Justia California Court of Appeals Opinion Summaries

A passenger was seriously injured after the driver of a remotely rented vehicle, accessed via a membership-based car-sharing service, crashed while under the influence of alcohol. The driver, a university student and approved member of the rental service, reserved the vehicle through a mobile app late at night after consuming alcohol at a party. The process for renting and accessing the car involved no face-to-face interaction with company staff, and the company had no prior knowledge of the driver’s intoxication or any history of impaired driving. Following the crash, the driver was convicted of felony DUI causing injury.The injured passenger sued the car-sharing company and its affiliated vehicle owner in the Superior Court of Yolo County, alleging negligent entrustment for providing the car to an unfit driver, negligent maintenance for failing to include technology to detect driver impairment, and vicarious liability based on vehicle ownership. Both sides moved for summary judgment. The trial court ruled for the defendants, holding that the company owed no duty to inquire about a renter’s impairment at the time of a remote rental, had no duty to install alcohol-detection devices, and was shielded from vicarious liability by federal law (the Graves Amendment).On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. The court held that remote rental car companies are exempt from statutory requirements to inspect for signs of impairment at the time of rental, per Civil Code section 1939.37, and that courts should not impose additional investigatory duties absent legislative action. The court also held that the Graves Amendment preempts state law claims of vicarious liability based solely on vehicle ownership. Judgment for the defendants was therefore affirmed. View "Tavares v. Zipcar, Inc." on Justia Law

The case centers on a defendant who was convicted by a jury of multiple offenses resulting from his involvement in a shootout with police officers in San Diego. During jury selection, the prosecution exercised a peremptory challenge to remove a prospective juror (Juror 1), who was believed to be a Latina, based on the prosecutor’s belief that she was confused about the concept of intent. The defendant objected, arguing that the peremptory challenge was being used to exclude Hispanic or Latina jurors. The trial court adopted the prosecution’s rationale, found that Juror 1 was confused about intent, and overruled the objection.The Superior Court of San Diego County presided over the trial and issued the challenged judgment, sentencing the defendant to a lengthy prison term. The defendant appealed, asserting that the trial court’s finding about Juror 1’s confusion was unsupported by the record. On appeal, the prosecution argued that the trial court’s factual finding was supported by substantial evidence and that the defendant had forfeited certain arguments for not making more specific objections during trial.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. Applying de novo review as mandated by statute, the appellate court concluded that the record did not support the trial court’s finding that Juror 1 was confused about intent. The court further held that the prosecutor’s justification—juror confusion—was a presumptively invalid reason for a peremptory challenge under section 231.7 of the Code of Civil Procedure, and that the trial court failed to properly confirm the asserted behavior occurred. Because there was no substantial evidence to support the prosecutor’s stated reason, the appellate court held that the judgment must be reversed and remanded for a new trial. View "People v. Aguilar" on Justia Law

A woman, Susan, was one of three beneficiaries of her father Warren’s trust. She believed the trust’s terms were unfair to her compared to her brothers, David and Michael, as her share was subject to restrictive terms and higher taxes. Warren allegedly wanted to amend the trust to make distributions equal among his children, and had consulted an attorney about this. Susan claimed that David and Michael undertook several actions in 2021 to prevent Warren from making this amendment, including interfering with his lawyer, making accusations against Susan, and isolating Warren.Previously, Susan filed a probate petition in Alameda County Superior Court, seeking to remove David as trustee and as Warren’s agent, and alleging elder isolation and similar misconduct by her brothers. The probate petition raised many of the same factual allegations later made in this civil case. After Warren’s death, Susan dismissed her probate petition without prejudice. She then filed a civil complaint, asserting claims for intentional interference with expected inheritance (IIEI) and elder financial abuse. The elder abuse claim was later dismissed, and the IIEI claim proceeded. David filed a demurrer, arguing Susan had an adequate remedy in probate, among other defenses.The California Court of Appeal, First Appellate District, Division Four, reviewed the case after the trial court sustained the demurrer without leave to amend and dismissed Susan’s complaint. The appellate court held that Susan’s IIEI claim could not proceed because she had an adequate remedy in probate. The court reasoned that the tort of IIEI is only available when probate does not provide a remedy, and Susan, as a beneficiary, had standing and the ability to seek relief in probate but chose to dismiss her petition. The judgment dismissing the complaint was affirmed. View "Halperin v. Halperin" on Justia Law

Plaintiffs brought a lawsuit against the operator of an assisted living facility, alleging negligence, breach of contract, and wrongful death after a facility employee moved the decedent, allegedly causing her health to deteriorate and leading to her death eight days later. The Superior Court of Sacramento County granted summary adjudication in favor of the defendant on the negligence and wrongful death claims but denied it as to the breach of contract claim. Plaintiffs then voluntarily dismissed the entire action without prejudice rather than proceed to trial on the remaining claim.After the voluntary dismissal, plaintiffs appealed, but the California Court of Appeal, Third Appellate District, dismissed the appeal, holding that a voluntary dismissal without prejudice was not an appealable final judgment. Plaintiffs then moved in the trial court to set aside their voluntary dismissal; when this was denied, they again appealed, and the Court of Appeal again dismissed, reiterating that there was no appealable final judgment.Subsequently, the trial court entered a judgment of costs in favor of the defendant. Plaintiffs appealed from this costs judgment, arguing that it constituted a final judgment that permitted them to challenge all prior orders in the case, including the summary adjudication. The California Court of Appeal, Third Appellate District, rejected this argument, holding that the costs judgment, entered after a nonappealable voluntary dismissal without prejudice, was not itself an appealable final judgment for the purposes of raising the underlying claims. The court explained that plaintiffs were not challenging the costs order itself, but were seeking review of prior nonappealable orders, which is not permitted. The appeal was therefore dismissed. View "Viani v. Fair Oaks Estates, Inc." on Justia Law

The case involves an individual, B.K., who has schizophrenia and has been under a conservatorship pursuant to the Lanterman-Petris-Short (LPS) Act since 2019. The conservatorship was initially established after B.K. was found to be gravely disabled as a result of a mental disorder, and it has been renewed annually following court hearings. In several renewal proceedings, B.K. expressed her desire to contest the conservatorship, at times requesting either a court or jury trial. At the most recent renewal proceeding, B.K. initially requested a jury trial but later, after consulting with her attorney, chose to proceed with a court trial instead. B.K. confirmed this choice in open court.The Superior Court of Los Angeles County conducted the court trial, during which expert testimony and B.K.’s own statements supported a finding that she remained gravely disabled and unable to care for herself due to her mental illness. The court renewed the conservatorship for another year. B.K. appealed, arguing that the trial court failed to adequately advise her of her right to a jury trial or to ensure that her waiver of that right was knowing and intelligent.The California Court of Appeal, Second Appellate District, Division Four, reviewed the case. Applying de novo review to statutory claims and substantial evidence review to the trial court’s implied finding, the Court of Appeal concluded that B.K. was aware of her right to a jury trial and that, under the totality of the circumstances, her waiver—made through counsel and confirmed in court—was knowing and intelligent. The appellate court held that direct advisement or a personal waiver was not required under the LPS Act when counsel confers with the conservatee and there is no indication of lack of authority or client understanding. The court affirmed the ruling, finding no reversible error. View "Conservatorship of B.K." on Justia Law

An 11-year-old student, Therese, died by suicide at her father's home during her school’s winter break. Her parents brought claims against the school district, alleging negligent hiring, supervision, and training of staff, failure to protect Therese from bullying, and inadequate response to her expressions of suicidal ideation. They argued the district failed to fulfill its duty to supervise students and to inform them of Therese’s condition. The parents also pursued a survival claim for Therese’s pre-death suffering, alleging harm occurred on campus due to the district’s negligence.The Superior Court of Solano County denied the school district’s motion for summary judgment, finding triable issues of fact as to whether the district exercised reasonable care and whether Therese suffered injury on campus due to the district’s negligence. The court relied on the California Supreme Court’s decision in Hoyem v. Manhattan Beach City School District, determining that statutory immunity under Education Code section 44808 did not apply because there were factual questions about on-campus harm and failure to exercise reasonable care.The Court of Appeal of the State of California, First Appellate District, Division Four, reviewed the case on a petition for writ of mandate. The appellate court held that under section 44808, the district is immune from liability for harms resulting from Therese’s off-campus suicide, as she was not under the district’s supervision at the time. However, the court determined that this immunity does not extend to the survival claim, which concerns alleged on-campus harm while Therese was under the district’s supervision. The appellate court ordered the trial court to grant summary adjudication in favor of the district on the wrongful death and related claims but allowed the survival claim to proceed. View "Vallejo City Unified School Dist. v. Superior Court" on Justia Law

In this case, the defendant was indicted along with several co-defendants for the murder of Kisasi Baltrip and related offenses following a grand jury proceeding in 2007. The charges included first-degree murder, conspiracy, discharge of a firearm, and gang participation, with various enhancements. The defendant later pleaded no contest to second-degree murder and other charges as part of a plea agreement, admitting to a firearm enhancement. The factual basis for the plea was stipulated to be found in police reports and grand jury testimony. He was sentenced to 15 years to life plus additional terms for the enhancements and related offenses, and the judgment was affirmed on appeal after a modification to custody credits.Subsequently, the defendant filed a petition for resentencing under Penal Code section 1172.6, which provides relief to certain individuals convicted of murder under theories that have since been restricted by legislative reform. The Superior Court of Kern County initially denied the petition at the prima facie stage, but the California Court of Appeal, Fifth Appellate District, reversed and remanded for a further hearing. Upon remand, the trial court conducted an evidentiary hearing and admitted the grand jury transcript, police reports, witness statements, and other law enforcement documents over defense objection, relying on these materials to deny the petition on the basis that the defendant was a major participant who acted with reckless indifference to human life.On appeal, the California Court of Appeal, Fifth Appellate District, held that neither the grand jury transcript nor the law enforcement-generated documents were admissible at the section 1172.6 evidentiary hearing under the governing statutory exception for evidence “previously admitted at any prior hearing or trial.” The court vacated the denial of the petition and remanded for a new evidentiary hearing, permitting the prosecution the opportunity to present admissible evidence. The holding was not that the petition should be granted outright, but rather that a new hearing must be held applying proper evidentiary standards. View "P. v. Dixon" on Justia Law

The underlying dispute arose after a public university system in California revised its student vaccination policy, reducing the number of mandatory immunizations required for incoming students as of fall 2023. The faculty union, representing teaching and academic staff, believed this policy change could negatively affect the health and safety of faculty members, especially those who are immunocompromised. Upon learning of the change shortly after its adoption, the union formally demanded bargaining over the policy’s effects. The university responded that the policy did not pertain to employment terms but was willing to meet and discuss the union’s concerns. The union declined this offer and instead filed an unfair practice charge, alleging the university failed to bargain in good faith.An administrative law judge for the Public Employment Relations Board (PERB) heard the case and found that, while the vaccination policy itself was not a mandatory subject of bargaining, its foreseeable effects on faculty health required effects bargaining. The judge concluded the university violated its statutory duty by implementing the policy without bargaining and ordered remedies including rescinding the policy and compensating affected employees. The university contested these findings, asserting it neither implemented the policy before the charge was filed nor refused to bargain, and that accommodations for affected faculty were already available under disability laws.On review, PERB largely upheld the administrative law judge’s findings, holding the university had a duty to bargain over the effects of the policy and had begun implementing it without sufficient notice and opportunity for bargaining. However, the California Court of Appeal, Second Appellate District, found that while substantial evidence supported PERB’s conclusion that the policy had reasonably foreseeable effects on faculty health and thus required effects bargaining, there was no substantial evidence the university had implemented the policy or definitively refused to bargain prior to the union’s charge. Therefore, the court affirmed PERB’s ruling on the duty to bargain effects, but vacated the finding of a statutory violation and the associated remedies, remanding the matter for the parties to engage in effects bargaining. View "Trustees of the Cal. State Univ. v. Public Emp. Relations Bd." on Justia Law

A man faced criminal charges stemming from two separate incidents: one in San Diego in August 2020, where he struck a taxi driver with a skateboard during what appeared to be a psychotic episode, and another in Newport Beach in March 2022, where he damaged property at a car dealership and stole a yacht, causing injury and property damage. After the first incident, he was diagnosed with paranoid schizophrenia and granted pretrial mental health diversion, but this was revoked following the second incident. After the Newport Beach offense, he was diagnosed by another expert with bipolar disorder and related conditions, with evidence suggesting he had been misdiagnosed and improperly medicated prior to the second incident.The Superior Court of Orange County considered his motion for pretrial mental health diversion under Penal Code section 1001.36, supported by expert reports stating his mental health conditions contributed to the offenses and that he would likely respond to treatment without posing an unreasonable risk to public safety if treated in the community. The prosecution opposed, arguing prior diversion had failed and that he posed a danger. The trial court denied the motion, finding him eligible but not suitable for diversion due to doubts about his responsiveness to treatment and concerns about danger to public safety, relying in part on his history of declining treatment and the circumstances of the offenses.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the lower court had abused its discretion. The appellate court held that the trial court applied the wrong legal standard regarding responsiveness to treatment by disregarding the uncontradicted opinion of a qualified mental health expert. It also found the trial court’s determination that the defendant posed an unreasonable risk of danger was not supported by substantial evidence. The appellate court granted a writ of mandate directing the trial court to vacate its order denying diversion and to reconsider the motion consistent with the proper legal standards. View "Siam v. Superior Court" on Justia Law

Tara Starr petitioned for dissolution of her marriage to Thomas Starr, with the principal dispute centering on the date of separation—Tara claimed 2012 and Thomas asserted 2020. Tara’s original petition alleged a separation date of March 20, 2009, but after retaining counsel, she amended her petition to allege June 2, 2020, as the separation date. Throughout subsequent proceedings, including case management statements, trial briefs, and settlement conference statements, Tara consistently maintained that the actual separation occurred in 2012, and Thomas continued to dispute her position, claiming September 2020.The Contra Costa County Superior Court presided over pretrial and trial proceedings. The matter was bifurcated to first determine the separation date. At the trial, the court, sua sponte, raised the issue that Tara was bound by her amended petition’s allegation of June 2, 2020, as the separation date and suggested there was no controversy. Despite both parties previously treating the date as contested and preparing for trial on that issue, the court held Tara to the June 2020 date, after Thomas ultimately accepted it, and entered an order accordingly. Tara’s subsequent motion to set aside the order was denied, with the court finding her pleading to be a deliberate litigation strategy and not a mistake.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court held that Tara’s amended petition did not constitute a binding judicial admission regarding the date of separation, as Thomas had consistently contested the allegation throughout the litigation, and both parties prepared for trial on the disputed issue. The appellate court reversed the trial court’s order and remanded the matter for further proceedings to determine the separation date, denying Tara’s request for reassignment to a different judge. Tara was awarded costs on appeal. View "In re Marriage of Starr" on Justia Law