Justia California Court of Appeals Opinion Summaries

A.M. and R.Y. were married in April 2019, separated in April 2023, and have a daughter born in August 2019. A.M. filed for divorce in April 2023, and the parties signed a marital settlement agreement (MSA) in December 2023, which was incorporated into an uncontested judgment of dissolution in February 2024. The MSA gave A.M. sole legal and primary physical custody of their daughter, with R.Y. having supervised weekend visitation. In May 2024, A.M. filed a request for a domestic violence restraining order (DVRO) against R.Y., alleging psychological, verbal, and emotional abuse, as well as coercive control.The Superior Court of San Diego County denied A.M.'s request for a domestic violence temporary restraining order (DVTRO) on the same day it was filed, citing insufficient evidence of past abuse and lack of detail about recent incidents. The court scheduled a hearing for a permanent DVRO but did not grant a temporary order pending the hearing. A.M. appealed the denial of the DVTRO and requested a stay of further proceedings in the trial court, which was denied. The court set the permanent DVRO request for an evidentiary hearing in August 2024, later continued to August 2025.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case and found that A.M. made a prima facie showing of abuse based on her declaration and accompanying evidence. The court concluded that the trial court erred in finding A.M.'s evidence insufficient and in denying the DVTRO without proper reasons. The appellate court held that the trial court has discretion to deny a DVTRO if it reasonably concludes that it is not necessary to protect the petitioner pending the noticed hearing. The appellate court reversed the order denying the DVTRO and remanded the matter for further consideration based on the totality of circumstances. View "Marriage of A.M. and R.Y." 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

The case involves the County of San Diego's adoption of thresholds of significance under the California Environmental Quality Act (CEQA) to streamline the evaluation of transportation-related environmental effects for land-use development projects. The County adopted two specific thresholds: one for "infill" projects within unincorporated villages and another for projects generating fewer than 110 automobile trips per day. Plaintiffs, two environmental groups, challenged these thresholds, arguing they were not supported by substantial evidence and did not comply with CEQA requirements.The Superior Court of San Diego County ruled in favor of the County, finding that the infill threshold was consistent with CEQA and that the small project threshold was justified by substantial evidence, as it aligned with recommendations from the Governor’s Office of Planning and Research (OPR).The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the County's infill threshold was not supported by substantial evidence, as it relied on unsubstantiated assumptions that infill development would generally result in insignificant vehicle miles traveled (VMT) impacts. The court found that the County failed to provide evidence showing that development in designated infill areas would typically generate VMT below the County average.Similarly, the court found that the small project threshold lacked substantial evidentiary support. The County had adopted OPR's recommendation without providing evidence that projects generating fewer than 110 trips per day would have a less-than-significant transportation impact in San Diego County.The Court of Appeal reversed the Superior Court's judgment and remanded the case with directions to grant the petition for writ of mandate, requiring the County to comply with CEQA by providing substantial evidence to support the adopted thresholds. View "Cleveland National Forest Foundation v. County of San Diego" on Justia Law

John Benson was convicted of first-degree murder and other felonies related to the shooting death of Chloe Evans, a commercial sex worker, in Los Angeles on October 25, 2019. Witness Kiera Furlow identified Benson as the shooter, describing his gang affiliation and a distinctive tattoo. Benson was charged with multiple offenses, including murder, attempted murder, and firearm possession.In the Superior Court of Los Angeles County, Benson's first trial ended in a mistrial due to a hung jury. During the second trial, Furlow was reluctant to testify and had to be arrested to secure her appearance. She recanted much of her previous testimony, claiming fear of the police rather than Benson. Despite her recantation, the jury convicted Benson of first-degree murder, shooting at an occupied vehicle, shooting from a vehicle, and firearm possession, but acquitted him of the attempted murder of Joshua Ellis. Benson was sentenced to 120 years to life in prison.The California Court of Appeal, Second Appellate District, reviewed the case. Benson argued that the trial court erred in admitting gang-related evidence, granting a trial continuance, and failing to investigate a juror's potential bias. The appellate court found that the gang evidence was relevant to issues of identity, witness credibility, and motive. The court also held that the trial court did not abuse its discretion in granting a one-week continuance due to the prosecutor's family emergency. Additionally, the appellate court determined that Benson forfeited his claim regarding the juror's potential bias by not providing an adequate record for review. Lastly, Benson's claim of prosecutorial error during closing arguments was deemed forfeited due to his failure to object at trial.The California Court of Appeal affirmed the judgment of the Superior Court. View "People v. Benson" on Justia Law

Myranda De la Cruz tripped on a pothole in a parking lot at a Mission Hills shopping center, which was managed by Triwell Properties. De la Cruz sued Mission Hills Shopping Center LLC and Triwell Properties (collectively referred to as Mission) for her injuries. Mission moved for summary judgment based on a contract between Mission and De la Cruz’s employer, a tenant in the shopping center. The contract contained an exculpatory clause relieving Mission from liability for negligent or wrongful acts. However, De la Cruz had not signed this contract.The Superior Court of Los Angeles County granted Mission’s motion for summary judgment, accepting the argument that the exculpatory clause in the contract applied to De la Cruz. The court did not address why De la Cruz, who was not a party to the contract, would be bound by its terms.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the trial court erred in granting summary judgment because Mission failed to establish a legal basis for binding De la Cruz to a contract she had not signed. The court emphasized that contracts require mutual assent, and it was Mission’s burden to demonstrate why De la Cruz was bound by the contract. The appellate court exercised its discretion to consider De la Cruz’s argument, despite it not being raised in the trial court, due to the foundational nature of the legal error.The Court of Appeal reversed the judgment and remanded the case, instructing the trial court to enter a new order denying Mission’s summary judgment motion. The appellate court also awarded costs to De la Cruz. View "De la Cruz v. Mission Hills Shopping Center LLC" 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

In 2001, Phuoc Thien Luu, then 17, participated in an attempted home invasion robbery with three others. One accomplice shot the homeowner, who survived. Luu and another accomplice, Dung Van Nguyen, were charged with attempted murder and related crimes. Nguyen was found guilty of attempted murder and sentenced to 102 years to life plus 10 years. Luu was found not guilty of attempted murder but guilty of attempted voluntary manslaughter and related crimes, receiving a sentence of 25 years to life plus 1.5 years.In 2022, both Luu and Nguyen filed petitions under Penal Code section 1172.6 for resentencing. The People conceded Nguyen was entitled to relief, and he was released. However, they argued Luu was ineligible because attempted manslaughter is not mentioned in section 1172.6. The trial court initially issued an order to show cause but later ruled Luu was statutorily ineligible for relief.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court found that excluding Luu from relief under section 1172.6, despite his conviction under the natural and probable consequences doctrine, led to an unjust and absurd result. The court held that a petitioner is eligible for relief under section 1172.6 if they were charged with attempted murder under the natural and probable consequences doctrine and convicted of the lesser included offense of attempted manslaughter. The court reversed the trial court's order and remanded the case, directing the trial court to reissue an order to show cause and conduct an evidentiary hearing. If the People cannot prove Luu's guilt under current laws, the court must resentence him with credit for time served. View "People v. Luu" on Justia Law

Plaintiff filed a putative class action against the City, alleging violations of the California Public Records Act (CPRA) and the California Constitution. The City maintains a website for public records requests but the Department of Water and Power (DWP) does not provide a specific method for such requests. Plaintiff, after receiving an erroneous water bill, submitted multiple records requests through the DWP website but received no response. She later posted a complaint on social media, which led to a phone call from a customer service representative but no records were provided.The Superior Court of Los Angeles County sustained the City’s demurrer without leave to amend, concluding that the CPRA does not permit class claims and that plaintiff’s individual claim was insufficient because the City provides a method for submitting CPRA requests through its main website. The court also denied the City’s motion for sanctions, finding plaintiff’s arguments were not frivolous.The California Court of Appeal, Second Appellate District, reviewed the case. The court agreed with the trial court that the CPRA does not allow for class claims, as the statutory language and case law limit judicial relief to the individual who made the records request. However, the appellate court found that plaintiff’s individual claim was sufficient, as she alleged that she submitted a request for public records and the City failed to respond within the statutory period. The appellate court reversed the judgment and remanded with directions to enter a new order sustaining the demurrer as to the class claims and overruling the demurrer to plaintiff’s individual CPRA claim. View "Di Lauro v. City of Burbank" on Justia Law

In 2006, a jury convicted the defendant of robbery and assault with a firearm, with enhancements for personal firearm use and prior convictions. The trial court sentenced him to 25 years to life for the robbery, 10 years for the firearm enhancement, and five years for a prior serious felony conviction, staying the sentence for the assault conviction. In 2024, the defendant petitioned for resentencing under the amended Penal Code section 1172.1, which the trial court dismissed, stating that the defendant was not entitled to file such a petition and that no authorized agency had recommended recall and resentencing.The defendant appealed the trial court's dismissal of his petition. The Court of Appeal of the State of California, Third Appellate District, reviewed whether the trial court's order was appealable. The court noted that under section 1237, subdivision (b), a criminal defendant can appeal any postjudgment order affecting their substantial rights. However, the court found that the trial court's order did not affect the defendant's substantial rights because the trial court had no statutory obligation to act on the defendant's request for recall and resentencing.The Court of Appeal concluded that the trial court's order dismissing the defendant's request for relief under section 1172.1 was not appealable. The court reasoned that since the trial court was not required to respond to the defendant's request, the order did not affect the defendant's substantial rights. Consequently, the appeal was dismissed. View "P. v. Roy" on Justia Law