Justia California Court of Appeals Opinion Summaries

Travis Rockhill was charged with the murder of Gary Matthews, who was shot outside a friend’s home and later died from his injuries. The prosecution presented evidence that Rockhill had a dispute with Matthews over a scooter sale and was angry with him prior to the shooting. The defense argued that another individual, Louie (“Primo”), was involved and that Rockhill was not the shooter. During Rockhill’s first trial, he made incriminating statements to the courtroom bailiff, but the prosecution did not introduce this evidence. The jury deadlocked, resulting in a mistrial.In the second trial, presided over by Judge Emily Cole, Rockhill testified in his own defense. After both sides rested, Judge Cole sent ex parte text messages to a former colleague at the District Attorney’s office, questioning why the prosecutor was not calling the bailiff as a rebuttal witness and suggesting someone should speak to the prosecutor about it. The prosecution did not act on this suggestion, and Rockhill was convicted of first-degree murder with a firearm enhancement. After the verdict, the prosecution disclosed Judge Cole’s ex parte communications to the defense. Judge Cole recused herself, acknowledging the impropriety but maintaining she had been impartial. Rockhill moved for a new trial based on judicial bias, but Judge Denise McLaughlin-Bennett of the Superior Court of Los Angeles County denied the motion, finding no intent to intervene in the proceedings and no impact on the verdict.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court held that Judge Cole’s ex parte communications constituted a due process violation and structural error, as they demonstrated an unconstitutional probability of actual judicial bias. The court reversed the judgment and remanded the case for a new trial, directing the lower court to grant Rockhill’s motion for a new trial. View "P. v. Rockhill" on Justia Law

Sara Lynn Krueger was charged with the murder of her young daughter, Kayleigh S., in Napa County, California. The prosecution alleged that the murder was committed by torture, and Krueger was tried on the theory that she either directly committed the crimes or aided and abetted her codefendant. The jury was instructed only on first degree murder by torture and not on felony murder or the natural and probable consequences doctrine. In May 2017, the jury found Krueger guilty of first degree murder by torture and assault causing death of a child, but the special circumstance finding of torture was later reversed on direct appeal due to insufficient evidence of specific intent to kill. The conviction for first degree murder was otherwise affirmed, and Krueger was sentenced to 25 years to life.Following legislative changes enacted by Senate Bill No. 1437, which limited certain theories of murder liability, Krueger filed a petition for resentencing under Penal Code section 1172.6, arguing she was eligible for relief because the jury instructions allegedly permitted malice to be imputed based solely on her participation in torture. The Superior Court of Napa County denied her petition at the prima facie stage, finding she was ineligible for relief as a matter of law since she was not convicted under any theory affected by the statutory amendments.The California Court of Appeal, First Appellate District, Division Two, reviewed the case and affirmed the trial court’s denial of Krueger’s petition. The appellate court held that Krueger was prosecuted and convicted solely under a theory of first degree murder by torture, which remains valid after Senate Bill 1437. The jury’s findings and instructions required proof of a mental state more culpable than malice, and thus, Krueger could still be convicted under current law. The court concluded she was ineligible for resentencing relief under section 1172.6. View "P. v. Krueger" on Justia Law

The case concerns Ryan Scott Warner, who was charged with the murder of Kayleigh S., the young daughter of his codefendant, Sara Lynn Krueger. The prosecution alleged that Warner either directly committed the murder or aided and abetted Krueger, with the sole theory presented to the jury being first degree murder by torture. The jury was not instructed on felony murder or the natural and probable consequences doctrine. In 2017, Warner was found guilty of first degree murder by torture and assault causing death of a child. On direct appeal, the Court of Appeal reversed the special circumstance finding due to insufficient evidence of specific intent to kill but affirmed the murder conviction, finding ample evidence of intent to inflict extreme pain for a sadistic purpose.Following legislative changes enacted by Senate Bill No. 1437, which amended California’s murder statutes to eliminate certain forms of accomplice liability and imputed malice, Warner petitioned for resentencing under Penal Code section 1172.6. The Superior Court of Napa County denied his petition at the prima facie stage, concluding Warner had not shown he could not be convicted of murder under the amended statutes. Warner appealed, arguing the trial court improperly engaged in factfinding and that the jury instructions permitted conviction on an impermissible theory of imputed malice.The California Court of Appeal, First Appellate District, Division Two, independently reviewed the record and affirmed the denial of Warner’s petition. The court held that Warner was prosecuted and convicted solely under a theory of murder liability—first degree murder by torture—that remains valid after Senate Bill No. 1437. The jury’s findings necessarily established the required mental state for murder under current law, and Warner was not convicted under any theory affected by the statutory changes. Therefore, Warner is ineligible for resentencing relief under section 1172.6 as a matter of law. View "P. v. Warner" on Justia Law

Several employees of the City and County of San Francisco who joined the city’s retirement system at age 40 or older and later retired due to disability challenged the method used to calculate their disability retirement benefits. The city’s retirement system uses two formulas: Formula 1, which provides a higher benefit if certain thresholds are met, and Formula 2, which imputes service years until age 60 but caps the benefit at a percentage of final compensation. Plaintiffs argued that Formula 2 discriminates against employees who enter the system at age 40 or above, in violation of the California Fair Employment and Housing Act (FEHA).Initially, the San Francisco City and County Superior Court sustained the city’s demurrer, finding the plaintiffs had not timely filed an administrative charge. The California Court of Appeal reversed that decision, allowing the case to proceed. After class certification and cross-motions for summary judgment, the trial court found triable issues and held a bench trial. At trial, plaintiffs presented expert testimony based on hypothetical calculations, while the city’s expert criticized the lack of actual data analysis and highlighted factors such as breaks in service and purchased credits.The California Court of Appeal, First Appellate District, Division Four, reviewed the trial court’s post-trial decision. The appellate court affirmed the trial court’s judgment, holding that the plaintiffs failed to prove intentional age discrimination or disparate impact under FEHA. The court found substantial evidence that Formula 2 was motivated by pension status and credited years of service, not age. The plaintiffs’ evidence was insufficient because it relied on hypotheticals rather than actual data showing a disproportionate adverse effect on the protected group. The appellate court also affirmed the denial of leave to amend the complaint, finding no reversible error. The judgment in favor of the city was affirmed. View "Carroll v. City & County of S.F." on Justia Law

Orlando Rodriguez, while employed as a mechanic, suffered significant head and brain injuries in November 2016. His employer’s insurer, administered by Illinois Midwest Insurance Agency, accepted the injuries as work-related. Beginning in September 2018, Rodriguez’s treating physician repeatedly requested home health care services in six-week increments, which Illinois Midwest generally approved, sometimes after utilization review. In September 2019, a new request for home health care was denied by a utilization review physician, and the denial was communicated to all relevant parties.Rodriguez challenged the denial by seeking an expedited hearing before a workers’ compensation judge. The judge found Rodriguez was entitled to ongoing home health care, reasoning that Illinois Midwest could not terminate the treatment without substantive medical evidence of a change in condition. The judge concluded the utilization review decision was “moot” due to Rodriguez’s ongoing need and relied on Patterson v. The Oaks Farm (2014) 79 Cal.Comp.Cases 910. Illinois Midwest petitioned for reconsideration, but the Workers’ Compensation Appeals Board (WCAB) affirmed the judge’s decision, again relying on Patterson and finding no evidence of changed circumstances.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. The court held that, following legislative reforms in 2004 and 2013, disputes over medical necessity for requested treatments must be resolved through the statutory utilization review and independent medical review processes, not by the WCAB or courts, even for ongoing or continual treatment. The court rejected Patterson’s contrary rule for post-2013 injuries, finding no statutory exception for ongoing treatment. The court annulled the Appeals Board’s decision and remanded the matter for further proceedings consistent with its opinion. View "Illinois Midwest Insurance Agency, LLC v. Workers’ Compensation Appeals Board" on Justia Law

The case involves a long-running dispute between two parties, Baer and Tedder, stemming from Baer's lawsuit against Tedder for malicious prosecution. During the course of this litigation, Baer filed a motion to compel production of documents and requested sanctions against Tedder and his counsel, Kent, for misuse of the discovery process. The trial court found that Tedder and Kent had engaged in evasive and unjustified conduct during discovery, which hindered Baer's ability to prepare his case. As a result, the court imposed $10,475 in monetary sanctions against both Tedder and Kent, jointly and severally.Tedder and Kent appealed the sanctions order to the California Court of Appeal, Fourth Appellate District, Division Three. In a prior opinion, the appellate court affirmed the trial court’s sanctions order, finding that Tedder and Kent’s actions were not substantially justified and that their arguments on appeal were largely frivolous. Following the remittitur, Baer moved in the trial court to recover attorney’s fees incurred in defending the appeal, arguing that the relevant discovery statutes authorized such an award. The trial court agreed, awarding Baer $113,532.50 in appellate attorney’s fees, but imposed liability only on Tedder.On further appeal, the California Court of Appeal, Fourth Appellate District, Division Three, held that Code of Civil Procedure sections 2023.030(a) and 2031.320(b) authorize a trial court to award attorney’s fees incurred on appeal to a party who successfully defends an order imposing monetary sanctions for discovery misuse. The appellate court found the amount of fees reasonable with one reduction and concluded that both Tedder and Kent should be held jointly and severally liable for the full amount. The order was modified to reduce the fee award to $101,805 and to impose joint and several liability on both Tedder and Kent, and as modified, the order was affirmed and remanded for entry of the revised order. View "Baer v. Tedder" on Justia Law

A man was charged with illegal possession of ammunition after police stopped a car in which he was a passenger late at night, citing a non-functioning license plate light and tinted windows. During the stop, officers asked both occupants if they were on parole or probation, ordered them out of the vehicle, and conducted pat searches, citing low lighting and baggy clothing as reasons. A search of a backpack near the passenger seat revealed ammunition and documents with the passenger’s name. The passenger, who had prior felony convictions, was arrested. During the encounter, officers used slang and whistled at both the passenger and two Latino men passing by.The Santa Clara County Superior Court initially denied the passenger’s motion under the California Racial Justice Act (RJA), finding he had not made a prima facie showing that the officers’ actions were motivated by racial bias. After the California Court of Appeal issued an alternative writ requiring reconsideration and a detailed ruling on all claims, the trial court again denied the motion, concluding that the allegations were conclusory or unsupported.The California Court of Appeal, Sixth Appellate District, reviewed the case de novo and held that the passenger had made a prima facie showing under the RJA. The court found that, when considering the totality of the facts—including expert testimony, statistical evidence, and the officers’ language and conduct—there was a substantial likelihood that law enforcement exhibited bias based on race, ethnicity, or national origin. The court clarified that at the prima facie stage, the trial court should not weigh evidence or make credibility determinations, but should accept the truth of the movant’s factual allegations unless they are conclusory or contradicted by the record. The appellate court issued a writ directing the trial court to hold an evidentiary hearing on the RJA motion. View "Hernandez v. Superior Court" on Justia Law

Two young children, ages four and two, suffered severe injuries after falling from a second-floor bedroom window in their apartment, which had recently undergone renovations. The property owner and manager had replaced the window without installing a fall prevention device, despite the window’s low sill height and significant drop to the ground. The children, through their guardian ad litem, sued the owner and manager for negligence, alleging both general negligence and negligence per se based on an alleged violation of the California Building Standards Code, which requires fall prevention devices on certain windows.The Superior Court of California, County of Alameda, heard the case. Before trial, the defendants sought summary adjudication and moved in limine to exclude expert testimony regarding the Building Code, arguing that the property was exempt from current requirements due to compliance with the code at the time of original construction and the use of “like-for-like” materials during renovation. The trial court denied these pretrial motions but, after plaintiffs presented their case at trial, granted a nonsuit on both negligence theories, finding no duty under general negligence and that the code exemption applied to the negligence per se claim.The Court of Appeal of the State of California, First Appellate District, Division Four, reviewed the case. It affirmed the trial court’s ruling on general negligence, holding that the harm was not sufficiently foreseeable to impose a duty on the landlord under the circumstances. However, it reversed the nonsuit on negligence per se, holding that the trial court misinterpreted the Building Code: a window is not an “original material” exempt from current safety requirements. The appellate court remanded the case for retrial on the negligence per se claim. View "Jimenez v. Hayes Apartment Homes, LLC" on Justia Law

In 2008, a jury convicted the petitioner of multiple serious offenses, including two counts of attempted first degree murder, three counts of attempted murder of police officers, infliction of corporal injury on a cohabitant, and attempted arson. The trial court imposed a lengthy custodial sentence, including consecutive and concurrent life terms, as well as additional years for other offenses. The court also imposed an $8,000 restitution fine under Penal Code section 1202.4, ordered $1,700 in direct victim restitution, and assessed a court security fee.Following the conviction, the petitioner’s judgment was affirmed on direct appeal. Years later, the California Legislature amended the law to provide that restitution fines imposed under section 1202.4 become unenforceable and uncollectible after 10 years, and the portion of the judgment imposing such fines is vacated. The petitioner sought relief by filing a habeas corpus petition, arguing that the statutory vacatur of the restitution fine required a full resentencing and that habeas was the proper vehicle to effectuate this change.The California Court of Appeal, Fourth Appellate District, Division Two, held that the statutory vacatur of the restitution fine under section 1465.9(d) does not trigger the full resentencing rule. The court reasoned that the statute only vacates the portion of the judgment imposing the fine, not the entire sentence, and does not affect the custodial components. The court further held that a postjudgment motion in the trial court, rather than a habeas petition, is the appropriate method to correct the abstract of judgment to reflect the vacatur of the restitution fine. The petition for writ of habeas corpus was therefore denied. View "In re Mattison" on Justia Law

A company filed a lawsuit against another corporate entity, seeking damages for breach of a sublease. The plaintiff attempted to serve the defendant corporation by leaving the summons and complaint with an individual named Roberto Molina at the defendant’s business address, followed by mailing copies to the defendant’s chief executive officer. Molina was later identified as a bus washer employed by a related but separate company, not as an employee or officer of the defendant. The defendant did not initially respond to the lawsuit, resulting in the entry of default and a default judgment in favor of the plaintiff.Subsequently, the defendant moved in the Superior Court of Los Angeles County to quash service and vacate the default judgment, arguing that service of process was improper because Molina was not a person “apparently in charge” of the defendant’s office as required by California law. The plaintiff opposed, relying on the process server’s declaration and standard procedures. The trial court denied the defendant’s motion, finding that substituted service was valid and refusing to vacate the default judgment.On appeal, the California Court of Appeal, Second Appellate District, Division Eight, reviewed the matter de novo. The appellate court held that the substituted service was not valid because there was insufficient evidence that Molina was “apparently in charge” of the defendant’s business office, as required by Code of Civil Procedure section 415.20. The court found that the process server’s declaration lacked necessary facts to support such a conclusion, and the defendant’s evidence rebutted any presumption of proper service. The appellate court reversed the trial court’s order, vacated the entry of default and the default judgment, and remanded with directions to grant the defendant’s motion and allow time to respond to the complaint. View "Chinese Theater, LLC v. Starline Tours USA, Inc." on Justia Law