. Consequently, the court did not address the defendant's alternative argument regarding Williams's standing.The California Court of Appeal, Second Appellate District, Division Five, affirmed the lower court's decision. The court held that to be a PAGA plaintiff, an individual must have a timely individual claim for at least one Labor Code violation. Since Williams's individual claims were time-barred, he could not satisfy this requirement. The court rejected Williams's arguments that other aggrieved employees' timely claims could substitute for his own untimely claims and that the continuous accrual doctrine applied. The court also found no abuse of discretion in denying leave to amend, as Williams's proposed amendments would not cure the timeliness defect. View "Williams v. Alacrity Solutions Grp." on Justia Law

Plaintiffs, former employees of Vicar Operating, Inc., filed a class action lawsuit alleging that Vicar failed to provide the required meal periods as mandated by California Labor Code section 512 and IWC Wage Orders Nos. 4-2001 and 5-2001. Vicar contended that the plaintiffs had signed valid written agreements prospectively waiving their meal periods for shifts between five and six hours, which could be revoked at any time. The plaintiffs argued that such prospective waivers allowed employers to circumvent statutory meal break requirements and denied employees a meaningful opportunity to exercise their right to meal breaks.The Superior Court of Los Angeles County granted summary adjudication in favor of Vicar, determining that the prospective waivers were valid under section 512 and the wage orders. The court found that the plain language of the statute and wage orders permitted such waivers and distinguished the case from Brinker Restaurant Corp. v. Superior Court, which did not address the timing of meal break waivers. The court also concluded that a DLSE opinion letter cited by the plaintiffs was not applicable as it interpreted different wage order regulations.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case and affirmed the lower court's decision. The appellate court held that the revocable, prospective waivers signed by the plaintiffs were enforceable in the absence of any evidence that the waivers were unconscionable or unduly coercive. The court concluded that the prospective written waiver of a 30-minute meal period for shifts between five and six hours was consistent with the text and purpose of section 512 and Wage Order Nos. 4 and 5. The court also determined that the legislative and administrative history confirmed that such waivers were consistent with the welfare of employees and that Brinker did not require a contrary result. View "Bradsbery v. Vicar Operating, Inc." on Justia Law

Pablo Arredondo Padron was hired by Hugo Osoy to install two skylights in Osoy’s home. The project was expected to take 10 to 12 days, with Padron working eight hours each day. However, Padron fell from a ladder and was injured before completing 52 hours of work. Padron sued Osoy for negligence, but the trial court granted summary judgment in favor of Osoy, finding that Padron’s claims were exclusively covered by workers’ compensation.The Superior Court of Los Angeles County ruled that Padron’s employment was covered by workers’ compensation under Labor Code section 3351(d), which includes individuals employed by homeowners for duties incidental to the ownership, maintenance, or use of the dwelling. The court also found that Padron did not fall under the exclusion in section 3352(a)(8)(A), which excludes workers employed for less than 52 hours in the 90 days preceding the injury, because Padron had contracted to work for more than 52 hours.The California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s decision. The appellate court held that the exclusion in section 3352(a)(8)(A) does not apply when the employment is contracted to be for more than 52 hours, regardless of the actual hours worked before the injury. The court also rejected Padron’s arguments that he was not subject to the workers’ compensation system and that Osoy should be estopped from asserting the exclusivity defense. The court concluded that Osoy had secured workers’ compensation coverage through his homeowners’ insurance policy, which included the required coverage by operation of law. Therefore, Padron’s exclusive remedy was under the workers’ compensation system, and the summary judgment in favor of Osoy was affirmed. View "Padron v. Osoy" on Justia Law

Billy Ford worked as a full-time security guard for Parkwest Casino Lotus from September 2018 to December 2021. Upon hiring, Ford signed an arbitration agreement that excluded claims for workers' compensation, unemployment compensation, certain administrative complaints, ERISA claims, and "representative claims under [PAGA]." In February 2022, Ford filed a complaint against Parkwest under PAGA, alleging Labor Code violations, including mandatory off-the-clock health screenings and inaccurate wage statements. Parkwest moved to compel arbitration of Ford's individual PAGA claims and to dismiss the representative PAGA claims, citing Viking River Cruises, Inc. v. Moriana.The Superior Court of Sacramento County denied Parkwest's motion to compel arbitration, finding that the arbitration agreement specifically excluded all PAGA claims. Parkwest appealed, arguing that the agreement was ambiguous regarding the exclusion of individual PAGA claims and that such ambiguity should be resolved in favor of arbitration.The Court of Appeal of the State of California, Third Appellate District, reviewed the case. The court concluded that the arbitration agreement unambiguously excluded all PAGA claims, including individual claims. The court reasoned that the language of the agreement and the circumstances under which it was executed indicated that the parties intended to exclude all PAGA claims from arbitration. The court affirmed the trial court's order denying Parkwest's motion to compel arbitration. View "Ford v. The Silver F" on Justia Law

In this case, the plaintiff, a tenured professor at a community college, filed a complaint alleging sexual harassment, retaliation, and related claims against the Los Angeles Community College District and a vice president of student services. The alleged harassment occurred over an eight-month period in 2017, during which the vice president made inappropriate comments and advances towards the plaintiff. The plaintiff also claimed retaliation when she did not comply with his demands, including attempts to move her program and firing her staff.The Superior Court of Los Angeles County presided over the trial, where a jury awarded the plaintiff $10 million in noneconomic damages. The defendants filed motions for a new trial and partial judgment notwithstanding the verdict, citing prejudicial errors in the admission of evidence and excessive damages. These motions were denied by the trial judge, who made inappropriate and irrelevant comments during the post-trial hearing, leading to his disqualification for cause.The California Court of Appeal, Second Appellate District, reviewed the case and found significant errors in the trial court's evidentiary rulings. The appellate court determined that the admission of 20-year-old newspaper articles and evidence of the vice president's misdemeanor convictions were prejudicial and irrelevant. Additionally, the testimony of a student who had filed a separate harassment complaint against a different administrator was improperly admitted, as it was not closely related to the plaintiff's circumstances and theory of the case.The appellate court concluded that these errors, combined with the excessive damages awarded, warranted a new trial. The judgment was reversed, and the case was remanded for a new trial. The defendants were awarded costs on appeal. View "Odom v. L.A. Community College Dist." on Justia Law