Justia California Court of Appeals Opinion Summaries

In April 1996, James Alvin Thompson was convicted of first-degree murder with special circumstances, including committing the murder during a robbery and having a prior murder conviction. The jury sentenced him to death. Thompson's conviction and sentence were affirmed on direct appeal. Following the enactment of Senate Bill No. 1437, which amended the felony murder rule, Thompson filed a petition for resentencing. The trial court summarily denied the petition, citing the special circumstances findings as rendering him ineligible for relief.The California Supreme Court had previously affirmed Thompson's conviction and sentence. Thompson also filed a habeas corpus petition, which was transferred to the Riverside County Superior Court and subsequently denied. Thompson appealed the denial, but the appeal was stayed due to funding issues for appellate habeas counsel. In January 2022, Thompson filed a petition for resentencing under Senate Bill No. 1437, which the trial court denied at the prima facie stage.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court concluded that a capital defendant is entitled to seek resentencing relief under section 1172.6, but must do so through a petition for writ of habeas corpus pursuant to section 1509, in compliance with Proposition 66. The court vacated the trial court's order denying Thompson's resentencing petition and remanded the case with directions to allow Thompson to file a limited petition for writ of habeas corpus challenging his murder conviction under section 1172.6. The court emphasized that the trial court must follow the procedures outlined in section 1172.6, including appointing counsel if requested and holding a hearing to determine if Thompson has made a prima facie case for relief. View "P. v. Thompson" on Justia Law

Khyle Armando Briscoe, at age 21, participated in a robbery during which his accomplice, Shaun P., was fatally shot by the victim, Ben P. Briscoe was convicted of first-degree murder, robbery, and burglary, with a special circumstance finding under Penal Code section 190.2, subdivision (d), which led to a life without parole sentence. This special circumstance applies to non-killer participants in felonies who act with reckless indifference to human life.The trial court sentenced Briscoe to life without parole, and the conviction was affirmed on appeal. Briscoe later sought a parole hearing under Penal Code section 3051, which allows certain youth offenders to seek parole but excludes those sentenced to life without parole for special circumstance murder. The trial court denied his motion, and Briscoe appealed.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court noted that section 3051 was intended to provide youth offenders with a meaningful opportunity for release based on demonstrated growth and rehabilitation. However, the statute excludes youth offenders sentenced to life without parole for special circumstance murder. Briscoe argued that this exclusion violated equal protection, particularly because section 190.2, subdivision (d) employs the same standard of liability as section 189, subdivision (e)(3), which does not exclude youth offenders from parole consideration.The Court of Appeal agreed with Briscoe, finding that the exclusion of youth offenders sentenced under section 190.2, subdivision (d) from parole consideration under section 3051 violated equal protection. The court reversed the trial court's order and remanded the case for a parole hearing and related proceedings. View "P. v. Briscoe" on Justia Law

Shahriyar Shayan appealed an order denying his motion to quash a writ of execution for attorney fees filed by Zohreh McIntyre Shayan. Shahriyar argued that the writ should be quashed because it was sought more than ten years after the entry of judgment, violating Code of Civil Procedure section 683.020, and was subject to the renewal requirements of Code of Civil Procedure section 683.130. He contended that judgments for attorney fees under the Family Code are not exempt from these requirements.The Superior Court of Los Angeles County denied Shahriyar's request to set aside the writ of execution. The court found that the judgment for attorney fees, entered under the Family Code, was enforceable until satisfied in full and did not require renewal under Family Code section 291, subdivision (b). Shahriyar appealed this decision.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that when a judgment for attorney fees is entered under the Family Code, it is enforceable until paid in full, and failure to renew the judgment does not affect its enforceability. The court found that the plain language of Family Code section 291, its legislative history, and common sense supported this interpretation. The court affirmed the lower court's order, concluding that Family Code section 291's reference to money judgments includes those for attorney fees, exempting them from the ten-year limitation and renewal requirements of the Code of Civil Procedure. View "In re Marriage of Shayan" on Justia Law

Lucky Chances, Inc. and its owners, Rommel and Ruell Medina, had their gambling licenses renewed by the California Gambling Control Commission with additional conditions. The Commission also imposed a 14-day suspension, stayed it, and ordered a monetary penalty based on findings that Rene Medina, a disqualified person, was materially involved in the gambling operation. The trial court issued a writ of administrative mandamus, ordering the Commission to reconsider the penalty, limiting it to $20,000 per violation.The Superior Court of Sacramento County found substantial evidence supporting the Commission's finding of Rene's material involvement but ruled that the monetary penalty exceeded statutory limits. The court ordered the Commission to set aside the penalty and reconsider it in light of the court's decision.The California Court of Appeal, Third Appellate District, reviewed the case. The court concluded that the Commission was authorized to impose additional license conditions based on its findings. However, it determined that the Commission could not use California Code of Regulations, title 4, section 12554, subdivision (d) to impose discipline because the Commission did not find that the Licensees violated any relevant law, regulation, or previously imposed license condition.The Court of Appeal modified the judgment to order the Commission to reconsider the discipline imposed under California Code of Regulations, title 4, section 12554, subdivision (d) in a manner consistent with its opinion. The judgment, as modified, was affirmed, and costs on appeal were awarded to Lucky Chances, Inc., Rommel Medina, and Ruell Medina. View "Lucky Chances, Inc. v. Cal. Gambling Control Com." on Justia Law

Govind Vaghashia and other plaintiffs appealed a trial court order denying their motion to vacate a settlement agreement with Prashant and Mita Vaghashia. The settlement involved a $35 million payment from the Govind Parties to Prashant and Mita, with specific terms about property collateral and a quitclaim deed for a residence. Disputes arose over the interpretation of the agreement, leading to motions to enforce it by both parties. The trial court enforced the agreement but not in the manner the Govind Parties desired.The Los Angeles County Superior Court initially heard the case, where Prashant and Mita sued Govind and his affiliates, claiming a 50% interest in their business ventures. Govind counter-sued for mismanagement. A bench trial began but was paused for settlement discussions, resulting in the contested agreement. When disputes over the settlement terms emerged, both parties filed motions to enforce the agreement. The trial court ruled largely in favor of Prashant and Mita, enforcing the settlement.The California Court of Appeal, Second Appellate District, reviewed the case. The court found no abuse of discretion in the trial court's decision, holding that the Govind Parties were judicially estopped from seeking to vacate the settlement agreement after previously moving to enforce it. The appellate court noted that the Govind Parties' positions were totally inconsistent and that they had been successful in asserting the enforceability of the agreement in their initial motion. The court affirmed the trial court's orders, including the denial of the motion to vacate the settlement agreement. View "Vaghashia v. Vaghashia" on Justia Law

Plaintiffs filed two class action complaints against Experian Information Solutions, Inc. in Orange County Superior Court, alleging violations of the Fair Credit Reporting Act (FCRA). They claimed that Experian failed to include a required statement in the "Summary of Rights" portion of their consumer reports, which informs consumers of additional rights under state law. Plaintiffs sought actual, statutory, and punitive damages. Experian removed the cases to federal court, where Plaintiffs argued they lacked standing under Article III of the U.S. Constitution because they did not suffer concrete harm. The federal court agreed and remanded the cases back to state court.In state court, Experian moved for judgment on the pleadings, arguing that Plaintiffs lacked standing under Wisconsin law and that their FCRA claim did not fall within the "zone of interests" the FCRA is designed to protect. Plaintiffs contended that California law should apply and that they had standing under California law. The trial court granted Experian's motion, relying on the precedent set by Limon v. Circle K Stores Inc., which held that a plaintiff must allege a concrete injury to have standing in California state courts. Plaintiffs appealed the decision.The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court's judgment. The court found Limon persuasive and concluded that Plaintiffs lacked standing because they did not allege a concrete or particularized injury. The court held that an informational injury without adverse effects is insufficient to confer standing under California law. Therefore, the judgment in favor of Experian was affirmed. View "Muha v. Experian Information Solutions" on Justia Law

Two defendants, Martin Field and John Asher, were found to be sexually violent predators (SVPs) by separate juries and committed indefinitely to a state hospital. They were compelled to testify against themselves during their commitment trials. Both argued on appeal that they were similarly situated to individuals found not guilty by reason of insanity (NGIs), who are not required to testify against themselves at their commitment trials. They claimed this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, previously found merit in Field's equal protection argument and remanded the case to the Superior Court of San Bernardino County for an evidentiary hearing. The same conclusion was reached for Asher's case by Division Three of the Fourth Appellate District. The trial court held an evidentiary hearing and determined that the People had not met their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated and ordered new commitment trials for both Field and Asher.The People appealed the new trial orders, arguing that the trial court erred in finding that the disparate treatment of SVPs was not justified. The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court's orders. The appellate court held that the People had not demonstrated that the testimony of SVPs was more necessary than that of NGIs to justify the disparate treatment under the strict scrutiny standard. The court emphasized that there were sufficient records and other means to evaluate SVPs without compelling their testimony, and thus, the equal protection violation was not justified. View "P. v. Field" on Justia Law

The case involves a father (H.B.) appealing a juvenile court's disposition order that declared his two sons dependents of the court, placed them in the custody of their mother, and provided family maintenance services to the mother and supportive services to the father. The San Francisco Human Services Agency filed a petition alleging that the minors were at substantial risk of harm due to the father's substance abuse and provision of drugs to one of the children. The father contested the findings, arguing that the juvenile court applied an incorrect legal standard and that there was insufficient evidence to support its findings.The juvenile court sustained the petition's allegations, assumed jurisdiction over the children, and ordered their placement with the mother. The court found that the father posed a substantial danger to the children due to his substance abuse and poor parenting decisions, including providing drugs to his son. The court applied section 362, subdivision (c), rather than section 361, subdivision (c), concluding that the children were not removed from a custodial parent since they remained with their mother.The California Court of Appeal, First Appellate District, reviewed the case. The court determined that the juvenile court erred in applying section 362(c) instead of section 361(c), as the children were effectively removed from the father's custody. The appellate court found substantial evidence supporting the juvenile court's finding of substantial danger to the children if returned to the father's care. However, it concluded that there was insufficient evidence to support the finding that reasonable efforts were made to prevent or eliminate the need for removal. The appellate court reversed the disposition order and remanded the case for a new disposition hearing, instructing the juvenile court to make its decision based on the facts existing at the time of the new hearing. View "In re H.B." on Justia Law

Santa Rita Holdings, Inc. applied for a conditional use permit (CUP) from the County of Santa Barbara to cultivate cannabis on a 2.54-acre parcel owned by Kim Hughes. The only access to the parcel is through a private easement over land owned by JCCrandall, LLC. The County's fire and public works departments deemed the road adequate for the project. Despite JCCrandall's objections, the County granted the CUP, and the Board of Supervisors upheld this decision.JCCrandall petitioned for a writ of administrative mandate, arguing that the use of the easement for cannabis activities was prohibited by the easement deed and federal law, that state law required their consent for such activities, and that the road did not meet County standards. The trial court denied the petition, applying the substantial evidence standard and finding the County's decision supported by substantial evidence.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court determined that the trial court erred in applying the substantial evidence standard instead of the independent judgment standard, as JCCrandall's right to exclude unauthorized persons from their property is a fundamental vested right. The appellate court held that under federal law, cannabis is illegal, and thus, the use of the easement for cannabis transportation exceeds the scope of the easement. The court also found that the County's reliance on Civil Code section 1550.5, subdivision (b), which deems cannabis activities lawful under California law, defies the Supremacy Clause of the U.S. Constitution. Consequently, the judgment was reversed, and costs were awarded to JCCrandall. View "JCCrandall v. County of Santa Barbara" on Justia Law

In 2019, Steven Watts, an automotive repair shop owner, was diagnosed with mesothelioma, a cancer caused by asbestos exposure. He and his wife, Cindy Watts, filed a lawsuit against 28 defendants, later adding eight more. By the time of trial, only one defendant, Pneumo Abex, LLC (Abex), a brake linings manufacturer, remained. The jury awarded the plaintiffs $2,943,653 in economic damages, $6.75 million in noneconomic damages, and $1 million for loss of consortium, attributing 60% fault to Abex, 25% to other brake manufacturers, and 15% to Watts.The trial court directed a verdict against Abex on its sophisticated user defense and made several rulings on the allocation of fault. Abex appealed, arguing for a new trial on all issues, particularly challenging the directed verdict on the sophisticated user defense and the allocation of fault.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court found that the trial court erred in directing a verdict against Abex on the sophisticated user defense, as there was substantial evidence that Watts, as a trained mechanic and business owner, should have known about the dangers of asbestos. The court also found errors in the trial court's rulings on the allocation of fault, including the exclusion of joint compound manufacturers from the verdict form and the preclusion of Watts's interrogatory responses.The appellate court concluded that these errors warranted a new trial. The court reversed the September 15, 2022 judgment, the November 28, 2022 order, and the March 20, 2023 amended judgment, and remanded the case for a new trial. Abex was awarded its costs on appeal. View "Watts v. Pneumo Abex" on Justia Law