Justia California Court of Appeals Opinion Summaries

In 1994, Karl Senser was fatally stabbed during a carjacking, following a series of related crimes. Law enforcement quickly identified Steven Thomas as a prime suspect and later arrested him, but although circumstantial evidence suggested Leon Daniel McInnis was Thomas’s accomplice, authorities did not believe they had enough evidence to charge McInnis with murder at that time. The investigation included interviews, lineups, and early DNA testing, but no physical evidence directly linked McInnis to the murder scene. McInnis ultimately pled guilty to a related carjacking, while Thomas was convicted of Senser’s murder.The Superior Court of San Diego County dismissed the murder charge against McInnis in 2023, after he argued that the 27-year delay in prosecution violated his state due process rights. The court found the delay negligent, reasoning that law enforcement could have tested key evidence, such as a napkin found at the scene, for DNA in 1994. The court also determined that the loss of eyewitnesses due to the passage of time prejudiced McInnis’s ability to defend himself, and that no remedy short of dismissal could cure this prejudice.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case and reversed the trial court’s dismissal. The appellate court held that, under California Supreme Court precedent, courts may not find negligence by second-guessing prosecutorial decisions about when sufficient evidence exists to file charges, how investigations are conducted, or how resources are allocated. The delay was deemed “investigative,” not negligent, because prosecutors waited until new DNA evidence provided a strong basis for charging McInnis. The appellate court remanded the case for the trial court to properly balance the prejudice to McInnis against the prosecution’s justification for the delay, and to consider alternative remedies. View "P. v. McInnis" on Justia Law

The case concerns a defendant who, while driving under the influence of alcohol with a blood alcohol content of at least 0.18 percent, crashed into another vehicle, resulting in the deaths of three individuals and causing serious injury to a fourth person, Sarah S. The defendant was charged with multiple felonies, including three counts of gross vehicular manslaughter while intoxicated, two counts of driving under the influence causing injury to Sarah, and two counts of perjury. He pled no contest to the perjury charges and was found guilty by a jury on all remaining counts.Following his conviction in San Mateo County Superior Court, the defendant was originally sentenced to 47 years and two months to life in prison. On direct appeal, the California Court of Appeal ordered corrections to the abstract of judgment but otherwise affirmed the conviction. After remittitur and resentencing, the trial court imposed a sentence of 47 years to life. The defendant appealed again, arguing that his convictions for driving under the influence causing injury should be dismissed as lesser included offenses of gross vehicular manslaughter while intoxicated, and also challenged the trial court’s failure to specify the fines and fees imposed at resentencing.The California Court of Appeal, First Appellate District, Division Three, held that driving under the influence causing injury is not a lesser included offense of gross vehicular manslaughter while intoxicated when the offenses involve different victims. The court also found that the trial court erred by not itemizing the fines and fees imposed at resentencing. The appellate court remanded the matter for the trial court to specify the amount and statutory basis for each fine, fee, and assessment, but otherwise affirmed the judgment. View "People v. Demacedo" on Justia Law

A.H., a minor, was adjudged a ward of the juvenile court after admitting to grand theft and violating probation conditions, including disobeying his mother, leaving home without approval, and violating curfew. After further violations—failing to attend mentorship meetings and testing positive for THC—the probation department recommended out-of-home placement in a short-term residential therapeutic program (STRTP), citing A.H.’s mental health conditions and his mother’s unwillingness to house him due to safety concerns. The probation department did not submit a statutorily required case plan before the disposition hearing, although it later provided one after the court’s order.The Superior Court of Contra Costa County held several hearings, ultimately ordering A.H.’s placement in an STRTP without first reviewing a case plan as required by Welfare and Institutions Code sections 706.5 and 706.6, and relevant California Rules of Court. A.H.’s counsel objected to the lack of a case plan, but the court proceeded with the placement order and deferred consideration of certain recommendations pending receipt of the case plan. The case plan was provided at a subsequent hearing, but the court did not indicate it had reviewed it before proceeding.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. While the appeal became moot when the juvenile court vacated the placement order, the appellate court exercised its discretion to address the issue due to its public importance and likelihood of recurrence. The court held that the statutory scheme requires probation to submit, and the juvenile court to consider, a case plan before ordering foster care placement. The failure to do so constituted an abuse of discretion. After deciding the merits, the Court of Appeal dismissed the appeal as moot. View "In re A.H." on Justia Law

Travis Rockhill was charged with the murder of Gary Matthews, who was shot outside a friend’s home and later died from his injuries. The prosecution presented evidence that Rockhill had a dispute with Matthews over a scooter sale and was angry with him prior to the shooting. The defense argued that another individual, Louie (“Primo”), was involved and that Rockhill was not the shooter. During Rockhill’s first trial, he made incriminating statements to the courtroom bailiff, but the prosecution did not introduce this evidence. The jury deadlocked, resulting in a mistrial.In the second trial, presided over by Judge Emily Cole, Rockhill testified in his own defense. After both sides rested, Judge Cole sent ex parte text messages to a former colleague at the District Attorney’s office, questioning why the prosecutor was not calling the bailiff as a rebuttal witness and suggesting someone should speak to the prosecutor about it. The prosecution did not act on this suggestion, and Rockhill was convicted of first-degree murder with a firearm enhancement. After the verdict, the prosecution disclosed Judge Cole’s ex parte communications to the defense. Judge Cole recused herself, acknowledging the impropriety but maintaining she had been impartial. Rockhill moved for a new trial based on judicial bias, but Judge Denise McLaughlin-Bennett of the Superior Court of Los Angeles County denied the motion, finding no intent to intervene in the proceedings and no impact on the verdict.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court held that Judge Cole’s ex parte communications constituted a due process violation and structural error, as they demonstrated an unconstitutional probability of actual judicial bias. The court reversed the judgment and remanded the case for a new trial, directing the lower court to grant Rockhill’s motion for a new trial. View "P. v. Rockhill" on Justia Law

Sara Lynn Krueger was charged with the murder of her young daughter, Kayleigh S., in Napa County, California. The prosecution alleged that the murder was committed by torture, and Krueger was tried on the theory that she either directly committed the crimes or aided and abetted her codefendant. The jury was instructed only on first degree murder by torture and not on felony murder or the natural and probable consequences doctrine. In May 2017, the jury found Krueger guilty of first degree murder by torture and assault causing death of a child, but the special circumstance finding of torture was later reversed on direct appeal due to insufficient evidence of specific intent to kill. The conviction for first degree murder was otherwise affirmed, and Krueger was sentenced to 25 years to life.Following legislative changes enacted by Senate Bill No. 1437, which limited certain theories of murder liability, Krueger filed a petition for resentencing under Penal Code section 1172.6, arguing she was eligible for relief because the jury instructions allegedly permitted malice to be imputed based solely on her participation in torture. The Superior Court of Napa County denied her petition at the prima facie stage, finding she was ineligible for relief as a matter of law since she was not convicted under any theory affected by the statutory amendments.The California Court of Appeal, First Appellate District, Division Two, reviewed the case and affirmed the trial court’s denial of Krueger’s petition. The appellate court held that Krueger was prosecuted and convicted solely under a theory of first degree murder by torture, which remains valid after Senate Bill 1437. The jury’s findings and instructions required proof of a mental state more culpable than malice, and thus, Krueger could still be convicted under current law. The court concluded she was ineligible for resentencing relief under section 1172.6. View "P. v. Krueger" on Justia Law

The case concerns Ryan Scott Warner, who was charged with the murder of Kayleigh S., the young daughter of his codefendant, Sara Lynn Krueger. The prosecution alleged that Warner either directly committed the murder or aided and abetted Krueger, with the sole theory presented to the jury being first degree murder by torture. The jury was not instructed on felony murder or the natural and probable consequences doctrine. In 2017, Warner was found guilty of first degree murder by torture and assault causing death of a child. On direct appeal, the Court of Appeal reversed the special circumstance finding due to insufficient evidence of specific intent to kill but affirmed the murder conviction, finding ample evidence of intent to inflict extreme pain for a sadistic purpose.Following legislative changes enacted by Senate Bill No. 1437, which amended California’s murder statutes to eliminate certain forms of accomplice liability and imputed malice, Warner petitioned for resentencing under Penal Code section 1172.6. The Superior Court of Napa County denied his petition at the prima facie stage, concluding Warner had not shown he could not be convicted of murder under the amended statutes. Warner appealed, arguing the trial court improperly engaged in factfinding and that the jury instructions permitted conviction on an impermissible theory of imputed malice.The California Court of Appeal, First Appellate District, Division Two, independently reviewed the record and affirmed the denial of Warner’s petition. The court held that Warner was prosecuted and convicted solely under a theory of murder liability—first degree murder by torture—that remains valid after Senate Bill No. 1437. The jury’s findings necessarily established the required mental state for murder under current law, and Warner was not convicted under any theory affected by the statutory changes. Therefore, Warner is ineligible for resentencing relief under section 1172.6 as a matter of law. View "P. v. Warner" on Justia Law

Several employees of the City and County of San Francisco who joined the city’s retirement system at age 40 or older and later retired due to disability challenged the method used to calculate their disability retirement benefits. The city’s retirement system uses two formulas: Formula 1, which provides a higher benefit if certain thresholds are met, and Formula 2, which imputes service years until age 60 but caps the benefit at a percentage of final compensation. Plaintiffs argued that Formula 2 discriminates against employees who enter the system at age 40 or above, in violation of the California Fair Employment and Housing Act (FEHA).Initially, the San Francisco City and County Superior Court sustained the city’s demurrer, finding the plaintiffs had not timely filed an administrative charge. The California Court of Appeal reversed that decision, allowing the case to proceed. After class certification and cross-motions for summary judgment, the trial court found triable issues and held a bench trial. At trial, plaintiffs presented expert testimony based on hypothetical calculations, while the city’s expert criticized the lack of actual data analysis and highlighted factors such as breaks in service and purchased credits.The California Court of Appeal, First Appellate District, Division Four, reviewed the trial court’s post-trial decision. The appellate court affirmed the trial court’s judgment, holding that the plaintiffs failed to prove intentional age discrimination or disparate impact under FEHA. The court found substantial evidence that Formula 2 was motivated by pension status and credited years of service, not age. The plaintiffs’ evidence was insufficient because it relied on hypotheticals rather than actual data showing a disproportionate adverse effect on the protected group. The appellate court also affirmed the denial of leave to amend the complaint, finding no reversible error. The judgment in favor of the city was affirmed. View "Carroll v. City & County of S.F." on Justia Law

Orlando Rodriguez, while employed as a mechanic, suffered significant head and brain injuries in November 2016. His employer’s insurer, administered by Illinois Midwest Insurance Agency, accepted the injuries as work-related. Beginning in September 2018, Rodriguez’s treating physician repeatedly requested home health care services in six-week increments, which Illinois Midwest generally approved, sometimes after utilization review. In September 2019, a new request for home health care was denied by a utilization review physician, and the denial was communicated to all relevant parties.Rodriguez challenged the denial by seeking an expedited hearing before a workers’ compensation judge. The judge found Rodriguez was entitled to ongoing home health care, reasoning that Illinois Midwest could not terminate the treatment without substantive medical evidence of a change in condition. The judge concluded the utilization review decision was “moot” due to Rodriguez’s ongoing need and relied on Patterson v. The Oaks Farm (2014) 79 Cal.Comp.Cases 910. Illinois Midwest petitioned for reconsideration, but the Workers’ Compensation Appeals Board (WCAB) affirmed the judge’s decision, again relying on Patterson and finding no evidence of changed circumstances.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. The court held that, following legislative reforms in 2004 and 2013, disputes over medical necessity for requested treatments must be resolved through the statutory utilization review and independent medical review processes, not by the WCAB or courts, even for ongoing or continual treatment. The court rejected Patterson’s contrary rule for post-2013 injuries, finding no statutory exception for ongoing treatment. The court annulled the Appeals Board’s decision and remanded the matter for further proceedings consistent with its opinion. View "Illinois Midwest Insurance Agency, LLC v. Workers’ Compensation Appeals Board" on Justia Law

The case involves a long-running dispute between two parties, Baer and Tedder, stemming from Baer's lawsuit against Tedder for malicious prosecution. During the course of this litigation, Baer filed a motion to compel production of documents and requested sanctions against Tedder and his counsel, Kent, for misuse of the discovery process. The trial court found that Tedder and Kent had engaged in evasive and unjustified conduct during discovery, which hindered Baer's ability to prepare his case. As a result, the court imposed $10,475 in monetary sanctions against both Tedder and Kent, jointly and severally.Tedder and Kent appealed the sanctions order to the California Court of Appeal, Fourth Appellate District, Division Three. In a prior opinion, the appellate court affirmed the trial court’s sanctions order, finding that Tedder and Kent’s actions were not substantially justified and that their arguments on appeal were largely frivolous. Following the remittitur, Baer moved in the trial court to recover attorney’s fees incurred in defending the appeal, arguing that the relevant discovery statutes authorized such an award. The trial court agreed, awarding Baer $113,532.50 in appellate attorney’s fees, but imposed liability only on Tedder.On further appeal, the California Court of Appeal, Fourth Appellate District, Division Three, held that Code of Civil Procedure sections 2023.030(a) and 2031.320(b) authorize a trial court to award attorney’s fees incurred on appeal to a party who successfully defends an order imposing monetary sanctions for discovery misuse. The appellate court found the amount of fees reasonable with one reduction and concluded that both Tedder and Kent should be held jointly and severally liable for the full amount. The order was modified to reduce the fee award to $101,805 and to impose joint and several liability on both Tedder and Kent, and as modified, the order was affirmed and remanded for entry of the revised order. View "Baer v. Tedder" on Justia Law

A man was charged with illegal possession of ammunition after police stopped a car in which he was a passenger late at night, citing a non-functioning license plate light and tinted windows. During the stop, officers asked both occupants if they were on parole or probation, ordered them out of the vehicle, and conducted pat searches, citing low lighting and baggy clothing as reasons. A search of a backpack near the passenger seat revealed ammunition and documents with the passenger’s name. The passenger, who had prior felony convictions, was arrested. During the encounter, officers used slang and whistled at both the passenger and two Latino men passing by.The Santa Clara County Superior Court initially denied the passenger’s motion under the California Racial Justice Act (RJA), finding he had not made a prima facie showing that the officers’ actions were motivated by racial bias. After the California Court of Appeal issued an alternative writ requiring reconsideration and a detailed ruling on all claims, the trial court again denied the motion, concluding that the allegations were conclusory or unsupported.The California Court of Appeal, Sixth Appellate District, reviewed the case de novo and held that the passenger had made a prima facie showing under the RJA. The court found that, when considering the totality of the facts—including expert testimony, statistical evidence, and the officers’ language and conduct—there was a substantial likelihood that law enforcement exhibited bias based on race, ethnicity, or national origin. The court clarified that at the prima facie stage, the trial court should not weigh evidence or make credibility determinations, but should accept the truth of the movant’s factual allegations unless they are conclusory or contradicted by the record. The appellate court issued a writ directing the trial court to hold an evidentiary hearing on the RJA motion. View "Hernandez v. Superior Court" on Justia Law