Justia California Court of Appeals Opinion Summaries

Matthew Morrison was convicted of a sexually violent offense and sentenced to prison. Before his release, the Santa Clara County District Attorney filed a petition to commit him as a sexually violent predator under the Sexually Violent Predator Act (SVPA). The trial court found the petition true, declared Morrison a sexually violent predator, and committed him to the State Department of State Hospitals for an indeterminate term.Morrison appealed, arguing that the trial court violated his constitutional rights by not personally advising him of his right to a jury trial and securing a personal waiver of that right. He claimed that the SVPA’s failure to require a personal jury trial advisement and waiver, unlike other civil commitment statutes, violated the constitutional equal protection guarantee.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court determined that Morrison’s equal protection challenge was subject to rational basis review. Since Morrison did not raise the issue in the trial court, the appellate court conditionally affirmed the commitment order and remanded the matter to allow Morrison to raise his equal protection claim before the trial court. The appellate court provided guidance on the principles the trial court should apply when resolving Morrison’s constitutional claim. View "P. v. Morrison" on Justia Law

A.T. was born in May 2024 and tested positive for amphetamine and methamphetamine, as did her mother, M.T. The mother admitted to drug addiction and using methamphetamine throughout her pregnancy. The San Diego County Health and Human Services Agency (Agency) was notified, and A.T. was placed with a relative caregiver, Gloria T. The father, W.M., had a history of domestic violence and substance abuse issues, and had previously been involved in dependency proceedings for his other children, Y.M. and J.G.The Superior Court of San Diego County found that A.T. was a dependent child under section 300 of the Welfare and Institutions Code and ordered her removal from her mother's custody. The court also found that placing A.T. with her father would be detrimental to her well-being, citing his history of domestic violence, ongoing relationship with the mother, and lack of cooperation with the Agency.The father appealed, arguing that section 361, subdivision (d) should apply, which requires a higher standard of proof for removal, and that there was no clear and convincing evidence to support the finding of detriment. The Agency argued that section 361.2, subdivision (a) applied because the father did not have physical custody of A.T. at the time of disposition and sought to assume custody.The California Court of Appeal, Fourth Appellate District, Division One, concluded that section 361.2 applied because the father was the noncustodial parent seeking custody. The court found clear and convincing evidence supporting the juvenile court's finding that placing A.T. with the father would be detrimental to her safety and well-being. The court affirmed the juvenile court's dispositional order, maintaining A.T.'s placement with the relative caregiver and granting the father liberal unsupervised visitation. View "In re A.T." on Justia Law

In 1987, Fred Marion Cain III was charged with the kidnapping, sexual assault, and murder of a six-year-old child. The Solano County Public Defender’s Office was appointed to represent him. The People moved to recuse the Public Defender’s Office, citing a conflict of interest due to its previous representation of Shawn Melton, who was tried twice for the same murder, resulting in mistrials and eventual dismissal. DNA evidence later excluded Melton and implicated Cain. The Public Defender’s Office asserted no conflict existed as they had no connection to Melton’s case files or personnel involved in his defense.The trial court granted the People’s motion to recuse the Public Defender’s Office, expressing concerns about potential conflicts and public perception. The court focused on whether the attorney-client privilege survived Melton’s death and whether the Public Defender’s Office could ethically seek testimony from Melton’s former attorney, Peter Foor. Despite the Public Defender’s Office’s assurances and lack of evidence of any conflict, the court disqualified them based on their stance on the attorney-client privilege and duty of confidentiality.The California Court of Appeal, First Appellate District, reviewed the case. The court concluded that no actual or potential conflict of interest existed. It found no substantial evidence that the Public Defender’s Office possessed confidential information from Melton’s case or that Cain’s defense would be compromised. The court held that the Public Defender’s Office’s ethical stance on not seeking Foor’s testimony did not constitute a conflict of interest. Consequently, the court issued a writ of mandate directing the trial court to vacate its order disqualifying the Public Defender’s Office and to deny the motion to recuse. View "Cain v. Superior Ct." on Justia Law

Pablo Arredondo Padron was hired by Hugo Osoy to install two skylights in Osoy’s home. The project was expected to take 10 to 12 days, with Padron working eight hours each day. However, Padron fell from a ladder and was injured before completing 52 hours of work. Padron sued Osoy for negligence, but the trial court granted summary judgment in favor of Osoy, finding that Padron’s claims were exclusively covered by workers’ compensation.The Superior Court of Los Angeles County ruled that Padron’s employment was covered by workers’ compensation under Labor Code section 3351(d), which includes individuals employed by homeowners for duties incidental to the ownership, maintenance, or use of the dwelling. The court also found that Padron did not fall under the exclusion in section 3352(a)(8)(A), which excludes workers employed for less than 52 hours in the 90 days preceding the injury, because Padron had contracted to work for more than 52 hours.The California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s decision. The appellate court held that the exclusion in section 3352(a)(8)(A) does not apply when the employment is contracted to be for more than 52 hours, regardless of the actual hours worked before the injury. The court also rejected Padron’s arguments that he was not subject to the workers’ compensation system and that Osoy should be estopped from asserting the exclusivity defense. The court concluded that Osoy had secured workers’ compensation coverage through his homeowners’ insurance policy, which included the required coverage by operation of law. Therefore, Padron’s exclusive remedy was under the workers’ compensation system, and the summary judgment in favor of Osoy was affirmed. View "Padron v. Osoy" on Justia Law

Sarah Ann Miles and Jeffrey Gerstein entered into an oral traditional surrogacy agreement in which Miles agreed to conceive and carry a child using her ova and Gerstein's sperm, with the understanding that Gerstein would be the sole parent. The child, E., was born in December 2013, and both parties adhered to the terms of the agreement for seven years, with Gerstein acting as E.'s sole parent and Miles not assuming any parental role.The Superior Court of Sacramento County found that the oral surrogacy agreement was valid and enforceable, determining that Miles was not E.'s parent under the agreement. The court concluded that the parties had a clear understanding that Gerstein would be the sole parent and that Miles would not be involved in the child's upbringing. The court also found that it was not in E.'s best interest for Miles to enter her life as a parent.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the lower court's judgment. The appellate court held that traditional surrogacy agreements do not need to be in writing to be enforceable under California law. The court found that the oral agreement between Miles and Gerstein was valid and that the parties' conduct over the years supported the existence of the agreement. The court also determined that the agreement did not violate public policy or constitutional principles, as Miles never intended to be E.'s parent and did not assume a parental role in E.'s life. The judgment was affirmed, and Miles was ordered to pay Gerstein's costs on appeal. View "Miles v. Gerstein" on Justia Law

In 2021, the Napa Foundation for Options in Education (Napa Foundation) filed a petition with the Napa Valley Unified School District (School District) to establish the Mayacamas Charter Middle School. The School District Board of Education denied the petition, and the Napa Foundation then submitted the petition to the Napa County Board of Education (County Board), which also denied it. The Napa Foundation appealed to the State Board of Education (State Board), which reversed the denials. The School District and the California School Boards Association’s Educational Legal Alliance (Educational Legal Alliance) filed petitions for writs of mandate to set aside the State Board’s decision.The trial court granted the writ petitions, finding that the State Board abused its discretion. The court concluded that the District Board did not provide a fair and impartial hearing process and that the County Board’s decision was supported by substantial evidence, including the fiscal impact of the proposed charter school on the School District.The California Court of Appeal, Third Appellate District, reviewed the case. The court found that the State Board’s determination that the District Board failed to provide a fair and impartial hearing was not supported by substantial evidence. The court also found that the County Board’s written factual findings, which detailed the negative fiscal impact of the proposed charter school, were supported by substantial evidence. The court concluded that the State Board’s decision to reverse the County Board’s denial was arbitrary, capricious, and entirely lacking in evidentiary support.The Court of Appeal affirmed the trial court’s judgments, upholding the denials of the charter school petition by the District Board and the County Board. The court emphasized that the State Board failed to properly apply the abuse of discretion standard in its review of the lower boards’ decisions. View "Napa Valley Unified School Dist. v. State Bd. of Education" on Justia Law

In 2009, John Roe DZ 20, John Roe DZ 21, and John Roe DZ 22 (Plaintiffs) sued an employee of Doe 3, Family Services Organization (Family Services), alleging childhood sexual assault. The trial court dismissed the claims against the employee with prejudice due to the statute of limitations. In 2022, Plaintiffs filed a new complaint against Family Services based on the same allegations, relying on the revival provision of Code of Civil Procedure section 340.1.Family Services demurred to the complaint, arguing that Plaintiffs’ claims could not be revived under section 340.1, subdivision (q), because they were derivative of the claims litigated to finality in the 2009 action. The trial court overruled the demurrer. Family Services then petitioned for a writ of mandate to direct the trial court to vacate its order and sustain the demurrer without leave to amend.The Court of Appeal of the State of California, Sixth Appellate District, reviewed the case. The court held that a claim for derivative liability against a principal is considered “litigated to finality” under section 340.1, subdivision (q), if a previous suit against the agent for the same damages based on the same operative facts was dismissed with prejudice. Consequently, the court issued a writ of mandate directing the trial court to sustain the demurrer but allowed Plaintiffs leave to amend their complaint to potentially allege new facts that could support a cause of action against Family Services. View "Doe 3 v. Superior Ct." on Justia Law

L.H. pled no contest to first-degree murder and was committed to a secure youth treatment facility by the juvenile court. The court set his maximum term of confinement to 25 years to life or until he turns 25, whichever comes first, and applied 734 days of precommitment credits to this term. L.H. appealed, arguing that the court incorrectly applied Welfare and Institutions Code section 875 in setting his maximum term of confinement beyond his 25th birthday and erred in applying his precommitment credits against a theoretical maximum term of 25 years. He also claimed that equal protection principles require his precommitment credits to be applied against a term that does not exceed his 25th birthday.The juvenile court adjudged L.H. a ward of the court and committed him to Briones Youth Academy, Secure Pathway. The court determined that L.H.'s remaining custody time was 22 years and 361 days after applying the precommitment credits.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the juvenile court correctly applied section 875 in setting the maximum term of confinement. The court interpreted section 875, subdivision (c)(1)(A) as providing a separate cap on the length of a ward’s physical confinement, independent of the maximum term of confinement set by the juvenile court. The court also held that the juvenile court did not err in applying L.H.'s precommitment credits against the maximum term of confinement of 25 years, as required by section 875, subdivision (c)(1)(C). The court found no equal protection violation, as the application of precommitment credits was consistent with the statutory requirements.The Court of Appeal affirmed the juvenile court’s disposition order. View "In re L.H." on Justia Law

Ramiro Munoz, a member of a criminal street gang, was convicted in 2008 of first-degree murder and shooting at an occupied motor vehicle, with firearm and gang allegations found true. Munoz, who was 15 years old at the time of the crime, was sentenced to 50 years to life in prison. In 2023, Munoz filed a petition for recall and resentencing under Penal Code section 1170, subdivision (d)(1), arguing that his sentence was the functional equivalent of life without the possibility of parole, making him eligible for relief under the statute.The Superior Court of Los Angeles County denied Munoz's petition, stating that he would be eligible for parole under section 3051 in 2029, when he would be 39 years old. Munoz appealed the decision, and the case was reviewed by the Court of Appeal of the State of California, Second Appellate District, Division Seven.The Court of Appeal affirmed the superior court's decision, holding that Munoz's sentence of 50 years to life is not the functional equivalent of life without the possibility of parole. The court concluded that section 1170, subdivision (d)(1), applies only to juvenile offenders explicitly sentenced to life without the possibility of parole and does not extend to those with lengthy sentences that may be considered de facto life without parole. The court also noted that Munoz would have a realistic opportunity to obtain release from prison during his expected lifetime, distinguishing his case from others with significantly longer sentences. View "People v. Munoz" on Justia Law

Billy Ford worked as a full-time security guard for Parkwest Casino Lotus from September 2018 to December 2021. Upon hiring, Ford signed an arbitration agreement that excluded claims for workers' compensation, unemployment compensation, certain administrative complaints, ERISA claims, and "representative claims under [PAGA]." In February 2022, Ford filed a complaint against Parkwest under PAGA, alleging Labor Code violations, including mandatory off-the-clock health screenings and inaccurate wage statements. Parkwest moved to compel arbitration of Ford's individual PAGA claims and to dismiss the representative PAGA claims, citing Viking River Cruises, Inc. v. Moriana.The Superior Court of Sacramento County denied Parkwest's motion to compel arbitration, finding that the arbitration agreement specifically excluded all PAGA claims. Parkwest appealed, arguing that the agreement was ambiguous regarding the exclusion of individual PAGA claims and that such ambiguity should be resolved in favor of arbitration.The Court of Appeal of the State of California, Third Appellate District, reviewed the case. The court concluded that the arbitration agreement unambiguously excluded all PAGA claims, including individual claims. The court reasoned that the language of the agreement and the circumstances under which it was executed indicated that the parties intended to exclude all PAGA claims from arbitration. The court affirmed the trial court's order denying Parkwest's motion to compel arbitration. View "Ford v. The Silver F" on Justia Law