Justia California Court of Appeals Opinion Summaries

A young adult, H.T., was adjudicated a ward of the court after admitting to a crime and was committed to a secure youth treatment facility. Upon completion of his baseline term, the juvenile court prepared to discharge him to probation supervision in the community. However, finding suitable housing proved difficult due to probation conditions: H.T. could not live with his mother, was ineligible for community organization housing due to a registration requirement, and could not be placed in the probation department’s usual facility because of its proximity to a high school. H.T. requested that the court order the County of Sacramento to pay for his stay at a transitional housing facility.The Superior Court of Sacramento County initially granted H.T.’s request for 30 days of housing but later declined to order further payments, concluding it lacked statutory authority to require the County to pay for H.T.’s housing. The court instead directed the probation department to provide hotel vouchers and other support. H.T. appealed the orders denying his requests for continued payment of rent at the transitional housing facility.The California Court of Appeal, Third Appellate District, reviewed the case. It held that the juvenile court had discretion under Welfare and Institutions Code section 900, subdivision (b), to order the County to pay for the support and maintenance of a ward, including necessary housing expenses. The appellate court found that the lower court misinterpreted its authority and abused its discretion by failing to recognize the full scope of its statutory power. The Court of Appeal vacated the juvenile court’s order and remanded the matter for the juvenile court to exercise its discretion under the correct legal standard, specifically to determine whether payment for H.T.’s housing was necessary at the relevant time. View "In re H.T." on Justia Law

A 25-year-old defendant was charged with multiple counts of attempted murder and assault with a deadly weapon after allegedly attacking four individuals, all of whom were Black, with a metal pipe in Santa Monica. The attacks were accompanied by racial slurs and resulted in serious injuries to at least one victim. The defendant had a documented history of mental illness, substance abuse, and noncompliance with treatment, including leaving mental health facilities against medical advice and failing to take prescribed medication.The Superior Court of Los Angeles County considered the defendant’s motion for pretrial mental health diversion under Penal Code section 1001.36, supported by a psychological evaluation indicating that his schizoaffective disorder was treatable and that he would not pose an unreasonable risk to public safety if his symptoms were controlled with treatment. The prosecution opposed the motion, citing the defendant’s history of noncompliance and violence when untreated. After a hearing, the trial court granted diversion, ordering residential, medically assisted treatment and compliance with program rules, but made no express findings on whether the defendant would not pose an unreasonable risk to public safety if treated in the community.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the case on a petition for writ of mandate. The appellate court held that there was no substantial evidence to support the trial court’s implicit finding that the defendant would not pose an unreasonable risk of danger to public safety if granted diversion. The court emphasized the lack of evidence that the defendant would comply with treatment in a community setting and noted his history of abandoning treatment. The appellate court granted the petition, directing the trial court to vacate its order granting diversion and to deny the motion. View "People v. Superior Ct. (Taylor)" on Justia Law

The defendant was convicted in 2001 of attempted second degree murder, with additional firearm and gang enhancements, resulting in a sentence of 42 years to life. On direct appeal in 2003, the gang enhancement was stricken, reducing the sentence to 32 years to life. In 2021, the defendant sought resentencing under a statute that, at the time, did not apply to attempted murder. Subsequent motions for reconsideration and rehearing were filed, during which the trial court recognized a sentencing error: the defendant, who was not the actual shooter, should not have received the firearm enhancement after the gang enhancement was stricken. The court found the sentence appeared unauthorized but believed it lacked authority to correct it absent a habeas petition or a request from the district attorney or corrections department.The Los Angeles County Superior Court denied the defendant’s resentencing requests, finding he had not established a prima facie case for relief under the applicable statute. At a later hearing, the court acknowledged the sentencing error but concluded it could not act without a formal habeas petition or other postconviction relief mechanism, despite the prosecutor’s agreement that the sentence was excessive.The California Court of Appeal, Second Appellate District, Division Six, held that a trial court has inherent authority to correct an unauthorized sentence at any time, regardless of whether a habeas petition is filed or whether the request comes from the defendant, the prosecution, or the corrections department. The court reversed the order denying resentencing and remanded the case with instructions to hold a prompt resentencing hearing. If the trial court finds the sentence is unauthorized, it must correct it. The court clarified that statutory limitations on resentencing do not bar correction of an unauthorized sentence. View "P. v. Cervantes" on Justia Law

The dispute centers on groundwater management in the Tulare Lake groundwater subbasin, a high-priority basin under California’s Sustainable Groundwater Management Act (the Act). Local groundwater agencies developed and submitted a sustainability plan for the subbasin, but the Department of Water Resources twice found the plan inadequate. Following these determinations, the State Water Resources Control Board designated the Tulare subbasin as probationary, triggering state intervention and new monitoring, reporting, and fee requirements. In response, Kings County Farm Bureau and other parties filed a writ of mandate and complaint, challenging the State Board’s authority and actions, including the probationary designation and associated fees.The Superior Court of Kings County reviewed the Farm Bureau’s claims. It granted a preliminary injunction halting the State Board’s implementation of the probationary designation and denied in part the State Board’s demurrer to the complaint. Specifically, the trial court dismissed the equal protection claim with leave to amend but allowed the Farm Bureau to proceed on claims alleging improper underground regulations, unconstitutional fees, and general declaratory relief. The State Board then sought appellate review of the trial court’s order overruling its demurrer.The California Court of Appeal, Fifth Appellate District, reviewed the trial court’s decision de novo. It held that the Act exempts the State Board’s actions under the relevant statutory sections from the Administrative Procedures Act, precluding claims based on alleged underground regulations. The court further found that challenges to the extraction fees as unlawful taxes are barred by the “pay first” rule, requiring payment before judicial review. Finally, the court determined that declaratory relief is unavailable where the Legislature has provided a writ of mandate as the exclusive remedy. The appellate court issued a writ of mandate directing the trial court to vacate its order overruling the demurrer and to grant the demurrer without leave to amend as to the sixth, seventh, and ninth causes of action. View "State Water Resources Control Bd. v. Super. Ct." on Justia Law

This case concerns the State Water Resources Control Board’s designation of the Tulare Lake groundwater subbasin as a probationary basin under the Sustainable Groundwater Management Act (the Act). The Act requires local groundwater agencies to develop and implement sustainability plans for high-priority basins, subject to state review. In the Tulare subbasin, five local agencies collaborated on a single plan, which the Department of Water Resources twice found inadequate. Following these findings, the State Board designated the basin as probationary, triggering additional monitoring, reporting, and fee requirements for groundwater extractors. The Kings County Farm Bureau and other plaintiffs challenged the State Board’s actions, alleging the Board exceeded its authority, failed to properly consider requests for exclusion from probationary status, and did not provide adequate notice.The Superior Court of Kings County reviewed the Farm Bureau’s petition and complaint, which included multiple causes of action. The trial court granted a preliminary injunction barring the State Board from enforcing requirements stemming from the probationary designation and imposed only a nominal bond. The court found the Farm Bureau likely to succeed on several claims, including improper denial of the “good actor” exclusion, exceeding statutory authority, and failure to provide required notice. The State Board appealed the injunction and related orders.The California Court of Appeal, Fifth Appellate District, reviewed the preliminary injunction. The appellate court held that the trial court abused its discretion by issuing an overly broad injunction affecting the entire Tulare subbasin, when only certain claims regarding specific groundwater agencies were likely to succeed. The appellate court found the trial court erred in its analysis of some claims and that the injunction was not properly tailored to the harm at issue. The order granting the preliminary injunction was reversed and the case remanded for further proceedings. The petition for writ of supersedeas was denied as moot, and costs were awarded to the State Board. View "Kings County Farm Bureau v. State Water Resources Control Bd." on Justia Law

Two former employees of the University of California, after leaving their positions, delayed applying for retirement benefits under the University of California Retirement Plan (the Plan) until several years after reaching the normal retirement age of 60. When they eventually applied, both requested retroactive monthly retirement payments dating back to when they first became eligible. The Regents of the University of California denied these requests, interpreting the Plan to provide benefits only from the date of application forward. The plaintiffs, representing a class of similarly situated former employees, argued that the Plan entitled them to retroactive benefits or, alternatively, that The Regents breached a fiduciary duty by failing to inform them that retroactive benefits were unavailable.The Superior Court of Alameda County granted summary adjudication to The Regents on the breach of contract claim, finding that the Plan did not provide for retroactive monthly benefits prior to a member’s application. The court later held a bench trial on the breach of fiduciary duty claim, ultimately concluding that The Regents had not breached its duty to inform members about their retirement options, as the Plan documents and related communications were sufficient to fully and fairly inform a reasonable plan beneficiary.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. It held that the Plan’s language unambiguously requires a member to apply for retirement benefits before those benefits become payable, and that retroactive monthly benefits are not available for periods before an application is filed. The court also affirmed that The Regents met its fiduciary duty of disclosure by providing adequate information about the Plan and its options. The judgment in favor of The Regents was affirmed. View "Mass v. Regents of the University of California" on Justia Law

The case centers on a long-standing dispute involving three churches over ownership and sale of real property in Los Angeles. Attorney Steven C. Kim represented one of the churches, Central Korean Evangelical Church, which granted him a deed of trust on the property to secure payment of attorney fees. Central Korean had contracted to sell the property to New Life Oasis Church but later reneged, leading to litigation. The trial court ordered Central Korean to honor the sale and expunged Kim’s deed of trust, which was obstructing the transaction. Kim’s client appealed, but the appeal was dismissed for lack of standing, and Kim did not pursue his own appeal. The judgment became final in 2018.Following the final judgment, Kim filed a new lawsuit against New Life Oasis Church and Bank of Hope, seeking a declaration that his deed of trust was still valid and challenging the prior expungement order. New Life and Bank of Hope moved for judgment on the pleadings, arguing that issue preclusion barred Kim from relitigating the validity of his lien. The Superior Court of Los Angeles County agreed and entered judgment against Kim. Additionally, New Life filed a cross-complaint alleging that Kim’s recording of a lis pendens constituted slander of title and abuse of process. After a bench trial, the court ruled in favor of New Life, awarding damages and not addressing Kim’s defense based on the litigation privilege.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It affirmed the trial court’s application of issue preclusion, holding that Kim could not relitigate the validity of his deed of trust. However, it reversed the judgment on the cross-complaint, holding that the litigation privilege protected Kim’s recording of the lis pendens from claims of slander of title and abuse of process. The case was remanded for entry of judgment consistent with these holdings. View "Kim v. New Life Oasis Church" on Justia Law

A child, X.D., was born in May 2022 and immediately placed with prospective adoptive parents, Cliff and Rebecca, after his biological mother, Jessica, relinquished him for adoption. Jessica had suffered repeated physical and emotional abuse from X.D.’s biological father, Raymon, including an incident where Raymon struck her in the face two weeks after learning of her pregnancy. Following this, Jessica left Raymon, sought refuge in a domestic violence shelter, and cut off communication. Raymon was unaware of X.D.’s birth and believed Jessica had miscarried after she told him the baby “is not here no more.” Throughout Jessica’s pregnancy, Raymon made sporadic attempts to contact her but did not provide support for the pregnancy or the child.The Superior Court of Los Angeles County reviewed the adoption petition and Raymon’s opposition, in which he claimed status as a “Kelsey S. father”—an unwed biological father who is constitutionally entitled to block adoption if he promptly demonstrates a full commitment to parental responsibilities. The trial court found Raymon qualified as a Kelsey S. father, reasoning that Jessica’s actions prevented him from asserting his rights and that he had shown sufficient emotional and financial commitment. The court excluded key evidence—screenshots of Raymon’s threatening text messages—on authentication and hearsay grounds.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It held that the trial court erred in excluding the text message evidence, which was sufficiently authenticated and relevant. Upon considering the full record, including the excluded evidence, the appellate court found insufficient support for Raymon’s claim to Kelsey S. status. The court further determined that it was not in X.D.’s best interest for Raymon to retain parental rights. The judgment was reversed and remanded with directions to allow the adoption to proceed. View "Adoption of X.D." on Justia Law

A man was charged with and convicted of raping a woman who was intoxicated. The incident occurred after the two met at a bar, where the woman had consumed significant amounts of alcohol and experienced a blackout, leaving her with little memory of the events. The defendant, who was known for dressing as a pirate and living in his van, accompanied the woman home, where sexual intercourse occurred. The woman later reported the incident to the police after learning from the defendant that they had sex, which she did not remember. Medical examination revealed injuries consistent with intercourse, but expert testimony indicated such injuries could result from either consensual or nonconsensual sex.The Santa Cruz County Superior Court conducted a jury trial, during which the jury found the defendant guilty of rape of an intoxicated person and found true certain aggravating factors. The defendant was sentenced to six years in prison. On appeal, the defendant argued that the trial court erred by not instructing the jury on the lesser included offense of battery, and by admitting prejudicial evidence regarding his homelessness. He also raised claims of prosecutorial misconduct and ineffective assistance of counsel.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that battery is a lesser included offense of rape of an intoxicated person and that the trial court erred by failing to instruct the jury on this lesser offense. The appellate court found there was substantial evidence from which a jury could have concluded the defendant did not know, and reasonably should not have known, that the victim was too intoxicated to consent. The court determined this instructional error was prejudicial and reversed the conviction, remanding the case for a possible new trial with proper jury instructions. View "P. v. Mirabal" on Justia Law

The case concerns a petition for resentencing filed by Safoloooi Sam Taito, who was convicted in 1994 of first degree murder with a felony-murder special circumstance, as well as second degree robbery, for the killing of Librado Godoy Lopez. The evidence at trial showed that Taito and a codefendant repeatedly punched and kicked Lopez, stabbed him in the head with a screwdriver, and took his personal property. Lopez died from both blunt force trauma and the stab wound. Witnesses testified to Taito’s direct involvement in the attack and theft.Following the charges, the Superior Court of Los Angeles County instructed the jury on theories of premeditated murder and felony murder, including aiding and abetting. The jury convicted Taito of first degree murder and found true the felony-murder special circumstance and a weapon enhancement. He was sentenced to life without parole. The California Court of Appeal previously affirmed his conviction in 1997.In 2021, Taito petitioned for resentencing under Penal Code section 1172.6, arguing that changes to California’s felony-murder law made him eligible for relief. The Superior Court denied the petition at the prima facie stage, finding the record conclusively established that the jury’s findings met the requirements of current law.The California Court of Appeal, Second Appellate District, Division Three, reviewed the denial de novo. The court held that Taito was ineligible for resentencing as a matter of law because the jury’s true finding on the felony-murder special circumstance demonstrated he was convicted under a theory consistent with current Penal Code section 189, subdivision (e)(2). The court affirmed the Superior Court’s order denying Taito’s petition for resentencing. View "P. v. Taito" on Justia Law