Justia California Court of Appeals Opinion Summaries

A former hourly, nonexempt employee of a large lumber manufacturer filed a class action in October 2018 alleging wage and hour violations on behalf of eight classes of present and former employees. Many employees had signed arbitration agreements that precluded class actions and required arbitration of employment-related disputes, but neither the named plaintiff nor other named plaintiffs were signatories. Throughout several years of litigation, the employer did not identify signatory employees or produce the signed arbitration agreements, despite being ordered to do so. The employer participated in extensive discovery and litigation regarding all putative class members, including those who had signed the agreements.The Superior Court of Shasta County reviewed the case and, after extensive discovery disputes, granted class certification for eight classes in November 2022. Following class certification, the employer produced over 3,000 signed arbitration agreements and promptly moved to compel arbitration for class members who had signed the agreements. The plaintiffs opposed this, arguing the employer had waived its right to compel arbitration due to its prior litigation conduct, including failure to produce agreements and treating signatory employees as class members throughout discovery. The trial court denied the employer’s motion to compel arbitration, finding waiver under the St. Agnes test, and granted sanctions precluding the employer from presenting evidence of the arbitration agreements or arguing that class members had signed them.Upon appeal, the Court of Appeal of the State of California, Third Appellate District, affirmed the order denying the motion to compel arbitration and dismissed the appeal from the sanctions order. The main holding was that the employer had waived its contractual right to compel arbitration by conduct that was inconsistent with an intent to arbitrate, including withholding the agreements and treating signatory employees as class members, as established by clear and convincing evidence. The court dismissed the appeal regarding sanctions for lack of appellate jurisdiction. View "Sierra Pacific Industries Wage and Hour Cases" on Justia Law

For many years, one company exclusively provided emergency medical services (EMS) in a California county. Seeking improvements, the county initiated a competitive bidding process, issuing a request for proposals (RFP) and identifying policy goals such as improved service, efficiency, and reinvestment. Two entities submitted proposals. After evaluation by a review committee, one received the highest cumulative score, while the other received higher scores from most individual evaluators. The county determined the scores were substantially equivalent and proceeded to negotiate with both parties, ultimately awarding the contract to the bidder that did not have the highest cumulative score.The company that lost the contract protested the decision, arguing the county was required to negotiate only with the highest-scoring proposer, as set forth in the RFP. After an unsuccessful protest, the losing bidder first sued in federal court, where its federal antitrust claims were dismissed under the Parker immunity doctrine, and the district court declined to address state law claims. The company then filed a new action in San Bernardino County Superior Court, seeking a writ of mandate and a preliminary injunction. The superior court found the county’s selection process was ministerial and that the RFP required negotiations only with the highest-scoring proposer. The court granted a preliminary injunction, halting the contract’s implementation.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that neither the governing statute (the EMS Act) nor the RFP imposed a ministerial duty on the county to negotiate exclusively with the highest-scoring proposer. The court further concluded the county acted within its discretionary authority and did not abuse its discretion by considering both proposals. The appellate court reversed the preliminary injunction and remanded the case to the superior court, directing it to deny the motion for a preliminary injunction and reconsider the bond amount. View "American Medical Response of Inland Empire v. County of San Bernardino" on Justia Law

Plaintiffs, comprised of several California cities and counties, initiated legal action against Citgo Petroleum Corporation and other fossil fuel companies, alleging that their purchase, distribution, and sale of fossil fuel products in California contributed to climate-related harms within the state. The plaintiffs asserted that Citgo and others participated in extensive business operations involving fossil fuels in California from the 1980s to the mid-2000s. They claimed the defendants knew about the environmental dangers posed by fossil fuels but failed to warn the public, instead allegedly engaging in deceptive marketing and disinformation campaigns to obscure climate-related risks.After identical complaints were filed against all defendants, Citgo moved to quash service of summons, arguing lack of personal jurisdiction. Citgo maintained its activities in California were too limited and lacked sufficient connection to the alleged injuries. The Superior Court of San Francisco granted Citgo’s motion, finding that Citgo’s contacts with California did not satisfy the “relatedness” requirement for specific jurisdiction, as there was insufficient evidence of deceptive conduct directed at California. The court denied similar motions by other defendants, concluding that their broader contacts with California supported jurisdiction.Reviewing the case de novo, the California Court of Appeal, First Appellate District, Division Three, determined that specific personal jurisdiction over Citgo was proper. The court held that Citgo’s direct involvement in the distribution and sale of branded gasoline in California, without providing warnings about climate risks, sufficiently related to plaintiffs’ claims. The court further found that exercising jurisdiction would be fair and reasonable given California’s significant interest in redressing local climate harms. The order granting Citgo’s motion to quash was reversed, with instructions to deny the motion, allowing the case to proceed against Citgo in California. View "In re Fuel Industry Climate Cases" on Justia Law

Enrique Aguilar was involved in a shootout with San Diego Police Department officers after leading one officer on a foot chase during which he brandished a gun. Although Aguilar was wounded, none of the officers were hit, and a bullet fired from Aguilar’s direction struck a nearby store door. Aguilar was charged with multiple offenses, including attempted voluntary manslaughter, assaulting peace officers with a semiautomatic firearm, shooting at an occupied building, possessing methamphetamine while armed, and being a felon in possession of a firearm. At trial in September 2023, a jury convicted him of all charges and the court sentenced him to a lengthy prison term.During jury selection in the Superior Court of San Diego County, the prosecutor used a peremptory challenge to strike a Latina juror (Juror 1), claiming she struggled to understand the concept of intent, as revealed by her responses to a hypothetical question. Aguilar objected, arguing that the prosecutor was improperly excluding Hispanic and Latina jurors. The trial court accepted the prosecutor’s explanation, found Juror 1’s answers equivocal and overruled Aguilar’s objection, determining that ethnicity was not a factor in the challenge.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of Aguilar’s objection de novo, as required by Code of Civil Procedure section 231.7. The appellate court found no substantial evidence supporting the trial court’s finding that Juror 1 was confused about intent; her answers were clear and consistent. The court held that “juror confusion” is a presumptively invalid reason for a peremptory challenge under section 231.7, and that the prosecution failed to rebut this presumption. The judgment was reversed and the case remanded for a new trial. View "P. v. Aguilar" on Justia Law

John Doe was a motivational speaker who, for nearly thirty years, was featured, promoted, and endorsed by the California Association of Directors of Activities (CADA) to intermediate and high school audiences. In 2022, CADA received an email from a former church youth group member alleging that Doe, under a different name in the 1990s, had engaged in an inappropriate sexual relationship with a 17-year-old student. After an independent investigation, CADA concluded that Doe was likely the person in question and terminated its association with him. CADA notified its members of the termination without disclosing the nature of the accusation.Doe filed suit in Santa Cruz County Superior Court against both CADA and the accuser, asserting tort and contractual claims. Both defendants filed special motions to strike under California’s anti-SLAPP statute. The trial court granted the accuser’s motion, finding Doe’s claims against her were protected by the common interest privilege and lacked evidence of malice. Regarding CADA, the trial court found the claims arose from protected activity but denied CADA’s motion to strike most of Doe’s claims, concluding Doe showed a sufficient probability of prevailing, particularly on contract-based claims.On appeal, the California Court of Appeal, Sixth Appellate District, reviewed the trial court’s order denying CADA’s anti-SLAPP motion. The appellate court held that all of Doe’s tort claims and contractual claims based on CADA’s communications were subject to the common interest privilege and must be stricken, as Doe did not show CADA acted with malice. However, the court affirmed the denial of the motion as to Doe’s contractual claims based on his termination, concluding Doe demonstrated minimal merit and that public policy did not bar enforcement. The appellate court reversed in part and remanded, directing the lower court to strike the specified claims and allegations. View "Doe v. California Assn. of Directors of Activities" on Justia Law

SoCal Lien Solutions, LLC attempted to serve process on a domestic corporation, BDB Properties, at the address listed in public records for its principal office, executive officers, and agent for service of process. After multiple unsuccessful attempts to serve BDB’s designated agent, SoCal obtained a court order under California Corporations Code section 1702 authorizing service by hand delivery of the summons and complaint to the Secretary of State. SoCal delivered the documents to the Secretary on June 10, 2022. The Secretary did not forward notice of service to BDB until October 24, 2022, which was after the court had entered a default and default judgment against BDB.BDB later sought to set aside the default and judgment, first by ex parte application, which was denied, and then by a noticed motion under Code of Civil Procedure section 473.5. The Superior Court of Los Angeles County found BDB’s motion untimely under section 473.5 but granted relief on the ground that service was not complete until the Secretary mailed notice of the documents to BDB, rendering the judgment void.The California Court of Appeal, Second Appellate District, Division One, reviewed the statutory language of Corporations Code section 1702 and determined that service is deemed complete ten days after the documents are delivered to the Secretary, regardless of when the Secretary forwards notice to the corporation. The court held that the lower court erred in ruling that service was incomplete until the Secretary mailed notice. The Court of Appeal reversed the order setting aside the default and default judgment and directed the trial court to vacate its order granting BDB’s motion. The main holding is that service on a corporation via the Secretary of State under section 1702 is complete ten days after delivery, and subsequent mailing of notice by the Secretary is not required to complete service. View "Socal Lien Solutions, LLC v. BDB Properties" on Justia Law

Rebecca Eisenberg, a director of the Santa Clara Valley Water District, was permitted to review two confidential investigation reports at the District’s facility in January 2024. These reports, prepared by outside counsel, addressed allegations of misconduct by Eisenberg and complaints she raised against staff. The District explicitly instructed Board members not to remove the reports from the premises. Eisenberg nevertheless left the facility with the reports, later admitting her actions at Board meetings. After repeated requests for their return and a formal censure by the Board, Eisenberg refused to return the reports.The District filed suit in Santa Clara County Superior Court, asserting claims including conversion and seeking prejudgment recovery of the reports. It successfully moved for a writ of possession and a turnover order, which Eisenberg temporarily stayed by posting a statutory undertaking. The District then sought a mandatory preliminary injunction compelling the return of the reports. Eisenberg opposed this, arguing that the claim and delivery law’s remedy (the writ of possession, now stayed) precluded further injunctive relief and that the District did not meet the requirements for an injunction.The California Court of Appeal, Sixth Appellate District, reviewed the trial court’s order granting the preliminary injunction. The appellate court held that Code of Civil Procedure section 516.050 expressly permits a party to seek injunctive relief for possession of personal property, even after pursuing relief under the claim and delivery law. The court further found no abuse of discretion: the District demonstrated a likelihood of prevailing on its conversion claim and showed that the harm to the District from denial of the injunction outweighed any harm to Eisenberg. The appellate court affirmed the order granting the preliminary injunction, requiring Eisenberg to return the confidential reports. View "Santa Clara Valley Water Dist. v. Eisenberg" on Justia Law

The petitioner was charged in three separate criminal cases for drug-related offenses in Solano County. Two of these cases involved charges under Health and Safety Code section 11395, which was newly established by Proposition 36 and criminalizes possession of a hard drug with two prior drug-related convictions. The third case concerned possession for sale of a controlled substance. The petitioner sought pretrial mental health diversion under Penal Code section 1001.36 for all pending charges, arguing that he had a qualifying mental health diagnosis and was a suitable candidate for diversion, while also requesting treatment under section 11395.The Solano County Superior Court ruled that the petitioner was ineligible for pretrial mental health diversion for the section 11395 charges, interpreting the statute as precluding diversion due to its “notwithstanding any other law” language. The court granted pretrial mental health diversion for the possession for sale charge but denied it for the section 11395 charges, reasoning that the treatment-mandated felony provisions of section 11395 superseded the diversion option. After denial of a motion for reconsideration, the petitioner sought relief via a writ of mandate.The California Court of Appeal, First Appellate District, Division Four, reviewed the statutory interplay between section 11395 and Penal Code section 1001.36 de novo. The court held that section 11395 does not expressly or impliedly preclude trial courts from granting pretrial mental health diversion to defendants charged under section 11395. It found that both statutes can coexist, as section 11395 provides a postconviction treatment path and does not bar the pretrial diversion process. Accordingly, the appellate court directed the superior court to vacate its denial and to reconsider the petitioner’s requests for pretrial mental health diversion under Penal Code section 1001.36. View "Reed v. Superior Court" on Justia Law

After serving nearly 19 years in prison for a series of robberies, the defendant was released on parole. Within eight months, at age 57, he committed 10 new robberies, each involving the use of a pellet gun to threaten employees and take cash. He did not physically harm anyone during these offenses. The jury convicted him of 13 counts of second-degree robbery, finding he had used a deadly and dangerous weapon, and the trial court determined he had three prior serious felony convictions. The defendant was sentenced under California’s Three Strikes law to a total of 369 years to life.Following a change in sentencing law that gave trial judges discretion to strike five-year prior conviction enhancements, the Secretary of the California Department of Corrections and Rehabilitation recommended resentencing. The Superior Court of Los Angeles County recalled the defendant’s sentence, struck the prior conviction and weapon enhancements, and resentenced him to 225 years to life. The defendant appealed, arguing that the resentencing was not a “meaningful modification” as suggested by the uncodified statement of intent from the 2023 bill amending Penal Code section 1172.1, and that his postconviction rehabilitation and low risk of reoffending were not properly considered. He also claimed ineffective assistance of counsel and challenged the trial court’s calculation of postsentence conduct credits.The California Court of Appeal, Second Appellate District, Division One, held that the uncodified statement of legislative intent does not create a mandate for resentencing to advance release or parole dates. The court found no abuse of discretion in the trial court’s decision to leave the Three Strikes sentence intact, given the defendant’s extensive recidivism. The ineffective assistance claims lacked merit, as the arguments were unsupported. However, the appellate court modified the judgment to remove postsentence conduct credits, which should be calculated by the Department of Corrections. The judgment was affirmed as modified, and a separate appeal from the trial court’s decision not to act on the defendant’s motion to vacate the new sentence was dismissed as non-appealable. View "People v. Brammer" on Justia Law

The dispute centers on the City’s decision to relocate a piece of playground equipment known as the Sky Track within Arroyo Park, Davis, California, due to noise complaints from nearby residents. After its installation in 2019, the City received complaints about excessive noise, particularly at night, and responded by commissioning noise studies and implementing mitigation measures, such as restricted hours and physical sound dampening. These measures proved challenging to enforce, leading the City to investigate alternative locations within the park. Expert analysis indicated that relocating the Sky Track to a specific area (Location B) would reduce noise levels at the nearest residences compared to its previous location.Following approval by the City Council to move the Sky Track and the filing of a notice of exemption under three categorical exemptions from the California Environmental Quality Act (CEQA), the plaintiffs challenged the exemption. They filed a verified petition for writ of mandate in the Superior Court of Yolo County, arguing that the unusual circumstances exception to the categorical exemption should apply because of the potential for significant noise impacts. The Superior Court denied the petition, finding substantial evidence that the project fell within the scope of the exemptions and that relocating the equipment would reduce, not increase, noise impacts, thus failing to establish unusual circumstances.On appeal, the California Court of Appeal, Third Appellate District, reviewed whether the unusual circumstances exception was triggered. The court held that mere violation of the City’s noise ordinance does not itself amount to substantial evidence of a significant environmental effect. Furthermore, it found no substantial evidence to support a fair argument that relocating the Sky Track would create a significant adverse noise impact. The court affirmed the lower court’s judgment, concluding that the City acted within its discretion and complied with CEQA’s exemption procedures. View "Krovoza v. City of Davis" on Justia Law