Justia California Court of Appeals Opinion Summaries

The City of Los Angeles implemented the recycLA program in 2017, establishing exclusive franchise agreements with private waste haulers to provide waste collection services for commercial and multi-unit residential properties. Under these agreements, haulers paid the City a percentage of their gross receipts as a franchise fee. Several property owners and tenants who paid for waste hauling services under this system filed a consolidated class action against the City, alleging that the franchise fees were actually an unlawful tax imposed without voter approval, in violation of Proposition 218 and related constitutional provisions. The plaintiffs sought refunds of the alleged illegal taxes and declaratory relief regarding the validity of the fees.The Superior Court of Los Angeles County considered the plaintiffs’ motion for class certification. While the court found the proposed class sufficiently numerous and ascertainable, and agreed that the question of whether the franchise fees constituted an illegal tax was subject to common proof, it identified a fundamental problem: not all proposed class members suffered an economic loss, as some landlords and property owners may have passed the cost of the fees on to tenants. The court concluded that entitlement to refunds was not susceptible to common proof and that individual issues predominated over common ones. It also found that a class action was not the superior method for resolving the dispute, due to the risk of unjust enrichment and the complexity of determining who actually bore the cost of the fees. The court denied class certification.On appeal, the California Court of Appeal, Second Appellate District, Division Four, reviewed the trial court’s order under the substantial evidence standard. The appellate court affirmed the denial of class certification, holding that the trial court did not err in finding that individual issues predominated and that class treatment was not superior. The order denying class certification was affirmed. View "Leeds v. City of L.A." on Justia Law

Haamid Khan created an account with Coinbase, Inc., an online platform for buying, selling, and storing digital currencies. Khan alleged that Coinbase charged customers a hidden “Spread Fee” during transactions, which was not clearly disclosed to users. He claimed that the fee was only revealed if a customer clicked a tooltip icon and that the platform’s design misled less sophisticated users by imposing the fee only on those using the default trading option. Khan sought an injunction under California’s unfair competition and false advertising laws to prohibit Coinbase from continuing these practices.Coinbase responded by filing a petition in the City & County of San Francisco Superior Court to compel arbitration, citing a user agreement that included an arbitration clause and a waiver of class and public injunctive relief. The trial court denied Coinbase’s petition, finding that Khan’s claims sought public injunctive relief, which could not be waived or compelled to arbitration under California law, specifically referencing McGill v. Citibank, N.A. The court determined that the relief sought would benefit the public at large, not just Khan or a defined group of users.The California Court of Appeal, First Appellate District, Division Three, reviewed the case de novo. The appellate court affirmed the trial court’s order, holding that Khan’s complaint seeks public injunctive relief under the standards set forth in McGill. The court found that the arbitration agreement’s waiver of public injunctive relief was invalid and unenforceable. It concluded that Khan’s requested injunction would primarily benefit the general public by prohibiting ongoing deceptive practices, and thus, his claims could proceed in court rather than arbitration. The order denying Coinbase’s petition to compel arbitration was affirmed. View "Kahn v. Coinbase, Inc." on Justia Law

A law firm sought to recover over $1.7 million in fees and costs for representing the Los Angeles County Sheriff, Alex Villanueva, and the Sheriff’s Department in litigation initiated by the County of Los Angeles. Due to a conflict of interest, the County’s Board of Supervisors offered Villanueva independent counsel, allowing him to select his attorney but reserving discretion over compensation. Villanueva chose the law firm, which entered into an engagement agreement with him. The County, however, sent its own retainer agreement to the firm, which the firm refused to sign. The firm continued its representation but was never paid. After the firm demanded arbitration under its engagement agreement, the County and related plaintiffs filed suit seeking a declaration that no valid agreement to arbitrate existed and an injunction against the arbitration.The Superior Court of Los Angeles County granted a preliminary injunction, then summary judgment for the County plaintiffs, finding the Sheriff lacked authority to enter into the engagement agreement. The court denied the law firm’s post-judgment motion for leave to file a cross-complaint, citing both untimeliness and bad faith. The firm then filed a separate lawsuit against the County and related defendants, asserting breach of contract and related claims. The trial court sustained the County’s demurrer, dismissing the complaint with prejudice on grounds that the claims were compulsory cross-claims in the earlier action and for failure to allege compliance with the Government Claims Act.The California Court of Appeal, Second Appellate District, Division Eight, affirmed both the judgment in the County’s action and the dismissal of the law firm’s separate lawsuit. The court held that the Sheriff did not have authority to retain counsel on his own; only the Board of Supervisors could contract for legal services. The law firm’s claims were barred as compulsory cross-claims and for failure to comply with the Government Claims Act. View "County of Los Angeles v. Quinn Emanuel Urquhart & Sullivan, LLP" on Justia Law

A defendant committed several serious offenses, including first-degree murder and attempted murder, when he was 17 years old. In 2002, a jury convicted him of these crimes, and he was sentenced to a total term of 79 years to life with the possibility of parole. The sentence included both determinate and indeterminate terms, with firearm enhancements. The crimes occurred in 2000, and the defendant was not sentenced to life without the possibility of parole (LWOP), but rather to a lengthy term that could be considered the functional equivalent of LWOP.Years later, the defendant filed a petition in the Superior Court of Ventura County seeking recall of his sentence under Penal Code section 1170, subdivision (d)(1)(A), which allows for resentencing of juvenile offenders sentenced to LWOP. The trial court granted the petition, reasoning that the defendant’s 79-year-to-life sentence was functionally equivalent to LWOP, relying on the reasoning in People v. Heard (2022) 83 Cal.App.5th 608 and People v. Sorto (2024) 104 Cal.App.5th 435. The court recalled the sentence, conditionally reversed the conviction and sentence, and certified the matter to juvenile court for further proceedings under Proposition 57. Meanwhile, the defendant received a youth offender parole hearing under Penal Code section 3051, but was found unsuitable for parole.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. It held that the defendant was not eligible for relief under section 1170(d)(1)(A) because he was not sentenced to LWOP, and that subsequent legislative changes, specifically section 3051, rendered the Heard rule moot. The court concluded that since the defendant had already received a parole hearing, he was not serving the functional equivalent of LWOP. The appellate court reversed the trial court’s orders. View "P. v. Lara" on Justia Law

The defendant was charged with resisting and obstructing an officer, domestic battery with corporal injury, and assault on a peace officer. During jury selection, the defendant sought to remove Juror 122 for cause due to the juror’s background in law enforcement and personal experience with domestic violence, but the Superior Court of Orange County denied the challenge for cause after Juror 122 stated he could remain impartial. The defendant then used a peremptory challenge to remove Juror 122, but the prosecution objected under Code of Civil Procedure section 231.7, arguing the challenge was based on impermissible grounds. The trial court sustained the objection, keeping Juror 122 on the panel. The jury ultimately convicted the defendant on one count, convicted him of a lesser included offense on another, and acquitted him on the third count.The Appellate Division of the Superior Court of California, County of Orange, reviewed the case. It reversed the conviction on one count but affirmed the judgment in all other respects. The Appellate Division held that the “deemed prejudicial” standard in section 231.7(j)—which requires automatic reversal if an objection to a peremptory challenge is erroneously denied—does not apply when an objection is erroneously granted. Instead, the court applied traditional harmless error analysis and found the defendant had not shown prejudice from Juror 122’s inclusion.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the Appellate Division’s judgment. The main holding is that the “deemed prejudicial” standard in section 231.7(j) applies only to erroneous denials of objections to peremptory challenges, not to erroneous grants. When an objection to a peremptory challenge is erroneously granted, traditional rules regarding prejudicial error govern, and automatic reversal is not required. View "P. v. Guzman" on Justia Law

The case concerns a defendant who was convicted of first degree murder by torture and assault causing the death of a child. The prosecution’s theory was that the defendant either directly committed the crimes or aided and abetted his codefendant, the child’s mother, in committing them. The jury was instructed only on murder by torture and aiding and abetting, not on felony murder or the natural and probable consequences doctrine. The jury found the defendant guilty of first degree murder and assault causing death of a child, but a special circumstance finding was later reversed on appeal due to insufficient evidence of specific intent to kill.After the California Court of Appeal reversed the special circumstance finding but otherwise affirmed the judgment, the trial court resentenced the defendant. Following the enactment of Senate Bill 1437, which limited certain theories of murder liability and created a resentencing procedure under Penal Code section 1172.6, the defendant petitioned for resentencing. He argued that the jury instructions permitted conviction on an impermissible theory of imputed malice. The Napa County Superior Court denied the petition at the prima facie stage, finding the defendant had not shown he could not be convicted of murder under the amended statutes.The California Court of Appeal, First Appellate District, Division Two, reviewed the denial. The court held that the record conclusively established the defendant’s ineligibility for relief under section 1172.6 because he was convicted under a theory of murder—murder by torture, either as a direct perpetrator or as an aider and abettor—that remains valid after Senate Bill 1437. The court found that any alleged instructional error did not relate to changes made by the new law and affirmed the trial court’s order denying resentencing. View "People v. Warner" on Justia Law

The case concerns a woman who was charged, along with a codefendant, with the murder of her young daughter, with the special circumstance of torture, and with assault resulting in the death of a child under eight. The prosecution’s theory was that the murder was committed by torture, and that the defendant either directly committed the crimes or aided and abetted her codefendant. The jury was not instructed on felony murder or the natural and probable consequences doctrine; the only theory presented was murder by torture. The jury found the defendant guilty of first degree murder by torture and assault causing death of a child. On direct appeal, the special circumstance finding was reversed for insufficient evidence of specific intent to kill, but the murder conviction was affirmed based on evidence of deliberate and premeditated intent to cause extreme pain for a sadistic purpose.After the passage of Senate Bill 1437, which amended California’s murder statutes to eliminate certain forms of accomplice liability and created a resentencing procedure for those convicted under now-invalid theories, the defendant petitioned for resentencing under Penal Code section 1172.6. The Superior Court of Napa County denied the petition at the prima facie stage, finding the defendant ineligible for relief because she was not convicted under any theory affected by the statutory changes. The defendant appealed this denial.The California Court of Appeal, First Appellate District, Division Two, reviewed the case and affirmed the trial court’s order. The appellate court held that the record conclusively established the defendant’s ineligibility for relief under section 1172.6, as she was convicted solely under a theory of murder by torture, which remains a valid basis for murder liability after Senate Bill 1437. The court found that any alleged instructional error did not relate to the statutory changes and thus could not support resentencing relief under section 1172.6. View "People v. Krueger" on Justia Law

The case concerns a defendant who, while under the influence of methamphetamine, set fire to his sister’s doorbell and started another fire in the street. He was charged with arson of an inhabited structure and had a prior strike conviction. The defendant sought mental health diversion, presenting evidence of bipolar disorder and substance abuse disorder, and a mental health professional recommended residential treatment. The court initially granted diversion on the condition that the defendant be accepted into a residential treatment program. However, due to issues with Medi-Cal coverage and facility requirements, the defendant was unable to secure placement in the recommended residential program.After it became clear that residential treatment was not available, the defendant requested to participate in an intensive outpatient program with housing at a room and board facility, but the Superior Court of Sacramento County denied this request, citing concerns about public safety and the need for residential treatment as a condition precedent for diversion. The court then set aside the grant of diversion, without prejudice to reconsideration if a suitable residential program became available. The defendant later moved for public funding for private residential treatment, but the court denied the motion, explaining it lacked authority to order such funding after Medi-Cal declined coverage.On appeal, the California Court of Appeal, Third Appellate District, held that the trial court did not abuse its discretion in terminating mental health diversion when the required residential treatment was unavailable. The appellate court also held that Penal Code section 1001.36 does not require a trial court to order public funding for private treatment when existing public programs decline coverage. The judgment of the trial court was affirmed. View "People v. Riddle" on Justia Law

The case concerns the City of San Diego’s approval of a 2022 ballot measure to remove the longstanding 30-foot building height limit in the Midway-Pacific Highway Community Planning area. This height restriction, established by a 1972 voter initiative, was intended to preserve coastal views, community character, and mitigate issues such as congestion and pollution. In 2018, the City updated the community plan and prepared a program environmental impact report (PEIR) under the assumption that the height limit remained in effect. In 2020, the City attempted to remove the height limit via a ballot measure, but the measure was invalidated for failing to adequately consider environmental impacts as required by the California Environmental Quality Act (CEQA).Following the invalidation, the City prepared a supplemental environmental impact report (SEIR) and approved a second ballot measure in 2022. Save Our Access, a nonprofit, challenged this new measure, arguing that the City’s environmental review remained inadequate. The Superior Court of San Diego County denied Save Our Access’s petition for writ of mandate, finding that the City’s SEIR sufficiently addressed the environmental impacts by focusing on visual effects and neighborhood character, and by relying on the 2018 PEIR for other impact categories.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, found that the City’s SEIR was inadequate under CEQA. The court held that the City failed to meaningfully analyze the environmental impacts of allowing buildings above 30 feet, such as effects on noise, air quality, biological resources, and geological conditions. The court concluded that relying on the prior PEIR and deferring analysis to future site-specific projects did not satisfy CEQA’s requirements. The judgment was reversed and remanded, with instructions to grant Save Our Access’s petition and direct the City to comply with CEQA. View "Save Our Access v. City of San Diego" on Justia Law

The California Department of Water Resources (DWR) planned to conduct preconstruction geotechnical work, such as soil and groundwater testing, in the Sacramento-San Joaquin Delta and Suisun Marsh as part of preparations for the Delta tunnel project, which aims to improve water conveyance and environmental protection. Various municipal, tribal, and public interest entities objected, arguing that DWR could not begin this work until it certified that the tunnel project was consistent with the Delta Plan, as required by the Sacramento-San Joaquin Delta Reform Act of 2009. The disputed geotechnical work included soil borings, groundwater monitoring, test trenches, and other activities intended to inform the project’s design and mitigation measures.The Superior Court of Sacramento County reviewed several related actions brought by these entities. The plaintiffs sought and obtained preliminary injunctions preventing DWR from conducting the preconstruction geotechnical work until it submitted a certification of consistency with the Delta Plan. The trial court found that the geotechnical work was an integral part of the tunnel project, which was a “covered action” under the Delta Reform Act, and concluded that DWR was required to certify consistency before initiating any part of the project, including the geotechnical work.On appeal, the California Court of Appeal, Third Appellate District, reversed the trial court’s orders. The appellate court held that the Delta Reform Act does not require DWR to submit a certification of consistency before engaging in preconstruction geotechnical work, distinguishing the requirements of the Delta Reform Act from those of the California Environmental Quality Act (CEQA). The court found that the geotechnical work was not itself a “covered action” under the Delta Reform Act and that the Act does not incorporate CEQA’s prohibition against “piecemealing.” The case was remanded for the trial court to reconsider the motions for preliminary injunction in light of this holding. View "Tulare Lake Basin Water Storage Dist. v. Dept. of Water Resources" on Justia Law