Justia California Court of Appeals Opinion Summaries

Dewayne Keith Parker faced criminal charges in both Fresno and Napa counties, including murder, burglary, and assault. He was found incompetent to stand trial in Fresno County and admitted to Napa State Hospital. While hospitalized, Parker allegedly assaulted another patient, leading to new charges in Napa County. The Napa County Superior Court found him incompetent to stand trial and committed him to the Department of State Hospitals. After Parker was restored to competency, he was discharged to Fresno County due to his primary commitment there. More than a year later, after being arrested on a Napa County bench warrant, Parker was returned to Napa County, where the court again found him incompetent to stand trial.The Napa County Superior Court held a restoration hearing and, relying on equitable tolling, paused the two-year maximum commitment period for Parker’s Napa County charges during the time he was involved in proceedings in Fresno County. Parker argued that this tolling was unauthorized by statute and violated his due process and equal protection rights. The court rejected these arguments, denied his request for release or conservatorship, and set a new commitment expiration date based on the tolled period.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court held that, although the statutory scheme for competency commitments does not expressly address tolling, courts have inherent equitable powers to pause the running of the commitment period when a defendant is unavailable due to proceedings in another jurisdiction. The court found that the delay caused by Parker’s simultaneous proceedings in Fresno County constituted good cause for tolling. The appellate court affirmed the Napa County Superior Court’s order, concluding that the tolling did not violate Parker’s constitutional rights. View "People v. Parker" on Justia Law

In this case, the plaintiff was subject to a default judgment in 2006 for an unpaid credit card debt after a process server claimed to have effected substitute service at a Hayward, California address. The plaintiff asserted he was never served, did not reside at the address where service was attempted, and only learned of the judgment in December 2022. The debt was later assigned to a new creditor, who sought to renew and enforce the judgment, which had grown substantially with interest. After the plaintiff’s motion to vacate the judgment for lack of service was denied, he filed a new action seeking equitable relief to set aside the judgment and alleging violations of the Rosenthal Fair Debt Collection Practices Act.The Superior Court of Alameda County granted the defendants’ anti-SLAPP motions, striking the complaint and dismissing it with prejudice. The court found the plaintiff’s uncorroborated declaration insufficient to rebut the presumption of valid service and concluded he had not shown a likelihood of prevailing on his equitable or statutory claims. The court also determined that, because the plaintiff admitted to owing the debt, he could not establish a meritorious defense to the underlying action.The California Court of Appeal, First Appellate District, Division Four, reversed the trial court’s judgment. The appellate court held that the trial court erred by weighing the credibility of the plaintiff’s declaration at the anti-SLAPP stage, rather than accepting it as true for purposes of determining minimal merit. The appellate court further held that, where a challenge to a default judgment is based on lack of service, due process does not require the plaintiff to show a meritorious defense to set aside the judgment. The court also found that the plaintiff’s statutory claim under the Rosenthal Act was not contingent on prevailing on his equitable claims. The judgment was reversed and costs were awarded to the plaintiff. View "Ahmed v. Collect Access, LLC" on Justia Law

The case concerns a challenge to the validity of Measure C, a citizens’ initiative placed on the ballot by the City of San Diego for the March 2020 election. Measure C proposed an increase in the city’s transient occupancy tax, with revenues earmarked for homelessness programs, street repairs, and convention center improvements. The measure also authorized the City to issue bonds repaid from the new tax revenues. Measure C received 65.24 percent of the vote, and the city council subsequently passed resolutions declaring the measure approved and authorizing the issuance of related bonds.After the election, Alliance San Diego and other plaintiffs filed actions challenging the City’s resolution declaring Measure C had passed, arguing it was invalid. The City responded with a validation complaint seeking judicial confirmation of the validity of Measure C and the related bond resolutions. California Taxpayers Action Network (CTAN) and other opponents answered, contending that Measure C required a two-thirds vote and was not a bona fide citizens’ initiative. The Superior Court of San Diego County initially granted a motion for judgment on the pleadings, finding that a two-thirds vote was required, and entered judgment against the City. On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reversed and remanded for further proceedings to determine whether Measure C was a bona fide citizens’ initiative.On remand, the trial court conducted a bench trial and rejected CTAN’s arguments, finding that it had subject matter jurisdiction, the case was ripe, the special fund doctrine exempted the bonds from the two-thirds vote requirement, and Measure C was a bona fide citizens’ initiative requiring only a simple majority vote. The California Court of Appeal affirmed the trial court’s judgment, holding that Measure C and the related bond resolutions were valid, and that the trial court properly excluded certain hearsay evidence. View "Alliance San Diego v. California Taxpayers Action Network" on Justia Law

A man was charged in 2002 with multiple sexual offenses involving three minor males. In 2003, he entered a plea agreement, pleading no contest to several counts of committing lewd acts on children aged 14 or 15 and one count of oral copulation with a victim under 16, which was amended from a charge of forcible oral copulation to a nonforcible offense. He did not admit to using force or violence in his plea, but the factual basis for the plea referenced police reports describing acts involving force. He was sentenced to state prison in accordance with the plea agreement.In 2005, two psychologists evaluated him for commitment as a Mentally Disordered Offender (MDO) under California Penal Code section 2962. A chief forensic psychiatrist certified that he met the criteria, including having committed a crime involving force or violence, based on documentary evidence such as probation and police reports. The Board of Parole Hearings affirmed the certification. He did not challenge the certification in superior court at that time. He remained in custody under annual recommitment petitions, and his only prior challenge was an unsuccessful appeal of a 2022 recommitment order.After that, he filed a habeas corpus petition in Fresno County Superior Court in 2023, arguing that his conviction did not qualify as an MDO offense and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is a proper vehicle to challenge an initial MDO certification based on static factors, even years later. The court found that the evidence was sufficient under the law at the time of certification, and that subsequent changes in evidentiary standards were not retroactive. The court also found no ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

The plaintiff, a former employee, brought a lawsuit against his employer alleging multiple claims of discrimination and harassment. The employer successfully moved to compel arbitration pursuant to an agreement between the parties. During the arbitration, the arbitration provider issued an invoice for fees, which the employer attempted to pay electronically on the last day of the statutory 30-day deadline. However, due to a processing delay, the payment was not received by the provider until three days after the deadline.The Superior Court of Los Angeles County found that the employer’s failure to ensure the arbitration fees were received within the 30-day period constituted a material breach of the arbitration agreement under California Code of Civil Procedure section 1281.98. The court vacated its prior order compelling arbitration, returned the case to court, and awarded the plaintiff $1,750 in sanctions for expenses incurred in bringing the motion. The plaintiff then sought over $300,000 in attorney fees and costs under section 1281.98, subdivision (c)(1), which allows recovery of all fees and costs associated with an abandoned arbitration. The trial court granted only a reduced amount, reasoning that the plaintiff was entitled only to fees and costs for work rendered useless by the termination of arbitration.On appeal, the California Court of Appeal, Second Appellate District, Division One, considered the impact of the California Supreme Court’s decision in Hohenshelt v. Superior Court (2025) 18 Cal.5th 310. Hohenshelt held that federal law preempts a strict application of section 1281.98, and that forfeiture of arbitral rights occurs only if the failure to pay fees is willful, grossly negligent, or fraudulent. The appellate court determined that the employer’s late payment was not willful, grossly negligent, or fraudulent, and therefore, the plaintiff was not entitled to attorney fees under section 1281.98, subdivision (c)(1). The order awarding attorney fees and costs was reversed. View "Wilson v. Tap Worldwide, LLC" on Justia Law

In December 2007, the defendant participated in a gang-related shooting in which he, along with two other gang members, drove into rival territory. The defendant, seated in the back of the car, rolled down his window, confronted a rival gang member, exited the vehicle, and fired multiple shots, injuring the victim but not fatally. After the incident, the driver, an uninvolved high school student, reported the shooting to authorities. The defendant later admitted to being the shooter.The Orange County District Attorney charged the defendant and his codefendants with attempted murder, street terrorism, and related enhancements. In 2011, the defendant pleaded guilty and received a negotiated 19-year sentence. One codefendant went to trial and was convicted by a jury of the same charges and enhancements. In 2022, the defendant filed a petition under Penal Code section 1172.6 to vacate his attempted murder conviction and be resentenced, arguing that changes in the law regarding accomplice liability applied to his case. At the evidentiary hearing, the Superior Court of Orange County admitted transcripts from the codefendant’s trial over the defendant’s objection and denied the petition, finding the defendant was the actual shooter and thus ineligible for relief.On appeal, the defendant argued that the trial court erred by admitting evidence from a trial in which he was not a party. The California Court of Appeal, Fourth Appellate District, Division Three, held that Penal Code section 1172.6(d)(3) allows the admission of evidence from any prior hearing or trial, so long as it is admissible under current law, regardless of whether the petitioner was a party to that proceeding. The court affirmed the trial court’s order denying the petition. View "P. v. Ramos" on Justia Law

A registered nurse was convicted by a jury of misdemeanor elder or dependent adult abuse for her role in the care of a 62-year-old dependent adult, Michael H., at an unlicensed boarding house in Riverside, California. The facility, Secure Hands, was not authorized to provide medical care and was intended for residents who could manage their own daily activities. However, Michael, who had recently suffered a stroke and had significant physical and mental limitations, was admitted to the facility under the nurse’s assessment and supervision. The nurse determined his care needs, recommended equipment, and was responsible for ensuring that appropriate caregivers were available. Despite knowing the facility was not equipped for dependent adults, she admitted Michael and did not report or address ongoing concerns about his care, including poor hygiene and lack of basic necessities, which were repeatedly brought to her attention.The Superior Court of Riverside County initially charged the nurse with four counts of felony elder or dependent adult abuse, but one count was dismissed before trial. The jury deadlocked on two counts, resulting in a mistrial for those, but found her guilty of the lesser included misdemeanor offense regarding Michael. She was sentenced to four months in county jail and fined $1,000.On appeal, the nurse argued that the definition of “care or custody” from the Elder Abuse and Dependent Adult Civil Protection Act should apply to her criminal prosecution, and that there was insufficient evidence she had such responsibility. The California Court of Appeal, Fourth Appellate District, Division Two, rejected this argument, holding that “care or custody” in Penal Code section 368(c) should be interpreted according to its plain and ordinary meaning, not the more restrictive civil definition. The court found substantial evidence supported the jury’s verdict and affirmed the conviction. View "P. v Molina" on Justia Law

A criminal defendant was charged with murder and released on a $1 million bail bond posted by United States Fire Insurance Company. After his release, the defendant appeared at several hearings, sometimes personally and sometimes through his attorney under a Penal Code section 977 waiver, which allows a defendant to be represented by counsel at certain proceedings. On March 15, 2022, the court ordered the defendant to return for all future hearing dates and continued the bond. On April 26, 2022, the defendant’s attorney appeared on his behalf, and the court ordered the defendant to be personally present at the next hearing. The defendant failed to appear on May 18, 2022, citing illness, and again on June 2, 2022, at which point the court vacated the trial date, forfeited the bond, and sent notice to the surety.United filed a motion in the Superior Court of Riverside County to vacate the forfeiture and exonerate the bond, arguing that the court should have forfeited the bond on April 26, 2022, when the defendant first failed to appear without sufficient excuse, and that the June 2 forfeiture was void for lack of jurisdiction. The trial court denied the motion. After summary judgment was entered against United, it filed a motion to set aside the judgment, again arguing lack of jurisdiction. The trial court denied this motion, finding the issue barred by res judicata.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of the motion to set aside summary judgment. The court held that the trial court was not divested of jurisdiction to forfeit the bail bond on June 2, 2022, because the defendant was not required to personally appear on April 26, 2022, and his appearance through counsel was valid under section 977. The order denying the motion to set aside summary judgment was affirmed. View "People v. United States Fire Insurance Co." on Justia Law

A consumer defaulted on credit payments, and the debt was assigned to a third-party debt collector. The collector sent a collection letter to the consumer that included mandatory language about debtor rights, but the notice used a smaller type size than required by California law. The consumer, on behalf of himself and a proposed class, filed suit alleging that the collection notices violated the type-size requirements of the Consumer Collection Notice law and, by extension, the Rosenthal Fair Debt Collection Practices Act. The suit sought statutory damages, attorney fees, costs, and injunctive relief.The Superior Court of Lake County granted summary judgment in favor of the debt collector. The court reasoned that the consumer and the class lacked standing to pursue statutory damages because they had not alleged or demonstrated any actual injury, harm, or loss resulting from the violation. The court concluded that civil liability under the relevant statutes could not be imposed without proof of actual or reasonably foreseeable harm.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The appellate court held that, under the Collection Notice law and the Rosenthal Act, a consumer has standing to seek statutory damages based solely on a statutory violation, regardless of whether the consumer suffered actual injury. The court explained that the statutory scheme authorizes recovery of statutory damages as a penalty to deter violations, not merely to compensate for actual harm. The court distinguished the relevant statutes from others that require proof of injury and rejected the argument that federal standing requirements or the use of the term “damages” limited standing to those who suffered actual harm. The judgment of the trial court was reversed. View "Kashanian v. National Enterprise Systems" on Justia Law

A fatal traffic accident occurred when a tractor trailer, driven by Andre Hill, ran a stop sign and collided with a vehicle driven by Olivia Mendoza, resulting in her death. Prior to the accident, Hill had picked up produce from Irigoyen Farms for delivery to a Walmart distribution center. The transportation of the produce involved several intermediaries: Irigoyen Farms contracted with a freight broker, who in turn contracted with other logistics companies, ultimately resulting in Hill being hired as an independent contractor by the motor carrier. Law enforcement determined that Hill’s extreme fatigue contributed to the crash.The decedent’s mother, Christina Casarez, filed suit in the Superior Court of Fresno County against Irigoyen Farms and Walmart, alleging motor vehicle negligence, general negligence, and wrongful death. She claimed that both defendants were directly negligent in their roles: Walmart for imposing contractual requirements that allegedly incentivized unsafe conduct, and Irigoyen Farms for loading the truck and sending Hill on his way despite knowledge of his fatigue. Both defendants moved for summary judgment, arguing that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) preempted Casarez’s claims. The superior court agreed, granting summary judgment in favor of both defendants.On appeal, the California Court of Appeal, Fifth Appellate District, reviewed the superior court’s decision de novo. The appellate court held that the FAAAA expressly preempts state law negligence claims against parties whose actions relate to the price, route, or service of a motor carrier with respect to the transportation of property, regardless of whether the party is a motor carrier, broker, or shipper. The court further held that the FAAAA’s safety exception did not apply because the claims did not directly concern the safety of the motor vehicle itself. The appellate court affirmed the superior court’s judgments in favor of Irigoyen Farms and Walmart. View "Casarez v. Irigoyen Farms" on Justia Law