Justia California Court of Appeals Opinion Summaries

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

A group of plaintiffs leased a 2,400-acre parcel of undeveloped land in San Luis Obispo County, California, from the predecessor of the defendant, Eureka Energy Company. The lease, originally executed in 1968 and later novated, provided for a 99-year term with an option to renew for another 99 years. The property, known as Wild Cherry Canyon, was historically used for cattle grazing, but the lease itself stated that the premises could be used for “any lawful purpose.” The parties understood that cattle grazing would continue, primarily to reduce wildfire risk rather than for commercial livestock production. In 2018, the plaintiffs exercised their option to renew the lease, but Eureka asserted that the lease was limited to 51 years under California Civil Code section 717, which restricts leases for agricultural purposes.The Superior Court of San Luis Obispo County held a court trial and issued a detailed statement of decision. It found that the lease was for agricultural purposes, specifically cattle grazing, and concluded that section 717 applied, limiting the lease to 51 years. The court entered judgment for Eureka, declaring that the lease expired in 2019 and that the plaintiffs had no further interest in the property. The plaintiffs appealed, arguing that the lease was not for agricultural purposes within the meaning of section 717, given the fire prevention intent.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. It held that, although cattle grazing generally constitutes an agricultural purpose under section 717, the particular circumstances here—where grazing was intended for fire prevention and not for commercial agriculture—meant the lease was not for agricultural purposes as defined by the statute. The court reversed the trial court’s judgment, finding that the lease was valid beyond the 51-year limit and that the plaintiffs’ leasehold interest should not be forfeited. View "Pacho Limited Partnership v. Eureka Energy Co." on Justia Law

Ashley McCall Hart and Steven Hart, who were married and have two children, became involved in a series of legal disputes following Ashley’s filing for dissolution of marriage in October 2017. On the same day, Ashley requested a domestic violence restraining order (DVRO) against Steven, which the Superior Court of Los Angeles County granted temporarily. Steven responded by filing his own DVRO request against Ashley, but after hearings, the court denied Steven’s request and granted Ashley a one-year DVRO. Ashley later dismissed a renewal request in accordance with a settlement agreement. In July 2023, Ashley again sought a DVRO, and the court issued a nine-month order. Before its expiration, Ashley requested renewal, which was granted for another nine months.Ashley appealed the renewal duration, arguing that Family Code section 6345 requires a minimum five-year renewal period for DVROs. The Superior Court had found Ashley demonstrated a reasonable apprehension of future abuse but believed it had discretion to renew the DVRO for less than five years.The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. It held that under Family Code section 6345, subdivision (a), a court may renew a DVRO only for five or more years, or permanently, at its discretion, but not for a period less than five years. The court found that the statutory language and legislative history clearly establish a mandatory minimum renewal period of five years, and the trial court’s discretion is limited to choosing between five years, a longer period, or permanent renewal. The appellate court reversed the lower court’s order to the extent it provided for a nine-month renewal and remanded with instructions to modify the order to provide for a five-year renewal. View "Hart v. Hart" on Justia Law

A plaintiff brought suit against a defendant for defamation, intentional infliction of emotional distress, and related claims after the defendant published false and damaging material about her online. The defendant initially participated in the litigation with counsel, but later became self-represented and provided a P.O. box as his address. After failing to appear or defend the action, his answer was stricken, and the plaintiff mailed a statement of damages to the address he provided. The court entered a default judgment against the defendant for over $1 million, which was later renewed nearly a decade after its entry.Prior to the current appeal, the Superior Court of Los Angeles County denied the defendant’s anti-SLAPP motion and struck his cross-complaint after direction from the California Court of Appeal, which also awarded attorney fees to the plaintiff. After the defendant’s answer was stricken for nonappearance, the plaintiff served a statement of damages and obtained a default judgment. Years later, the plaintiff renewed the judgment, and the defendant moved to vacate the renewal, arguing the default judgment was void due to improper notice of damages and defective service.The California Court of Appeal, Second Appellate District, Division Two, reviewed the denial of the defendant’s motion to vacate the renewal of judgment. The court held that the plaintiff’s claims for defamation and related torts qualified as personal injury actions, making a statement of damages appropriate. The court further held that use of a custom statement of damages form, rather than the Judicial Council form, did not render the judgment void, and that service by mail to the defendant’s provided address was proper under the applicable statutes. The court affirmed the order denying the motion to vacate the renewal of judgment. View "Backlund v. Stone" on Justia Law

Jose Haro Nevarez was involved in a fatal collision on Interstate-15 after driving while intoxicated at excessive speeds. His SUV became disabled and blocked a high-occupancy vehicle lane with its lights off. Minutes later, a motorcyclist, Robert Cole Sutton, struck the rear of Nevarez’s SUV and was killed. Nevarez admitted to officers at the scene that he was drunk and on DUI probation, and subsequent tests confirmed his blood alcohol level was well above the legal limit. Nevarez had previously been convicted of DUI and received a Watson advisement, warning him of the potential for a murder charge if he killed someone while driving under the influence.Following the incident, the People charged Nevarez with second-degree murder and other related offenses in the Superior Court of San Diego County. At the preliminary hearing, the magistrate found probable cause for all charges, distinguishing the facts from People v. Superior Court (Chagolla) (2024) 102 Cal.App.5th 499. Nevarez’s defense moved to set aside the murder charge under Penal Code section 995, arguing that Chagolla precluded liability because he was not driving at the moment of the fatal collision. The trial court denied the motion, finding Chagolla factually distinguishable.Nevarez then petitioned the California Court of Appeal, Fourth Appellate District, Division One, for a writ of prohibition to overturn the trial court’s order. The appellate court denied the petition, holding that probable cause supported the murder charge. The court clarified that liability for second-degree murder under People v. Watson (1981) 30 Cal.3d 290 does not automatically end when an intoxicated driver ceases driving. Instead, a fact-specific analysis of implied malice and proximate cause is required. The court rejected a rigid rule and affirmed that the circumstances supported probable cause for both implied malice and proximate cause in Nevarez’s case. View "Nevarez v. Superior Court" on Justia Law