Justia California Court of Appeals Opinion Summaries

Angelica Ramirez sued her former employer, Charter Communications, Inc., under the California Fair Employment and Housing Act (FEHA) for discrimination, harassment, retaliation, and wrongful discharge. Charter moved to compel arbitration based on an arbitration agreement signed by Ramirez during her onboarding process. The trial court found the agreement contained unconscionable provisions and refused to enforce it.The Superior Court of Los Angeles County found the arbitration agreement to be a contract of adhesion and identified several substantively unconscionable provisions, including shortened filing periods for claims, improper allocation of attorney fees, and lack of mutuality in claims subject to arbitration. The court denied Charter's motion to compel arbitration. Charter appealed, and a different panel of the Court of Appeal affirmed the trial court's decision, agreeing that the agreement contained multiple unconscionable provisions.The California Supreme Court reviewed the case and concurred that three provisions were substantively unconscionable but remanded the matter to the Court of Appeal to reconsider whether the unconscionable provisions could be severed from the agreement. On remand, the Court of Appeal concluded that severing the unconscionable provisions would not further the interests of justice. The court found that the agreement's central purpose was tainted with illegality and that the multiple unconscionable provisions indicated a systematic effort by Charter to impose arbitration in a manner that favored the employer. Therefore, the Court of Appeal affirmed the trial court's refusal to enforce the arbitration agreement. View "Ramirez v. Charter Communications, Inc." on Justia Law

Scott Packard (Scott) appealed an order granting judgment in favor of Gregory Roy Packard (Greg), as trustee of the Newton Roy Packard Trust, on Scott’s petition to reform an amendment to the trust. Scott argued that the probate court erred in finding his petition constituted a trust contest subject to a 120-day statute of limitations under Probate Code section 16061.7.The Superior Court of San Diego County had granted Greg’s motion for judgment on the pleadings, concluding that Scott’s petition was a trust contest and thus barred by the statute of limitations. The court found that the handwritten interlineation in the trust amendment was unambiguous and that Scott’s petition effectively sought to invalidate this amendment, constituting a contest to the trust.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court concluded that Scott’s petition was not a trust contest but rather a request to reform the trust to correct an alleged mistake in the trustor’s expression of intent. The court held that Scott’s petition was not subject to the 120-day statute of limitations for trust contests. The court emphasized that reformation petitions, which seek to correct a mistake to reflect the true intent of the trustor, do not constitute contests to the trust.The appellate court reversed the probate court’s order granting judgment on the pleadings and remanded the case for further proceedings consistent with its opinion. The court directed the probate court to deny Greg’s motion for judgment on the pleadings, allowing Scott the opportunity to prove his claim by clear and convincing evidence. Scott was awarded his costs on appeal. View "Packard v. Packard" on Justia Law

In March 2016, Paul Palalaua Tuilaepa filed his third petition for a writ of habeas corpus in the California Supreme Court, claiming his 1987 death sentence violated Atkins v. Virginia because he was intellectually disabled. He provided declarations from experts diagnosing him with an intellectual disability and another declaration recanting flawed testimony from his original trial. In November 2016, California voters enacted Proposition 66, which aimed to expedite death penalty appeals and postconviction proceedings. The trial court concluded Tuilaepa’s petition was procedurally barred under section 1509 and did not state a prima facie case for relief based on intellectual disability.The Superior Court of Los Angeles County denied Tuilaepa’s habeas petition in December 2020, ruling it was procedurally barred due to substantial delay and did not state a prima facie case for relief. The court found the expert declarations insufficient and inconsistent with other evidence in the record. Tuilaepa appealed, and the California Court of Appeal granted a certificate of appealability on whether the superior court erred in dismissing the petition as successive and without issuing an order to show cause.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case and concluded that section 1509, subdivision (d), applied retroactively to Tuilaepa’s petition. The court found that Tuilaepa’s petition was not procedurally barred because he established a prima facie case for relief based on intellectual disability. The court reversed the superior court’s order and remanded the case with directions to issue an order to show cause on Tuilaepa’s Atkins claim. View "In re Tuilaepa" on Justia Law

In this case, Joely Ng filed a complaint against Los Alamitos Medical Center and several doctors, alleging medical malpractice and wrongful death following the death of her husband, Kenneth Ng. Kenneth was admitted to the Medical Center due to a malfunction of his G-tube, which was improperly placed by Dr. McMahon. Subsequent negligence by other doctors led to Kenneth developing sepsis and dying three months later. Joely Ng sought noneconomic damages for both wrongful death and a survival claim.The Superior Court of Orange County granted the Medical Center's motion to strike portions of Ng's complaint that sought two separate caps on noneconomic damages under the Medical Injury Compensation Reform Act (MICRA). The court reasoned that the wrongful death claim was not separate from the medical negligence claim and thus could not be subject to a separate MICRA cap. The court denied leave to amend but allowed for the possibility of future amendments if Ng could allege facts supporting the claims as separate and distinct.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court concluded that wrongful death and survival claims are separate and distinct, even when based on the same incident of medical malpractice. Therefore, Ng is entitled to seek two separate MICRA caps for noneconomic damages. The court granted Ng's petition, directing the trial court to vacate its previous order and issue a new order denying the Medical Center's motion to strike. View "Ng v. Super. Ct." on Justia Law

The plaintiff, Steve Shehyn, owns a 20-acre avocado orchard in Moorpark, California. He alleged that sediment from the Ventura County Public Works Agency and Ventura County Waterworks District No. 1's (collectively, the District) water delivery system permanently damaged his irrigation pipes and orchard. The plaintiff claimed that the sediment was a direct result of the District's water supply facilities' plan, design, maintenance, and operation.The trial court sustained the District's demurrer to the plaintiff's first amended complaint, which included causes of action for breach of contract, negligence, and inverse condemnation. The court allowed the plaintiff to amend the breach of contract and negligence claims but sustained the demurrer without leave to amend for the inverse condemnation claim, citing that the plaintiff "invited" the District's water onto his property. The plaintiff filed a second amended complaint, maintaining the inverse condemnation claim unchanged and indicating his intent to seek a writ of mandamus. The trial court entered judgment for the District after the plaintiff voluntarily dismissed his contract and negligence claims without prejudice.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case de novo. The court concluded that the plaintiff sufficiently pleaded his claim for inverse condemnation. The court found that the plaintiff's allegations that the District's water delivery system delivered a disproportionate amount of sediment to his property, causing damage, supported a claim for inverse condemnation. The court disagreed with the trial court's reliance on Williams v. Moulton Niguel Water Dist., stating that the issue of whether the plaintiff "invited" the water goes to the merits of the claim, not its viability at the pleading stage. The appellate court reversed the judgment and remanded the case with instructions to enter a new order overruling the demurrer. View "Shehyn v. Ventura County Public Works Agency" on Justia Law

Jorge Sarmiento-Zuniga was found guilty by a jury of oral copulation of a person he knew or should have known was intoxicated. In March 2023, the San Francisco Superior Court sentenced him to the middle term of six years in prison for this count. The court reviewed various documents, including the probation officer’s report and the victim’s impact statement, before announcing a tentative sentence. The court cited Sarmiento’s prior convictions and the victim’s repeated refusals captured on video as reasons for the middle term sentence. Despite the defense’s argument for a lesser sentence based on time already served, the court finalized the middle term sentence.The San Francisco Superior Court’s decision was appealed by Sarmiento, who argued that the court erred in considering his prior convictions without certified records and that the lower term should have been imposed due to the victim’s voluntary intoxication. The People contended that the appeal was forfeited because Sarmiento did not object to the sentence during the trial. They also argued that certified records were unnecessary for the middle term sentence and that none of the statutory circumstances mandating the lower term applied.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. The court held that Sarmiento forfeited his appeal by not objecting to the sentence in the trial court. However, the court exercised its discretion to review the merits and affirmed the sentence. The court found that Penal Code section 1170, subdivision (b)(1) does not impose additional evidentiary requirements for a middle term sentence and that the trial court properly stated its reasons for the sentence on the record. The judgment was affirmed. View "People v. Sarmiento-Zuniga" on Justia Law

In September 2022, Antoine Leon Richardson had an altercation with Mckyla Middleton at a liquor store in Lancaster, California. Richardson accused Middleton of cutting him off, threatened her, and flashed a gun at her from a satchel. In November 2022, police searched Richardson’s home and found ammunition but no firearms. Richardson admitted to brandishing the gun during the altercation and owning the ammunition.The Los Angeles County Superior Court charged Richardson with being a felon in possession of a firearm, being a felon in possession of ammunition, and misdemeanor exhibiting a concealable firearm in public. The jury found Richardson guilty on all counts and confirmed his prior felony convictions. The court sentenced him to three years and eight months in prison for the firearm and ammunition charges, with a concurrent 364-day term for the misdemeanor.The California Court of Appeal, Second Appellate District, reviewed the case. Richardson argued that his convictions for firearm and ammunition possession violated the Second Amendment, citing New York State Rifle & Pistol Association, Inc. v. Bruen. The court disagreed, stating that the Second Amendment protects law-abiding citizens, not felons. The court also found that substantial evidence supported the trial court’s finding that Richardson had separate objectives for possessing and exhibiting the firearm, thus allowing multiple sentences under Penal Code section 654.The Court of Appeal affirmed the trial court’s judgment, upholding Richardson’s convictions and sentences. View "People v. Richardson" on Justia Law

In this wage-and-hour class action, the plaintiffs, employees of ACE American Insurance Company (ACE), alleged that ACE misclassified them as exempt employees and failed to provide benefits required for nonexempt employees under state law. The plaintiffs also added claims under the Private Attorneys General Act of 2004 (PAGA) for the same alleged violations. The plaintiffs had signed arbitration agreements as a condition of their employment, which required them to submit employment-related legal claims to arbitration.The Superior Court of Los Angeles County initially granted ACE's motion to compel arbitration and stayed the case pending arbitration. However, neither party initiated arbitration. The plaintiffs then moved to lift the stay, arguing that ACE was required to initiate arbitration and had waived its right to arbitrate by failing to do so. The trial court agreed with the plaintiffs, finding that ACE's inaction was inconsistent with its right to arbitrate and lifted the stay.The Court of Appeal of the State of California, Second Appellate District, reviewed the case. The court held that the plaintiffs, not ACE, were required to initiate arbitration under the terms of the arbitration agreements. The agreements specified that the party wanting to start the arbitration procedure should submit a demand, and in this context, it referred to the plaintiffs who had employment-related legal claims. The court concluded that ACE did not breach the arbitration agreements or waive its right to arbitration by failing to initiate the process. Consequently, the trial court's order lifting the stay was reversed, and ACE was awarded its costs on appeal. View "Arzate v. ACE American Insurance Company" on Justia Law

A medical doctor, employed by San Bernardino Medical Group and working for OptumCare Medical Group, faced a summary suspension of his clinical privileges by PrimeCare Medical Network, Inc. after a patient complaint. The patient alleged that the doctor hit her hand during an office visit, which the doctor admitted to in his notes, explaining it was to stop her from arguing. The next day, PrimeCare’s Chief Medical Officer (CMO) summarily suspended the doctor’s privileges, citing imminent danger to patient health.The Corporate Quality Improvement Committee (CQIC) upheld the suspension pending the doctor’s completion of an anger management course. The doctor requested a formal hearing, and PrimeCare’s Judicial Hearing Committee (JHC) found that the summary suspension was not warranted, as the incident was isolated and did not demonstrate imminent danger. The JHC recommended anger management and a chaperone for the doctor but did not find the suspension justified.PrimeCare’s Board of Directors reviewed the JHC’s decision, arguing it was inconsistent with the applicable burden of proof. The Board conducted an independent review, disagreed with the JHC’s findings, and reinstated the suspension, concluding that the doctor’s actions and subsequent comments posed an imminent threat to patients.The doctor filed a petition for writ of administrative mandamus, which the Superior Court of San Bernardino County granted. The court ruled that the Board exceeded its jurisdiction and committed a prejudicial abuse of discretion by independently reviewing and reversing the JHC’s decision. The court ordered the Board to adopt the JHC’s decision, reinstate the doctor’s privileges, and report the reinstatement to relevant entities.The California Court of Appeal, Fourth Appellate District, affirmed the trial court’s judgment, agreeing that the Board’s actions were unauthorized and inconsistent with the statutory requirement that peer review be performed by licentiates. View "Lin v. Board of Directors of PrimeCare Medical Network" on Justia Law

In September 2016, a high school student, almost 16 years old, was involved in a fistfight during an art class. The teacher, who weighed 375 pounds and had a back condition, intervened to stop the fight. While pulling one of the boys away, the teacher lost his balance and fell onto the plaintiff, breaking the plaintiff’s leg. The plaintiff sued the teacher and the school district for negligence, arguing that the teacher should not have intervened due to his physical condition and that the school district failed to train its teachers on safely handling physical altercations.The Superior Court of Los Angeles County held a 15-day trial, during which the jury viewed a video of the incident multiple times. The jury concluded that neither the teacher nor the school district was negligent and found that the plaintiff and the other boy were each 50 percent responsible for the harm. The plaintiff’s motion for judgment notwithstanding the verdict (JNOV) and a new trial was denied.The California Court of Appeal, Second Appellate District, reviewed the case. The court found substantial evidence supporting the jury’s verdict that neither the teacher nor the school district was negligent. The court also upheld the trial court’s exclusion of the plaintiff’s expert witness on the grounds that the expert was not qualified to opine on classroom management and discipline. Additionally, the court found no error in the trial court’s refusal to give the plaintiff’s requested special jury instructions, as the standard instructions on negligence were deemed sufficient. The judgment and the order denying the plaintiff’s motion for JNOV and a new trial were affirmed. View "I.C. v. Compton Unified School Dist." on Justia Law