Justia California Court of Appeals Opinion Summaries

A 16-year-old committed a violent home invasion, during which he sexually assaulted his former neighbor at knifepoint. He was convicted by a jury of multiple offenses, including rape, sodomy, oral copulation, robbery, burglary, and related enhancements. The original sentence was a combination of determinate and indeterminate terms, ultimately resulting in a total sentence of 44 years to life in prison, with parole eligibility at age 60 after a later modification.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that excluding him from resentencing relief violated equal protection principles. The trial court denied the petition, finding that his sentence was not functionally equivalent to LWOP and that, under People v. Heard, he was not eligible for relief.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which is rooted in Eighth Amendment jurisprudence, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as articulated in recent California Supreme Court decisions. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those, like the appellant, sentenced to lengthy terms with parole eligibility within their expected lifetimes. The court concluded that section 1170(d)’s limitation to LWOP sentences does not violate equal protection as applied to a 44-years-to-life sentence. The trial court’s denial of the petition was affirmed. View "People v. Baldwin" on Justia Law

Several utility companies operating in California, including in Ventura County, challenged the property tax rates applied to their state-assessed utility property. They argued that the method used to calculate the debt service component of their property tax rate resulted in a higher rate than that applied to locally assessed, nonutility property (referred to as “common property”). The utilities claimed this disparity violated section 19 of article XIII of the California Constitution, which states that utility property “shall be subject to taxation to the same extent and in the same manner as other property.”The utilities filed suit in the Ventura County Superior Court against the County of Ventura and the California State Board of Equalization, seeking partial refunds for property taxes paid between 2018 and 2023. The County demurred, relying on recent appellate decisions that had rejected similar claims. The parties stipulated that the decision in County of Santa Clara v. Superior Court was binding for purposes of this case, and the trial court sustained the demurrer, entering judgment in favor of the County and the Board.On appeal, the California Court of Appeal, Second Appellate District, Division Six, reviewed the case de novo. The court affirmed the trial court’s judgment, holding that article XIII, section 19 does not require that utility property be taxed at the same or a comparable rate as nonutility property. Instead, the provision is an enabling clause that allows utility property to be subject to property taxation, but does not mandate rate equivalence. The court also found that the general uniformity requirement in article XIII, section 1 does not override the Legislature’s authority to implement reasonable distinctions in tax treatment for utility property. The judgment in favor of the County and the Board was affirmed. View "Pacific Bell Telephone Co. v. County of Ventura" on Justia Law

The case concerns a defendant charged with several sex offenses who asserted his right to a speedy trial. The prosecution sought multiple continuances, arguing that the assigned prosecutor was unavailable due to involvement in another sex offense trial (the Lopez Perez case). However, at the time the continuances were granted, the judge assigned to the Lopez Perez case was still engaged in a different trial and was not available to begin the Lopez Perez trial to conclusion. The defendant objected to the continuances and later moved to dismiss the charges, claiming his statutory speedy trial rights were violated.The Superior Court of the City and County of San Francisco granted the prosecution’s requests for continuances under Penal Code section 1050(g)(2), finding that the prosecutor’s involvement in the Lopez Perez case constituted good cause. The court denied the defendant’s motion to dismiss, concluding that the prosecutor was engaged in another trial “in progress” as required by the statute.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. The court held that, under the standard articulated in Burgos v. Superior Court (2012) 206 Cal.App.4th 817, a trial is “in progress” for purposes of section 1050(g)(2) only if the judge is available and ready to try the case to conclusion, the court has committed its resources, and the parties are ready to proceed. The appellate court found that, at the time of the continuances, the Lopez Perez trial was not “in progress” because the assigned judge was not available to try the case to conclusion. Therefore, the trial court erred in granting the continuances and in denying the defendant’s motion to dismiss. The appellate court issued a writ directing the superior court to vacate its order denying dismissal and to grant the motion to dismiss. View "Hernandez v. Superior Ct." on Justia Law

A licensed physician pled guilty to a misdemeanor violation of California’s Business and Professions Code section 650, which prohibits receiving compensation for patient referrals. As part of a plea agreement, he paid restitution and other fees, and additional charges were dismissed. Before completing his probation, he successfully moved to have the case dismissed under Penal Code section 1385, which allows for dismissal in the interest of justice.Following this, the Department of Industrial Relations (DIR) suspended him from participating in California’s workers’ compensation system, citing Labor Code section 139.21. This statute mandates suspension of any provider convicted of certain crimes related to fraud or abuse of the workers’ compensation system. The physician challenged the suspension in an administrative hearing, arguing that the dismissal of his case meant he was no longer “convicted” under the statute. The administrative law judge rejected this argument and upheld the suspension. The physician then filed a petition for writ of mandate in the Superior Court of Los Angeles County, which denied the petition, finding that the statutory definition of “convicted” included a guilty plea accepted by a court, regardless of later dismissal.On appeal, the California Court of Appeal, Second Appellate District, Division Four, reviewed the matter de novo. The court held that under the plain language of Labor Code section 139.21, a person is considered “convicted” if a guilty plea has been accepted by a court, with no exception for cases later dismissed under Penal Code section 1385. The court found that the physician’s suspension was required by law and affirmed the judgment of the superior court. The DIR was awarded costs on appeal. View "Ahn v. Parisotto" on Justia Law

In 1996, the defendant broke into a home, raped a woman at knifepoint, and carried a child at knifepoint while stealing a firearm and ammunition. He was charged with multiple offenses, including kidnapping to commit robbery and, later, a one-strike rape allegation. After a mistrial due to a deadlocked jury and the emergence of DNA evidence linking him to the crime, the defendant pled guilty in 1998 to several charges under a plea agreement. The plea resulted in the dismissal of the rape charge and the one-strike allegation, and the kidnapping charge was amended. He was sentenced to a determinate prison term, which was later reduced.In 2024, the defendant, who is ethnically Samoan, filed a motion in the Superior Court of Riverside County seeking discovery under the Racial Justice Act (RJA). He argued that the addition of the one-strike allegation before trial was racially motivated, citing a different case involving a white defendant who was not similarly charged. He requested records of comparable cases, including defendants’ races and charges. The People opposed, arguing that the plea negotiations were driven by DNA evidence, not the added charge, and that the comparison case was not analogous. The trial court granted the discovery motion but limited the scope of the records to be produced.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case on a petition for writ of mandate. The appellate court held that the defendant failed to establish good cause for discovery under the RJA because his factual scenario was not plausible in light of the record, the comparison case did not support an inference of racial disparity, and statewide incarceration statistics did not provide specific facts of misconduct in his case. The court granted the writ, directing the trial court to vacate its order granting discovery and to deny the motion. View "People v. Superior Ct. (Lalo)" on Justia Law

Several public utility companies challenged the property tax rates imposed by a California county, arguing that the “debt service component” of the county’s property tax rate for utility property was higher than the average rate for non-utility (common) property. The utilities claimed this violated article XIII, section 19 of the California Constitution, which states that utility property “shall be subject to taxation to the same extent and in the same manner as other property.” The utilities sought a partial refund of property taxes for several fiscal years, asserting that the constitutional provision required rate equality between utility and common property.The Superior Court of Riverside County allowed two local water districts to intervene, as they relied on property tax revenue for bond payments. The county demurred, relying on a recent decision from the California Court of Appeal, Sixth Appellate District, which had rejected a similar claim by utilities in another county. The utilities conceded that this precedent was binding on the trial court but preserved their arguments for appeal. The trial court sustained the demurrer without leave to amend and dismissed the case.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. It considered the text, structure, and legislative history of article XIII, section 19, as well as recent appellate decisions from other districts. The court held that the constitutional provision does not require that utility and common property be taxed at the same rates. Instead, it authorizes local ad valorem taxation of utility property, replacing the prior system of state-level in-lieu taxation, but does not impose a rate limitation. The court also found that prior California Supreme Court precedent did not mandate rate equality. The judgment dismissing the utilities’ lawsuit was affirmed. View "Pacific Bell Telephone Co. v. County of Riverside" on Justia Law

An employee at a hospital operated by the University of California, Los Angeles (UCLA Health) photographed confidential patient information and posted it to his personal Instagram account, despite having received training and signing agreements to protect patient privacy. Although the employee redacted some information, personal details of ten patients remained visible. The hospital responded by placing the employee on administrative leave, ultimately terminating him, notifying affected patients, and reiterating privacy policies to staff. No patients reported adverse consequences from the disclosure.The California Department of Public Health investigated and imposed a $75,000 penalty on the hospital, finding a violation of Health and Safety Code section 1280.15, which requires health facilities to prevent unauthorized disclosure of patient medical information. An administrative law judge (ALJ) upheld the Department’s finding and penalty, interpreting section 1280.15 as imposing strict liability for any unauthorized disclosure, regardless of whether the hospital had implemented appropriate safeguards. The ALJ noted that the Department did not find a violation of section 1280.18, which requires reasonable safeguards, but still held the hospital responsible. The Department adopted the ALJ’s decision.The Regents of the University of California challenged the decision in the Superior Court of Sacramento County, seeking a writ of administrative mandate and declaratory relief. The trial court ruled in favor of the hospital, holding that a violation of section 1280.15 cannot occur without a concurrent violation of section 1280.18, thus importing a reasonableness standard into section 1280.15. The court ordered the Department to vacate its decision and remanded the matter.On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. The court held that section 1280.15 is not a strict liability statute; liability requires a failure to implement reasonable safeguards as mandated by section 1280.18. The hospital was not liable absent proof of such a failure. View "Regents of the Univ. of Cal. v. State Dept. of Public Health" on Justia Law

Angel Lynn Realty, Inc. (ALR) entered into a partnership agreement with Real Estate Portfolio Management, LLC (REPM) to purchase, rehabilitate, and sell properties, splitting profits equally. ALR alleged that REPM breached the agreement by failing to pay over $800,000 in profits and also breached its fiduciary duties. ALR further claimed that Steve George, REPM’s sole member, was the alter ego of REPM. After REPM failed to pay the judgment, ALR conducted a debtor’s examination and asserted that postjudgment actions by George fraudulently drained REPM’s assets to avoid payment.The Superior Court of Sacramento County held a bench trial and found in favor of ALR on the breach of partnership and fiduciary duty claims, awarding nearly $1 million in damages and interest against REPM. However, the court found that ALR had not proven George was REPM’s alter ego and entered judgment accordingly. When ALR later moved to amend the judgment to add George as a judgment debtor based on alleged postjudgment fraudulent conduct, the trial court denied the motion, ruling that collateral estoppel barred relitigation of the alter ego issue since it had already been decided.The California Court of Appeal, Third Appellate District, reviewed the case and held that the trial court erred by applying collateral estoppel without considering whether new facts or changed circumstances had arisen since the prior decision. The appellate court clarified that collateral estoppel does not bar reconsideration of an issue if material facts have changed after the original judgment. The order denying ALR’s motion to amend the judgment was reversed and the case remanded for the trial court to determine whether postjudgment events warrant a different outcome on the alter ego issue. View "Angel Lynn Realty, Inc. v. George" on Justia Law

A married couple with a young child became involved in a physical altercation at their home, during which the father, while intoxicated, struck the mother multiple times. During the incident, the mother was holding their infant son, and the father accidentally hit the child in the face, though the child was not injured. The mother sustained injuries, including a lacerated lip and a cut foot. The police responded, and the father was arrested for domestic violence and child endangerment. Both parents later gave conflicting accounts to social workers, with the mother initially reporting prior incidents of domestic violence, including while she was pregnant or breastfeeding, but later recanting some statements. The father admitted to slapping the mother but denied hitting the child or prior violence.The Los Angeles County Department of Children and Family Services filed a dependency petition under Welfare and Institutions Code section 300, subdivisions (a) and (b), alleging risk of harm to the child due to domestic violence and the father’s substance abuse. The Superior Court of Los Angeles County detained the child from the father, released him to the mother, and ordered services for both parents. At the combined jurisdictional and dispositional hearing, the court found the mother’s initial statements credible, sustained the domestic violence and substance abuse allegations, declared the child a dependent, and removed him from the father’s custody.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that substantial evidence supported the jurisdictional findings under both subdivisions (a) and (b) based on the parents’ history of domestic violence in the child’s presence, including the incident where the father accidentally struck the child. The court also found substantial evidence supported the removal order, given the ongoing risk and the parents’ lack of accountability. The appellate court affirmed the juvenile court’s findings and orders. View "In re Miguel J." on Justia Law

A company that sells jet fuel paid sales tax on all of its jet-fuel sales and later sought a refund, arguing that it should have been taxed on only 20 percent of those sales. The company’s position was based on a 1971 legislative amendment that partially exempted jet-fuel sales from local sales tax, and it contended that a 1991 legislative change eliminating this exemption was invalid because it was not approved by local voters as required by Proposition 62, which mandates voter approval for new or increased local taxes. The relevant counties had adopted ordinances in 1956 that imposed sales tax on all tangible personal property and included provisions automatically incorporating future amendments to the state’s sales tax laws, provided they were not inconsistent with the local ordinances.The Superior Court of Fresno County ruled in favor of the company, finding that the counties’ ordinances did not automatically incorporate the 1991 legislative change eliminating the jet-fuel exemption. The court concluded that the counties failed to pass new local ordinances implementing the change and that the full taxation of jet fuel without voter approval violated Proposition 62. The court ordered a refund and granted declaratory relief, allowing the company to pay tax only on 20 percent of future jet-fuel sales.The California Court of Appeal, Fifth Appellate District, reversed the trial court’s judgment. The appellate court held that the counties’ ordinances did automatically and lawfully incorporate the 1991 legislative elimination of the jet-fuel sales exemption. The court further held that Proposition 62 did not apply because the elimination of a tax exemption is not itself the imposition of a new tax; rather, it is a revision to an exemption within an existing, all-encompassing tax. Therefore, voter approval was not required for the change, and the company was not entitled to a refund. View "Southwest Jet Fuel Co. v. Dept. of Tax and Fee Administration" on Justia Law