Justia California Court of Appeals Opinion Summaries

American Surety Company posted a $100,000 bail bond for Marlon Anibal Valle-Mejia. Valle-Mejia failed to appear at a court hearing on July 19, 2022, despite knowing the date. His attorney did not provide a reason for his absence. The court continued the case to August 8 without forfeiting the bail bond. Valle-Mejia again failed to appear on August 8, and the court continued the case to August 29, ordering him to appear personally. When Valle-Mejia did not appear on August 29, the court forfeited the bail bond and issued a bench warrant.American Surety Company filed motions in the criminal court to vacate the forfeiture and exonerate the bail, arguing that the court lost jurisdiction by not forfeiting the bail after the initial failure to appear. The criminal court denied both motions, and American did not appeal these decisions. Subsequently, a summary judgment against the bond was entered in a civil case, and American filed a motion to set aside the summary judgment, which was denied by the civil court based on issue preclusion.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court held that the trial court was required to forfeit the bail when Valle-Mejia first failed to appear without sufficient excuse on July 19, 2022. By not doing so, the court lost jurisdiction to forfeit the bail later. Consequently, the subsequent forfeiture and summary judgment were void. The appellate court determined that issue preclusion did not apply because the initial forfeiture was beyond the court's fundamental jurisdiction. The judgment was reversed, and American Surety Company was entitled to recover its costs on appeal. View "P. v. American Surety Co." on Justia Law

In 1991, an individual was convicted of the rape and murder of a woman in San Diego County. The crime involved the perpetrator bludgeoning the victim with a metal steering wheel lock, restraining and sexually assaulting her for several hours, and ultimately suffocating her before burying her body in the desert. The perpetrator confessed to the crimes and entered a plea agreement, resulting in a sentence of six years for rape and 25 years to life for first-degree premeditated murder. Over the years, state forensic psychologists consistently diagnosed the individual with sexual sadism disorder and a personality disorder with narcissistic features.After serving decades in prison, the Board of Parole Hearings found the individual suitable for parole in 2019 and again in 2022. On both occasions, the Governor of California exercised his authority to independently review and reverse the Board’s decision, citing concerns about the individual’s insight into the crimes and risk to public safety. The San Diego County Superior Court denied the individual’s petition for writ of habeas corpus challenging the Governor’s 2022 reversal.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the habeas petition. Applying the highly deferential “some evidence” standard, the court examined whether there was a rational nexus between the evidence and the Governor’s determination of current dangerousness. The court found substantial evidence supporting the Governor’s conclusion that the individual lacked sufficient insight into the connection between his sexual disorder and violent conduct, continued to minimize his culpability, and demonstrated lapses in judgment and self-control in recent prison incidents. The court held that these factors, combined with the aggravated nature of the original crimes, provided a sufficient basis for the Governor’s decision. The petition for writ of habeas corpus was denied. View "In re Rogowski" on Justia Law

A student, E.I., attended El Segundo Middle School during the 2017-2018 school year and experienced bullying from classmates, particularly Skylar. Despite E.I. and her parents repeatedly reporting the bullying to school officials, including the principal and counselor, the school failed to take effective action. The bullying included verbal harassment, social media abuse, and physical aggression, which led E.I. to self-harm and develop PTSD and depression. The school’s anti-bullying policies were not adequately followed by the staff.The case was initially reviewed by the Superior Court of Los Angeles County, where a jury found the El Segundo Unified School District negligent and awarded E.I. $1 million in damages. The District moved for a new trial and for judgment notwithstanding the verdict, both of which were denied by the court.The California Court of Appeal, Second Appellate District, reviewed the case. The District argued several points on appeal, including errors in allowing reliance on certain Education Code provisions, claims of immunity under Government Code section 820.2, insufficient evidence of causation, improper consideration of a negligent training and supervision theory, admission of expert testimony, and attorney misconduct during closing arguments. The appellate court found that many of the District’s arguments were either waived or lacked merit. The court held that the District was not immune from liability under Government Code section 820.2, as the actions in question were operational rather than policy decisions. The court also found substantial evidence supporting the jury’s causation finding and determined that any potential errors were not prejudicial. Consequently, the appellate court affirmed the judgment in favor of E.I. View "E.I. v. El Segundo Unified School Dist." on Justia Law

Three former or current employees of Cross Country Staffing, Inc. (plaintiffs) filed a lawsuit against their employer, alleging various labor law violations. Upon hiring, each plaintiff signed two agreements: an Arbitration Agreement mandating arbitration for all employment-related claims and an Employment Agreement that included provisions favoring the employer, such as non-compete clauses and the right to seek injunctive relief in court without posting a bond.The Superior Court of Los Angeles County denied Cross Country Staffing's motion to compel arbitration, finding that the Arbitration Agreement, when read together with the Employment Agreement, was unconscionable. The court determined that the agreements were procedurally unconscionable due to their adhesive nature and substantively unconscionable because they unfairly favored the employer by allowing it to litigate its likely claims in court while forcing employees to arbitrate their likely claims. The court also noted the non-mutual attorney fees provisions and the employee's mandated concessions regarding injunctive relief.The California Court of Appeal, Second Appellate District, Division Five, affirmed the trial court's decision. The appellate court agreed that the two agreements should be read together under Civil Code section 1642, as they were part of the same transaction and related to the same subject matter. The court found significant substantive unconscionability in the agreements' imbalance of arbitration obligations and the employer's access to court for its claims. The court also upheld the trial court's refusal to sever the unconscionable provisions, concluding that the agreements' unconscionability permeated the entire arbitration framework and that refusing to enforce the Arbitration Agreement served the interests of justice. View "Silva v. Cross Country Healthcare, Inc." on Justia Law

A charter city in California entered into an agreement with a private developer to revitalize a nearly vacant mall into a multipurpose development. The city contributed approximately $51.36 million in local funds for public improvements, while the developer invested $143 million of its own funds and obtained additional loans. The developer selected the contractors and paid workers less than the prevailing wage, relying on a city ordinance exempting the project from the Prevailing Wage Law (PWL).The Department of Industrial Relations (DIR) determined that the project was subject to the PWL, as it involved public funds. The developer challenged this determination, but the Superior Court of Riverside County affirmed the DIR's decision, concluding that the project was not a municipal affair exempt from the PWL.The Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the lower court's judgment. The court held that the project was not a municipal affair under the home rule provision of the California Constitution. The court distinguished this case from others where charter cities directly managed and funded public works projects. Here, the developer controlled the construction, selected contractors, and bore the majority of the financial burden. The court concluded that the primary purpose of the project was to benefit the developer, not the city, and thus, the PWL applied. The judgment was affirmed, and the DIR was awarded costs on appeal. View "Palm Springs Promenade, LLC v. Dept. of Industrial Relations" on Justia Law

Brandon Duane Wagstaff was convicted by a jury of felony false imprisonment and related offenses stemming from a domestic violence incident. The trial court sentenced him to 16 months in prison. Wagstaff, who is Black, claimed that the trial court violated the California Racial Justice Act of 2020 (RJA) during various stages of the proceedings. However, his trial counsel did not object to these statements under the RJA, leading to the forfeiture of these claims on appeal. Wagstaff also argued that his trial counsel was ineffective for not objecting to a specific statement made by the trial court at sentencing, but the appellate court found this claim to be without merit.In the lower court, the prosecution charged Wagstaff with five counts, including felony false imprisonment, attempted second-degree robbery, contempt of court, threatening to commit a crime, and battery upon a person in a dating relationship. The jury found him guilty on four counts but acquitted him of attempted robbery. Wagstaff admitted to a prior conviction, and the trial court imposed an aggregate sentence of nine years and four months, including a term from a separate case.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that Wagstaff's claims under the RJA were forfeited due to the lack of objections by his trial counsel. The court also concluded that the trial court's failure to instruct the jury on misdemeanor false imprisonment as a lesser included offense was not erroneous because there was no substantial evidence to support such an instruction. The appellate court affirmed the judgment, finding no merit in Wagstaff's claims. View "P. v. Wagstaff" on Justia Law

In 1996, Daniel Whalen was convicted of first-degree murder during a robbery and received a death sentence. His conviction and sentence were affirmed by the California Supreme Court in 2013, and his first state habeas corpus petition was denied in 2014. Whalen filed a second habeas corpus petition in 2016, raising claims of prosecutorial misconduct, ineffective assistance of counsel, and constitutional challenges to the death penalty. This petition was transferred to the Stanislaus Superior Court, which denied it in 2022, finding the claims were successive and could have been raised earlier.Whalen appealed the denial and requested a certificate of appealability from the California Court of Appeal, Fifth Appellate District. The appellate court initially denied the request, but the California Supreme Court directed it to reconsider whether the superior court had properly ruled the petition as successive under Proposition 66 and its implementing statutes. Upon remand, the superior court reaffirmed its decision that the claims were successive and granted a certificate of appealability without specifying the claims.The California Court of Appeal, Fifth Appellate District, reviewed the case and found the certificate of appealability fatally defective because it did not indicate which claims were substantial, as required by law. The court dismissed the appeal and remanded the case to the superior court to either deny the certificate of appealability or issue a new one that complies with the statutory requirements. The appellate court also upheld the constitutionality of section 1509, subdivision (d), which limits successive habeas corpus petitions to claims of actual innocence or ineligibility for the death sentence. View "In re Whalen" on Justia Law

In 1996, Jesse Banda Ortega, then 17 years old, was involved in a gang-related shooting in Santa Ana, California, resulting in one death and one injury. Ortega was convicted of one count of murder and three counts of attempted murder, with firearm enhancements. He was sentenced to 25 years to life, plus 17 years, making him eligible for parole after 42 years.Ortega filed a petition for recall and resentencing under California Penal Code section 1170(d)(1) in 2023, arguing that his sentence was the functional equivalent of life without parole (LWOP) and that he should be eligible for relief under equal protection principles. The Superior Court of Orange County denied his petition, stating that Ortega's sentence included a meaningful opportunity for release during his 25th year of incarceration, thus it was neither LWOP nor its functional equivalent.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that Ortega's sentence, modified by legislative changes requiring youth offender parole hearings, provided a meaningful opportunity for release after 25 years. Therefore, Ortega was not serving a sentence equivalent to LWOP. The court affirmed the trial court's denial of Ortega's petition, concluding that his constitutional claim was moot due to the legislative changes ensuring parole eligibility. The court also found that Ortega's equal protection argument was moot, as his current sentence did not violate constitutional principles. View "P. v. Ortega" on Justia Law

Alonzo McClanahan, a former employee of DPR Construction, claimed workers' compensation benefits for an injury to his right shoulder that he alleged occurred on July 25, 2017, while moving heavy materials at work. DPR's claims administrator denied the claim, and McClanahan sought adjudication from the Workers' Compensation Appeals Board (WCAB). During the trial, McClanahan testified about the injury, but DPR presented evidence and testimony from employees that contradicted his account. Medical evaluations were conducted by several doctors, including Dr. McGahan, who supported McClanahan's claim of an industrial injury.The Workers' Compensation Judge (WCJ) ruled in favor of McClanahan, finding his testimony credible and supported by medical evidence. DPR filed a petition for reconsideration, which the WCJ recommended denying. The WCAB granted the petition for further review but ultimately affirmed the WCJ's decision in a two-to-one decision, despite acknowledging that the Hanley reports, which were not listed in the pretrial conference statement, were admitted in error. The dissenting board member believed the error warranted a return to the trial level for correction.The California Court of Appeal, Third Appellate District, reviewed the case. The court found that the WCAB did not err in its credibility determination under section 5313, as the WCJ provided sufficient reasons for finding McClanahan credible. However, the court agreed with DPR that the admission of the Hanley reports, which were not listed in the pretrial conference statement, violated section 5502. The court held that this error was not subject to harmless error analysis and annulled the WCAB's decision, remanding the case for reconsideration without reference to the Hanley reports. View "DPR Construction v. Workers' Compensation Appeals Board" on Justia Law

Citizens for a Better Eureka (CBE) filed a petition challenging the City of Eureka's decision to redevelop a city-owned parking lot into affordable housing, claiming the project was improperly exempted from the California Environmental Quality Act (CEQA). The City Council had adopted a resolution authorizing the reduction or removal of public parking to facilitate the development, citing a Class 12 CEQA exemption for surplus government property sales. CBE argued that the project was unlawfully piecemealed and that the entire redevelopment should be considered under CEQA.The Humboldt County Superior Court dismissed the petition, agreeing with the Wiyot Tribe's motion that the Tribe, selected as the developer for the project, was a necessary and indispensable party to the proceedings. The court found that the Tribe could not be joined due to its sovereign immunity, and thus, the case could not proceed without it.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court affirmed the lower court's decision, holding that the Tribe was indeed a necessary and indispensable party. The court reasoned that the Tribe had significant interests in the project, having invested time and resources into its development. The court also found that any judgment in favor of CBE would prejudice the Tribe by hindering its ability to proceed with the project. Additionally, the court noted that CBE failed to join the Tribe within the statutory period, further justifying the dismissal. The court concluded that the trial court did not abuse its discretion in dismissing the petition. View "Citizens for a Better Eureka v. City of Eureka" on Justia Law