Justia California Court of Appeals Opinion Summaries

The case centers on an employee who brought multiple claims against her former employer, including several for violations of California’s Labor Code and a representative claim under the Private Attorneys General Act (PAGA). The employee had signed an arbitration agreement at the start of her employment. As a result, all non-PAGA claims were compelled to arbitration, while the PAGA claims (both individual and representative) were stayed. The arbitrator found in favor of the employer on all Labor Code violations, concluding that the alleged violations did not occur.Following the arbitration, the Superior Court of San Bernardino County confirmed the arbitrator’s award and granted judgment on the pleadings against the employee on her PAGA claim, ruling that the arbitration results established she was not an “aggrieved employee” under PAGA, and therefore lacked standing to pursue the PAGA claim. When the employee appealed, the California Court of Appeal, Fourth Appellate District, Division Two, affirmed the denial of her motion to vacate the arbitration award but reversed the judgment on the pleadings as to the PAGA claim, holding that the arbitration did not preclude her from pursuing PAGA penalties.Subsequently, the employer filed a renewed motion for judgment on the pleadings, arguing that subsequent appellate court decisions and the California Supreme Court’s decision in Adolph v. Uber Technologies, Inc., constituted an intervening change in the law, rendering the law of the case doctrine inapplicable. The trial court denied this motion, finding that its prior ruling remained law of the case. Reviewing this denial, the California Court of Appeal, Fourth Appellate District, Division Two, held that the law of the case doctrine properly applied because there had been no controlling intervening change in the law. The court denied the employer’s writ petition, confirming that the arbitrator’s findings on non-PAGA claims did not preclude judicial determination of the employee’s standing under PAGA. View "Prime Healthcare Management v. Super. Ct." on Justia Law

A married couple underwent in vitro fertilization and created two frozen embryos, signing a written agreement with the IVF provider that specified options for disposing of the embryos in the event of legal separation or divorce. The agreement offered several choices, including discarding the embryos, donating them, or making them available to one partner if desired. The couple selected and initialed the option stating the embryos would be “made available to the partner if he/she wishes.” After the couple separated, the husband sought to have the embryos discarded, while the wife wanted to use them to attempt pregnancy.In the Superior Court of Orange County, the husband filed a motion to discard the embryos, and the wife requested immediate rights to them. Following an evidentiary hearing at which both parties acknowledged the agreement and their signatures, the court found the contract valid, clear, and unambiguous, and awarded the embryos to the wife. The court issued a minute order and later a formal order reflecting this decision.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, determined the order was not directly appealable but exercised its discretion to treat the appeal as a petition for writ of mandate. Reviewing the IVF agreement independently, the appellate court held that when parties have entered a valid contract specifying the disposition of embryos in the event of divorce, that agreement governs. The court found the contract’s language unambiguous and concluded the embryos should be made available to the wife, as specified. The court further found no violation of public policy or constitutional rights and denied the husband’s petition, affirming that the wife was entitled to the embryos under the contract. View "Pham v. Super. Ct." on Justia Law

A firefighter employed by a county for over two decades reported safety violations concerning the maintenance of fire extinguishers on county fire engines. After raising these concerns with his superiors, he was barred from working in fire prevention, which he believed was retaliation for his whistleblowing activities. Although he filed internal complaints with the county’s Office of Human Resources and the Civil Service Commission, he withdrew his appeal after assurances that his concerns would be addressed. Later, he was investigated for alleged misconduct and ultimately terminated for violations of county rules. He then filed a claim under the Government Claims Act, which the county rejected.The Superior Court of Kern County granted the county’s motion for judgment on the pleadings, finding that the plaintiff’s failure to exhaust the internal administrative remedies—specifically, by not appealing his dismissal to the Civil Service Commission—barred his whistleblower retaliation lawsuit. The court denied the plaintiff’s request for leave to amend his complaint, holding that he could not allege exhaustion of remedies.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case. It held that the plaintiff was not required to exhaust the county’s internal administrative remedies before bringing his whistleblower retaliation claims because the county’s ordinances and rules did not provide a clearly defined process for submitting, evaluating, and resolving such claims. The court distinguished between general disciplinary appeals and procedures for discrimination or harassment claims, noting that there was no specific administrative remedy for whistleblower retaliation. Consequently, the appellate court reversed the judgment and remanded the matter with instructions to deny the county’s motion for judgment on the pleadings. The holding clarifies that, where an internal administrative process does not address a particular type of claim, exhaustion of that process is not required before filing suit. View "Romero v. County of Kern" on Justia Law

A man used a social media application to communicate with what he believed to be a minor. In reality, he was interacting with a law enforcement officer posing as a 14-year-old girl. Their exchange included plans to meet for sexual contact, and when he arrived at the agreed location, law enforcement apprehended him. Physical evidence found in his vehicle supported the allegation that he intended to engage in sexual activity. At trial, the defendant asserted that he did not know he was interacting with a minor and claimed he had deleted the relevant message thread, losing access to the initial messages where age was mentioned.The Superior Court of California, County of Contra Costa, conducted the trial, where a jury found him guilty of meeting a minor for lewd purposes, contacting a minor for a sexual offense, and attempted lewd act upon a child. The trial judge sentenced him to probation. The defense argued that the jury instructions regarding mistake of fact were erroneous, specifically that they required any mistaken belief about the minor’s age to be reasonable. The prosecution conceded the instructional error but asserted it was harmless.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. It held that the trial court erred by instructing the jury that a mistake of fact as to the minor’s age must be reasonable, when the charged offenses require only an actual belief due to their specific intent elements. The appellate court found the error was prejudicial, emphasizing that the jury might have credited the defendant’s testimony but was prevented from considering an unreasonable yet genuinely held belief. Consequently, the Court of Appeal reversed the trial court’s judgment. View "P. v. Ismaiel" on Justia Law

Following a divorce, a father was granted supervised visitation with his two minor children. The supervision was to be conducted by a licensed therapist selected by the mother, as the parents could not agree on a supervisor. The therapist, after supervising some visits, suspended the father’s visitation, stating that the sessions could not proceed successfully unless the father admitted to charges of kidnapping and neglect and recognized their impact on his children.The father subsequently filed suit against the therapist, bringing three claims, including one for reckless infliction of emotional distress stemming from the suspension of visitation. In the Superior Court of Santa Cruz County, the therapist moved for summary judgment. The father conceded two of his claims, leaving only the emotional distress claim regarding the suspension of visitation. The trial court granted summary judgment in favor of the therapist, finding that the claim was barred by the litigation privilege and quasi-judicial immunity, and further concluding that the alleged conduct did not support a valid claim for intentional infliction of emotional distress.On appeal, the California Court of Appeal, Sixth Appellate District, reviewed only the emotional distress claim related to the suspension of visitation. Applying a de novo standard of review, the appellate court held that quasi-judicial immunity bars the claim. The court determined that the therapist was performing a judicial function delegated by the court—specifically, the authority to suspend visitation under the California Standards of Judicial Administration. The opinion found this function to be indistinguishable from those protected by quasi-judicial immunity in prior precedents. As a result, the appellate court affirmed the trial court’s grant of summary judgment in favor of the therapist. View "Vergara v. Ouse" on Justia Law

Two neighbors own adjacent properties in a subdivision, with one property benefiting from a road easement across the other’s land. The easement includes both a paved portion and a 244.5-foot gravel or dirt driveway segment. The defendant uses this gravel road for access. In an earlier lawsuit, the plaintiff alleged that the defendant had entered the property to clear trees, perform excavation, and build a rock wall without permission. That suit was resolved by partial settlement and judgment. While the first case was still pending, the plaintiff filed a second suit seeking to stop the defendant from paving the gravel portion of the easement, arguing that paving was not necessary for reasonable use.The Superior Court of El Dorado County first denied the defendant’s motion for judgment on the pleadings, rejecting arguments that the second complaint improperly split causes of action and was legally insufficient. The court found the new suit did not overlap with the first, as the threat to pave the easement arose after the initial complaint and involved distinct allegations. After a bench trial, the court determined that paving the driveway was not reasonably necessary for safe and convenient vehicular access, and issued an injunction prohibiting the defendant from paving.The California Court of Appeal, Third Appellate District, reviewed the case. It affirmed the trial court’s rulings, holding that the second suit was not barred as an improper splitting of actions because it addressed a different episode and new factual circumstances. The court further held that the scope of an easement does not automatically include the right to pave; such improvements must be reasonably necessary for the convenient use of the easement, as determined by the facts. The appellate court found no error with the trial court’s application of the legal standard or its factual findings, and affirmed the judgment in favor of the plaintiff. View "Berstein v. Sebring" on Justia Law

Manuel Contreras worked for Green Thumb Produce, Inc., primarily in the sanitation department, and became aware that he was earning less than other employees performing similar duties, some with less seniority. He repeatedly raised the pay disparity with management, but no action was taken. After consulting with the Labor Commissioner’s Office and reviewing a FAQ about the California Equal Pay Act (EPA), Contreras believed his employer was violating equal pay laws and presented these concerns, along with the FAQ, to human resources. Shortly thereafter, he was terminated, with Green Thumb citing violations of company policy.Contreras filed suit in the Superior Court of Riverside County, asserting three causes of action, including a claim under Labor Code section 1102.5(b) for whistleblower retaliation. At trial, the jury found in Contreras’s favor on all claims and awarded damages. Green Thumb moved for partial judgment notwithstanding the verdict (JNOV) on the whistleblower claim, arguing Contreras’s misunderstanding of the EPA—specifically, that he did not believe his pay disparity was based on sex, race, or ethnicity—was an unreasonable basis for a claim under section 1102.5(b). The Superior Court granted the JNOV motion, reasoning that Contreras’s belief did not relate to a violation of law.On appeal to the California Court of Appeal, Fourth Appellate District, Division One, the court addressed whether Contreras’s mistaken interpretation of the EPA defeated his whistleblower retaliation claim. The appellate court held that section 1102.5(b) requires only that an employee have an objectively reasonable belief that a violation of law occurred, not that the belief be legally correct. The court found that substantial evidence supported the jury’s conclusion that Contreras reasonably believed Green Thumb violated the EPA based on his consultation with the Labor Commissioner and the potentially misleading FAQ. The appellate court reversed the trial court’s JNOV ruling and instructed it to amend the judgment consistent with the jury’s verdict. View "Contreras v. Green Thumb Produce Inc." on Justia Law

After entering a no contest plea to charges including willful infliction of corporal injury and dissuading a witness, the petitioner was sentenced to four years’ probation and 60 days in county jail. She was referred to a work release program in lieu of serving her jail time. While participating, she discovered she was pregnant and could not complete her work assignment due to morning sickness. After providing proof of her pregnancy, the sheriff advised her not to return to the worksite because no light duty was available, and her case was sent back to the trial court for further action.The Contra Costa County Superior Court later considered her situation. At a hearing, the court found that she had not willfully violated the terms of the work release program but concluded that the alternative sentence was no longer feasible. The court ordered her to serve the remainder of her jail term in custody, denying her requests for re-referral to the program or a delayed surrender. The petitioner subsequently filed a habeas corpus petition with the California Court of Appeal, First Appellate District, Division Three, asserting that her due process rights had been violated.The California Court of Appeal, First Appellate District, Division Three, held that individuals enrolled in work release programs in lieu of jail time possess a conditional liberty interest that cannot be revoked without due process. The court found that the trial court’s decision to remand the petitioner into custody was based on a factual finding—her unfitness for the program—that was unsupported by the evidence. As a result, the appellate court reversed the trial court’s order and remanded the matter with instructions to re-refer the petitioner to the work release program to complete any remaining days owed. View "In re Riley" on Justia Law

A man was apprehended after leading police on a high-speed chase in a stolen vehicle. When the vehicle was stopped, law enforcement found an AR-style firearm with an overall length of less than 30 inches on the passenger-side floorboard. The man was charged with several offenses, including driving or taking a vehicle without consent, fleeing a police officer while driving recklessly, possession of a firearm by a felon, and possession of an assault weapon. The information also alleged several aggravating factors related to his criminal history and conduct.In Contra Costa County Superior Court, a jury found the defendant guilty of all charges except receiving a stolen vehicle. The court, after a hearing, found true several aggravating factors and sentenced him to three years and four months, including concurrent terms for some offenses. The sentence for possession of an assault weapon was stayed under Penal Code section 654.The California Court of Appeal, First Appellate District, Division Five, reviewed three issues raised by the defendant: whether California’s ban on assault weapon possession violated the Second Amendment; whether sentences for taking a vehicle without consent and fleeing an officer should have been stayed as based on the same act; and whether the abstract of judgment accurately reflected custody credits. The court held that Penal Code section 30605 does not violate the Second Amendment because there was no evidence in the record that assault weapons covered by the statute are in common use by law-abiding citizens, as required by relevant Supreme Court precedent. The court also held that the two vehicle-related offenses involved separate criminal objectives and thus did not require a stay under section 654. However, the court agreed that the custody credits were miscalculated and directed the trial court to correct the abstract of judgment accordingly. The judgment was otherwise affirmed. View "People v. Crenshaw" on Justia Law

The petitioner and real party in interest are the parents of a minor son, Xander. The petitioner, who has primary physical custody, was found in contempt by the Superior Court of Orange County for five alleged violations of custody-related court orders. The contempt findings were based on the petitioner’s unilateral decisions involving Xander’s participation in school sports and orthodontic treatment, as well as scheduling activities that overlapped with the other parent’s visitation time. The central factual disputes involved whether the petitioner’s actions—signing Xander up for sports teams and braces—constituted violations of joint legal custody and scheduling orders.After a high-conflict parentage case, the trial court (Superior Court of Orange County) conducted a contempt proceeding based on an amended Order to Show Cause filed by the real party in interest. Initially, 36 violations were alleged; after dismissal of many counts, a trial was held on five remaining counts. The trial court found the petitioner guilty on all counts, imposing a $10,000 sanction. The findings were largely based on a pattern of the petitioner presenting decisions to the other parent as a fait accompli.On review, the California Court of Appeal, Fourth Appellate District, Division Three, strictly construed the underlying orders and held that the contempt judgment was unsupported by substantial evidence of willful violation. The court found that the joint legal custody order did not require mutual consent for specific activities and did not prohibit unilateral decision-making, while the scheduling order did not extend to the petitioner’s authorization of Xander’s participation in events scheduled by third parties. The Court of Appeal granted the petition for writ of certiorari and annulled the contempt judgment, concluding that the orders lacked the specificity necessary to support a finding of contempt. The petitioner was awarded costs for the proceeding. View "Houser v. Superior Court" on Justia Law