Justia California Court of Appeals Opinion Summaries

In November 2014, Andre Pompey purchased a recreational vehicle (RV) from a dealership, with financing provided by the Bank of Stockton. Pompey later sued the dealership and the Bank, alleging that the retail installment sales contract did not include required disclosures under the Automobile Sales Finance Act (ASFA). Specifically, the contract failed to itemize the downpayment, showing $19,100 as a cash payment instead of $1,000 in cash and $18,100 in trade-in value. Pompey sought rescission of the contract and restitution of the amounts paid.The Superior Court of Fresno County ruled in favor of Pompey, concluding 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 for Pompey against the dealership on the ASFA violation and, by stipulation, applied the judgment to the Bank under the Federal Trade Commission’s holder rule. The Bank appealed, arguing that the one-year statute of limitations for penalties should apply.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court determined that the rescission and restitution remedy under the ASFA is a penalty because it is imposed without regard to fault or actual damages and significantly limits the court's discretion. The court noted that the legislative history of the ASFA indicated it was intended to be a penalty. Consequently, the court concluded that the one-year statute of limitations for statutory penalties under Code of Civil Procedure section 340 applies. The court reversed the trial court's decision and remanded the case for further proceedings consistent with this opinion. View "Pompey v. Bank of Stockton" on Justia Law

A.D. Improvements, Inc. (ADI) leased property from the California Department of Transportation (Caltrans) and sought to purchase it under Streets and Highways Code section 118.1, which mandates that Caltrans offer to sell commercial real property deemed excess to the current occupant at fair market value. ADI used the property commercially and applied to purchase it after Caltrans designated it as excess. However, Caltrans denied the application, arguing that the property was not commercial when initially acquired. The trial court agreed with Caltrans and denied ADI's petition for a writ of mandate.The Superior Court of San Bernardino County found that ADI met the conditions of section 118.1, including leasing, occupying, and improving the property. However, it ruled that the statute applied only to property that was commercial when acquired by Caltrans, interpreting "acquired" as a past-tense verb.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case de novo. The court determined that the plain and contextual reading of section 118.1 requires the property to be commercial at the time it is deemed excess, not when it was acquired. The court found that the statute's language, legislative history, and Caltrans' own manuals support this interpretation. Consequently, the court reversed the trial court's decision and remanded the case with directions to issue a writ requiring Caltrans to offer to sell the property to ADI at fair market value. The court held that ADI is entitled to its costs on appeal. View "A.D. Improvements v. Dept. of Transportation" on Justia Law

The case involves the Santa Clarita Organization for Planning the Environment and Advocates for the Environment (collectively, SCOPE) challenging the County of Los Angeles and Williams Homes, Inc. (Williams) over the approval of a residential housing development project in the Santa Clarita Valley. SCOPE's lawsuit contested the County's approval of a conditional use permit, an oak tree permit, and a vesting tentative tract map, alleging violations of the Subdivision Map Act (SMA) and the California Environmental Quality Act (CEQA).The Superior Court of Los Angeles County granted Williams's motion for judgment on the pleadings without leave to amend, finding that SCOPE's claims were barred under Government Code section 66499.37 of the SMA because SCOPE failed to serve a summons within 90 days of the County's approval of the vesting tentative tract map. The court concluded that section 66499.37 applied to both the SMA and CEQA causes of action, as the CEQA claims were intertwined with the SMA claims.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court held that section 66499.37 does not bar SCOPE's CEQA claims to the extent they allege procedural violations of CEQA and the County's failure to analyze and disclose the project's environmental impacts, as these claims are unique to CEQA and could not have been brought under the SMA. However, the court found that section 66499.37 does apply to SCOPE's CEQA claims challenging the reasonableness of the conditions of approval of the vesting tentative tract map, specifically the mitigation measures adopted as a condition of approval.The Court of Appeal reversed the judgment and remanded the case, directing the trial court to enter a new order denying the motion for judgment on the pleadings with respect to the first cause of action for violation of CEQA and granting the motion with respect to the second cause of action for violation of the SMA and zoning and planning law. View "Santa Clarita Organization for Planning the Environment v. County of Los Angeles" on Justia Law

The People of the State of California, represented by the San Diego City Attorney, filed a complaint against Kaiser Foundation Health Plan, Inc. alleging violations of the unfair competition law (UCL) and false advertising law (FAL). The complaint claimed that Kaiser failed to maintain and update accurate health plan provider directories (PDs) as required by California Health and Safety Code section 1367.27, among other statutes. The inaccuracies in the PDs allegedly harmed consumers and 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 concluded that the legislative framework did not impose an accuracy requirement on PDs and that adjudicating the case would require the court to assume the role of a regulator, which is better suited for 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 does impose clear mandates for PD accuracy, which the trial court can enforce through its ordinary judicial functions. The appellate court also determined that the People’s enforcement of section 1367.27 through a UCL cause of action is complementary to the DMHC’s regulatory authority and does not interfere with it. The appellate court reversed the judgment and remanded the matter with directions to the trial court to vacate its order granting Kaiser’s motion for summary judgment and to issue a new order denying the motion. View "People ex rel. Elliott v. Kaiser Foundation Health Plan" on Justia Law

In 2006, William Jay Price was admitted to the State Department of State Hospitals as a sexually violent predator. In 2022, the superior court found Price suitable for conditional release. However, before placing him in the community, the court reconsidered its order, held a new hearing, and found him unsuitable for release. Price argued that the superior court erred by denying him the assistance of experts in defending his suitability and that the ruling was not supported by sufficient evidence. The real party in interest conceded that the court erred in denying Price the assistance of experts.The superior court initially found Price suitable for conditional release in October 2022. However, due to difficulties in finding a suitable residential placement and concerns about Price's behavior, the court reconsidered its decision. In July 2023, the court granted a six-month continuance for further review of Price's readiness for release. In November 2023, after considering new evidence and testimony, the court found Price unsuitable for conditional release, citing his behavior and concerns raised by Liberty Healthcare and the Department of State Hospitals.The California Court of Appeal, Third Appellate District, reviewed the case and concluded that the superior court erred in finding Price unsuitable for conditional release without providing him the assistance of experts, as required by law. The court held that Price was entitled to a new hearing with the procedural protections provided by section 6608, including the appointment of experts. The court issued a peremptory writ of mandate directing the superior court to vacate its order finding Price unsuitable for conditional release and to conduct a new hearing consistent with the opinion. View "Price v. Super. Ct." on Justia Law

Plaintiffs, employees of the State of California providing dental care to inmates, sued the state 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 trial court sustained the defendants' demurrer without leave to amend, ruling that these activities were not compensable under the Portal-to-Portal Act of the Fair Labor Standards Act (FLSA). Plaintiffs appealed, arguing that their wage claims were viable and that the trial court improperly decided a disputed question of fact.The trial court, Solano County Superior Court, sustained the demurrer on the grounds that the activities in question were not compensable under the FLSA. The court did not address other grounds raised by the defendants, such as the Memorandum of Understanding (MOU) precluding the claims, the inapplicability of the statutes to government employers, failure to exhaust contractual remedies, and the statute of limitations.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court concluded that the trial court erred in not accepting as true the plaintiffs' allegation that providing security is among their principal activities. The appellate court found that the MOU precludes plaintiffs from seeking additional wages under general state wage laws, thus affirming the demurrer as to the first and second causes of action. However, the court held that plaintiffs stated a claim for breach of contract and that the affirmative defense of failure to exhaust contractual remedies could not be resolved on demurrer. The court also determined that the plaintiffs' contract claim was not time-barred.The appellate court affirmed in part and reversed in part, allowing the breach of contract claim to proceed while dismissing the other claims. View "Bath v. State" on Justia Law

Blake Wentworth, a former professor at the University of California, Berkeley, sued the Regents of the University of California for various claims, including failure to engage in the interactive process, failure to provide reasonable accommodations, and invasion of privacy. Wentworth alleged that the Regents did not accommodate his bipolar II disorder and disclosed confidential information about him.The trial court granted summary adjudication in favor of the Regents on Wentworth's claims for failure to engage in the interactive process, failure to provide reasonable accommodations, and invasion of privacy. The court found that the Regents had engaged in the interactive process and offered reasonable accommodations, such as stopping Wentworth's tenure clock. The court also ruled that the invasion of privacy claim failed because Wentworth did not demonstrate that the Regents disclosed any confidential information.The Court of Appeal of the State of California, First Appellate District, reviewed the case. The court affirmed the trial court's rulings on the interactive process and reasonable accommodations claims, finding that the Regents had acted appropriately. However, the appellate court reversed the summary adjudication of the invasion of privacy claim, concluding that there were triable issues of fact regarding whether the Regents disclosed Wentworth's personal information in violation of the Information Practices Act (IPA).The appellate court also reversed the trial court's denial of Wentworth's motion for attorney's fees and costs, remanding the case for further proceedings to determine whether Wentworth was entitled to fees under the catalyst theory or based on his success in obtaining his personnel file during the litigation. 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 challenge by failing to object to the verdict form before the jury was discharged. View "Wentworth v. Regents of the University of California" on Justia Law

Thomas Reich created a revocable trust in 2003, which was later amended in 2016. The trust provided specific cash gifts to his ex-wife, brother, and nephew, and the residue to his daughter Shannon or granddaughter Leah if Shannon predeceased him. Thomas also maintained an IRA, designating Shannon's and Leah's separate trusts as beneficiaries. Thomas married Pamela Reich in 2020 and died in 2021 without updating his trust to include her. Pamela sought an omitted spouse's share of Thomas's estate, including the IRA proceeds.The Superior Court of Los Angeles County initially overruled a demurrer by Shannon, ruling that IRA proceeds could sometimes be included in a decedent's estate. However, after a partial settlement excluding the IRA proceeds, Pamela filed new petitions regarding her entitlement to the IRA proceeds. The probate court dismissed these petitions, reasoning that the IRA proceeds were nonprobate assets and did not pass through Thomas's trust.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the IRA proceeds were not part of Thomas's estate for calculating Pamela's omitted spouse's share because IRAs are nonprobate assets. The court noted that the IRA proceeds were designated to pass directly to the separate trusts for Shannon and Leah, not through Thomas's trust. The court affirmed the probate court's orders, concluding that the IRA proceeds were correctly excluded from Pamela's omitted spouse's share. View "Reich v. Reich" 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. Union Pacific argued that Richard fell because he was improperly positioned on the train. 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 Superior Court of Los Angeles County granted Union Pacific’s motion in limine to exclude Hess’s testimony, finding that Hess lacked the necessary qualifications. The jury returned a special verdict for Union Pacific, finding the company was not negligent. Richard appealed, arguing that the exclusion of Hess’s testimony was erroneous and prejudicial.The Court of Appeal of the State of California, Second Appellate District, reviewed the case. The court concluded that the trial court erred in excluding Hess’s testimony. Hess had extensive experience relevant to the subject matter and his testimony would have been helpful to the jury. The exclusion of Hess’s testimony was prejudicial because it left Richard without a witness to testify about the locomotive engineer’s actions and their potential danger.The Court of Appeal reversed the judgment for Union Pacific and remanded the matter for a new trial, holding that the trial court abused its discretion by excluding Hess’s expert testimony and that the error was prejudicial to Richard’s case. View "Richard v. Union Pacific Railroad Co." on Justia Law

The defendant, Freddy Rivera Corbi, was bullied by gang members in his community for years. In July 2019, he was seriously injured by a gang member. A month later, Corbi encountered another gang member, Lazaro Orozco, and fatally shot him after an argument. At trial, the main issue was whether the shooting was in self-defense or an act of revenge. The jury convicted Corbi of second-degree murder.The Superior Court of San Diego County reviewed the case. Corbi argued that the trial court abused its discretion by allowing the prosecution’s gang expert to offer certain opinions and that the prosecutor violated the California Racial Justice Act of 2020 during closing arguments. He also claimed the court erred in considering whether to dismiss a firearm enhancement at sentencing. The trial court imposed a sentence of 15 years to life for the murder, plus 10 years for a reduced firearm enhancement.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court found no reversible error regarding the expert testimony, determining that the gang expert’s opinions were not speculative and did not prejudice the jury’s decision. The court also held that Corbi forfeited his Racial Justice Act claim by failing to raise it in the trial court. Finally, the court concluded that the trial court properly imposed the firearm enhancement, as it had discretion to impose or dismiss the enhancement and had considered the relevant mitigating factors. The judgment was affirmed. View "P. v. Corbi" on Justia Law