Justia California Court of Appeals Opinion Summaries

A woman brought a civil lawsuit against her uncle and godfather, alleging years of sexual abuse that began when she was a minor. The defendant was previously convicted in a criminal court for related offenses and was incarcerated. After his conviction, the plaintiff filed the civil suit seeking compensatory and punitive damages for personal injuries resulting from the abuse. The defendant initially had legal representation using personal funds, but those funds became inaccessible due to a blocked account ordered by a family court during concurrent divorce proceedings. When his accessible funds were depleted, the defendant began representing himself. He sought access to the blocked funds to retain new counsel but experienced significant delays in obtaining a family court order to release the money.The Superior Court of Alameda County presided over the civil trial, during which the defendant appeared remotely from prison. Despite repeated requests for continuances to secure counsel after finally gaining access to some funds, the trial court denied these requests. The trial proceeded, and a jury found the defendant liable for several torts, awarding the plaintiff substantial compensatory and punitive damages.Upon appeal, the California Court of Appeal, First Appellate District, Division Four, determined that the trial court abused its discretion and violated the defendant’s constitutional rights by denying his continuance requests, given his indigency, incarceration, and the fundamental right to meaningful access to the courts. The appellate court reversed the judgment and remanded the case for a new trial on all issues, including punitive damages. The court clarified that the plaintiff is entitled to retry all issues. The court did not address other trial errors or the excessiveness of damages due to its disposition. The appellate court also explained that the trial court did not err in admitting school photographs of the plaintiff, which may be relevant upon retrial. View "Mary D. v. McCauley" on Justia Law

Dan Schneider, a television producer known for creating several popular Nickelodeon shows, was featured in a documentary series titled "Quiet on Set: The Dark Side of Kids TV." The series and its trailer explored workplace culture on Schneider’s shows and described incidents of sexual abuse by Nickelodeon employees against child actors. Schneider asserted that through editorial choices, including voiceovers, graphics, and juxtaposed images, the documentary implied he was a child sexual abuser, leading reasonable viewers to draw that false conclusion. He sued multiple parties involved in creating, producing, and distributing the documentary and trailer for defamation.The Superior Court of Los Angeles County reviewed the case after Defendants filed an anti-SLAPP motion to strike Schneider’s defamation claim. The court found that the documentary and trailer were protected speech under California’s anti-SLAPP statute and noted the parties’ agreement on this point. Evaluating whether Schneider’s claim had minimal merit, the court concluded that he had presented substantial evidence to support his theory of implied defamation and denied Defendants’ motion to strike. Defendants appealed this ruling.The Court of Appeal of the State of California, Second Appellate District, Division Three, conducted a de novo review. The court held that neither the documentary nor its trailer were reasonably susceptible to the defamatory implication that Schneider sexually abused children. The court found that the allegedly defamatory elements cited by Schneider, when considered in context, did not permit such an implication and that public internet commentary could not establish reasonable interpretation as a matter of law. As a result, the appellate court reversed the trial court’s order denying the motion to strike and directed the trial court to grant the anti-SLAPP motion, awarding costs to Defendants. View "Schneider v. Warner Bros. Discovery, Inc." on Justia Law

A woman employed as an office support technician sought treatment from an orthopedic surgeon in 2016 for symptoms of carpal tunnel syndrome in her right hand. After conservative treatment failed, the surgeon performed carpal tunnel release surgery in January 2017. Following surgery, the patient continued to experience symptoms such as pain, grip weakness, and functional limitations. Her surgeon repeatedly reassured her that these symptoms were normal and that her healing was progressing as expected. Occupational therapy records indicated improvement, and at the time, both the patient and her doctor attributed any lingering issues to normal recovery or her repetitive work duties.Nearly four years later, in April 2021, the patient consulted a different physician due to worsening symptoms. Diagnostic imaging revealed the ligament that should have been severed during the 2017 surgery remained intact. The new physician explained the possibility of an incomplete release during the prior surgery, and a revision surgery was performed. The patient and her husband then filed a medical malpractice action against the original surgeon and his practice, alleging negligent surgery and delayed diagnosis. The Superior Court of San Diego County granted summary judgment for the defendants, finding the claims barred by the statute of limitations under California Code of Civil Procedure section 340.5, reasoning that the injury had manifested within months after the 2017 surgery.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that there were triable issues of material fact regarding when the plaintiff’s injury became sufficiently appreciable to trigger the statute of limitations. The appellate court concluded that the record supported the plaintiffs’ contention that the injury was not manifest until 2021, and thus summary judgment was improper. The judgment was reversed and the case remanded for further proceedings. View "Godshall v. Peterson" on Justia Law

An employee of an independent contractor was injured after falling through a skylight while working on equipment located on the roof of a warehouse. The warehouse owner had leased roof space and related access to a tenant (Verizon) expressly for the installation and maintenance of communications equipment. The tenant, in turn, hired a general contractor to perform work at the site, who then sent the injured employee to perform the task. The area where the accident occurred was not part of the leased roof section, but the employee accessed it while attempting to complete his assignment. It was undisputed that the general contractor, not the warehouse owner, was responsible for the means, methods, and safety of the work.After the accident, the injured worker brought a lawsuit against both the tenant and the warehouse owner in the Superior Court of Alameda County, asserting claims of negligence and premises liability. The warehouse owner moved for summary judgment, arguing that under the Privette doctrine, which generally shields those who hire independent contractors from liability for workplace injuries, it was not liable. The trial court denied the motion, ruling that because the warehouse owner was a landlord and not the entity that directly hired the independent contractor, the Privette doctrine did not apply. Summary judgment was granted in favor of the tenant on Privette grounds, and the plaintiff did not appeal that ruling.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court held that the Privette doctrine protects not only the party that directly hires an independent contractor but also applies to others in the “chain of delegation,” such as non-hiring landlords whose lease agreements contemplate the use of independent contractors for contracted work. The court directed the trial court to vacate its denial of summary judgment and to enter judgment for the warehouse owner, holding that the Privette doctrine barred the plaintiff’s claims. View "Schurman Family Company TIC v. Super. Ct." on Justia Law

The plaintiff suffered harm as a result of an incident at a Trader Joe’s store. Following a trial in the Superior Court of Stanislaus County, a jury found Trader Joe’s negligent and determined that its negligence was a substantial factor in causing injury to the plaintiff. The jury awarded damages of $23,509,165. After a post-trial motion, the court conditionally granted a new trial unless the plaintiff accepted a reduced award. The plaintiff accepted the remittitur, and an amended judgment was entered for $10,809,165.Trader Joe’s sought to appeal the amended judgment. The deadline to file the notice of appeal was January 20, 2026. On that date, Trader Joe’s submitted its notice of appeal electronically, receiving confirmation of receipt. However, the Superior Court clerk later rejected the filing, citing a local rule and a court website provision that classified notices of appeal as documents that could not be filed electronically. After further attempts, the notice of appeal was eventually accepted and filed on February 17, 2026. The plaintiff then moved to dismiss the appeal as untimely.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case. It held that the local rule and related court website provisions barring e-filing of notices of appeal were inconsistent with state law, particularly California Rules of Court, rule 2.253. As such, the rule was invalid. The court further held that since Trader Joe’s had delivered the notice of appeal to the clerk electronically on the jurisdictional deadline, the notice was timely. The court denied the plaintiff’s motion to dismiss the appeal. View "Gharraee v. Trader Joe's Co." on Justia Law

A patient presented to an emergency department with symptoms of COVID-19. He was examined by a physician, who determined that he was stable and did not exhibit severe symptoms, so she did not prescribe monoclonal antibodies—a treatment option available at the hospital. Instead, the patient was discharged with advice to use over-the-counter medications and to return if his condition worsened. A few days later, his condition deteriorated, and he was readmitted to the hospital, where he ultimately died from complications related to COVID-19.The patient’s survivors filed a negligence lawsuit in the San Bernardino County Superior Court against the treating physician, her medical group, and the hospital. The defendants moved for summary judgment, arguing that the Public Readiness and Emergency Preparedness Act (PREP Act) provided them immunity because their treatment decisions involved allocation of a covered countermeasure (monoclonal antibodies) during a period of constrained supply. The Superior Court denied the motion, finding a triable issue as to whether the physician’s decision not to prescribe the medication fell within the scope of PREP Act immunity, specifically whether it was related to prioritization due to limited supply.On review, the California Court of Appeal, Fourth Appellate District, Division Two, considered whether the PREP Act constituted a complete defense to the alleged liability for not prescribing monoclonal antibodies. The court held that the PREP Act does provide such immunity when failure to administer a covered countermeasure results from a conscious decision to prioritize or allocate it, rather than from mere neglect or lack of decision-making. The court found no triable issue of material fact regarding the physician’s conscious allocation decision and directed the trial court to grant summary judgment in favor of the defendants. View "Nassman v. Super. Ct." on Justia Law

This case involves three individuals who were cast members on a reality television show. The plaintiff was engaged in a secret sexual affair with another cast member, who was the longtime boyfriend of the defendant. The defendant discovered the affair after finding sexually explicit videos of the plaintiff on her boyfriend’s cell phone, which had been recorded without the plaintiff’s knowledge or consent. The defendant then made recordings of these videos and sent them to the plaintiff, along with a confrontational text message. The situation became widely publicized, leading to significant media attention and public scrutiny of the plaintiff.The plaintiff subsequently filed a lawsuit in the Superior Court of Los Angeles County against both the boyfriend and the defendant, alleging claims for “revenge porn” under Civil Code section 1708.85, invasion of privacy, and intentional infliction of emotional distress. The complaint alleged that the defendant accessed the boyfriend’s phone without authorization, made copies of the explicit videos, and disseminated them to others, resulting in harm to the plaintiff. The defendant responded by filing a special motion to strike under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16), arguing that her actions were protected as speech on a matter of public interest. The trial court denied the motion, finding that the claims arose from private conduct, not protected activity.On appeal, the California Court of Appeal, Second Appellate District, Division Eight, reviewed the order denying the special motion to strike de novo. The court held that the defendant failed to meet her burden of showing that the plaintiff’s claims arose from constitutionally protected activity under section 425.16. Specifically, the court concluded that the alleged acquisition and dissemination of the private videos did not constitute conduct in connection with a public issue or an issue of public interest. The order denying the special motion to strike was affirmed. View "Leviss v. Madix" on Justia Law

A woman employed as an office support technician with the FBI underwent carpal tunnel surgery on her right hand in January 2017, performed by an orthopedic surgeon. After the surgery, she continued to experience symptoms such as numbness, pain, and decreased grip strength. Her physician reassured her that these ongoing symptoms were normal and that she was healing well. She continued therapy and work with certain restrictions but did not realize the surgery might have been unsuccessful until 2021, when another physician diagnosed her with an incomplete release of her transverse carpal ligament during the original surgery. She subsequently underwent a corrective surgery.The Superior Court of San Diego County granted summary judgment in favor of the surgeon and his medical group, finding the plaintiff’s claims barred by the statute of limitations under California Code of Civil Procedure section 340.5. The court reasoned that her postoperative symptoms in 2017 were sufficient to trigger the three-year limitations period, which had expired before she filed suit in July 2022. The plaintiff appealed, arguing there were triable issues of fact regarding when she knew or should have known of the alleged injury and its negligent cause.The California Court of Appeal, Fourth Appellate District, Division One, reversed the summary judgment. The Court of Appeal held that triable issues of material fact remained as to when the plaintiff’s injury became sufficiently appreciable to trigger the statute of limitations and when she knew or, in the exercise of reasonable diligence, should have known the cause of her injury was the 2017 surgery. The court concluded that summary judgment was improper because reasonable minds could differ on when the statute began to run. The judgment was reversed, and costs on appeal were awarded to the appellants. View "Godshall v. Peterson" on Justia Law

A student attended high school within a public school district from 1998 to 2001. While she was a minor, a teacher employed by the district sexually assaulted her on several occasions. The assaults occurred off campus, but the teacher was able to take the student off school grounds after sanctioned activities, with no apparent measures in place by the district to prevent such conduct. The student later reported the incidents, resulting in the teacher’s criminal conviction and termination from employment. Years later, the student filed a civil suit against the district, alleging that it was negligent in supervising and protecting her while she was at school.In the Superior Court of San Bernardino County, the district moved for summary judgment, arguing it was immune from liability under Education Code section 44808 because the assaults happened off campus. The student countered that immunity does not apply when on-campus negligence leads to off-campus injury, pointing to the teacher’s ability to escort her from school without intervention as evidence of negligent supervision. The superior court denied summary judgment, finding a triable issue existed as to whether the district’s on-campus negligence proximately caused the off-campus harm.Upon petition for extraordinary writ, the California Court of Appeal, Fourth Appellate District, Division Two, reviewed the matter. The appellate court held that the location of the alleged negligent act, not the situs of the injury, is the key factor under Education Code section 44808. It concluded that school districts are not immune from liability for off-campus injuries if their negligence occurred on school property and proximately caused the injury, following the rule articulated in Hoyem v. Manhattan Beach City School District. The writ petition was denied, and the trial court’s decision was left in place. View "Victor Valley Union High Sch. Dist. v. Superior Court" on Justia Law

After being involuntarily detained for 72 hours under California Welfare and Institutions Code section 5150 due to a diagnosis of bipolar disorder and concerns about his safety, Anthony Sgaraglino was discharged from the psychiatric unit at Ventura County Medical Center. The attending physician determined that Anthony did not meet the criteria for an extended hold under section 5250. Despite his family’s warnings that he was suicidal and their efforts to continue his commitment, Anthony was released without medication. He died by suicide the following day.Anthony’s parents, Franklin and Linda Sgaraglino, filed a wrongful death lawsuit against the County of Ventura in the Superior Court of Ventura County, alleging general negligence based on the hospital’s decision to discharge Anthony without medication and despite warning signs. The County moved for summary judgment, arguing it was immune from liability under Welfare and Institutions Code section 5113. The trial court agreed, granting summary judgment in favor of the County. The court found that section 5113 provided immunity for decisions related to the release of psychiatric patients, and rejected the argument that the immunity did not extend to claims of gross negligence. The court also deemed the facts in the County’s separate statement as undisputed because the plaintiffs failed to file a responsive statement.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. It affirmed the trial court’s decision, holding that section 5113 immunizes psychiatric treatment facilities and their operators from both civil and criminal liability for actions taken by a person released at or before the end of an involuntary commitment period. The Court also held that this immunity applies even where claims are framed as gross negligence and that new theories of liability not raised below could not be considered on appeal. Judgment was affirmed. View "Sgaraglino v. County of Ventura" on Justia Law