Justia California Court of Appeals Opinion Summaries

The plaintiff, a former employee of California State University, Chico, filed suit against her prior employer and other parties alleging employment discrimination, whistleblower retaliation, and wrongful termination. She initiated the lawsuit on April 19, 2019. Under Code of Civil Procedure section 583.310, as extended by Judicial Council emergency rule 10 due to the COVID-19 pandemic, she was required to bring her case to trial by October 19, 2024. However, at a case management conference in March 2024, the trial court scheduled the trial for February 3, 2025, a date beyond the statutory deadline.After the trial date was set, the defendants moved to dismiss the case for failure to bring it to trial within the statutory period. They argued that no exception to the deadline applied, specifically contesting the existence of any oral agreement to extend the deadline. The plaintiff opposed dismissal, asserting that both parties had verbally agreed in open court to the February 2025 trial date, and that this agreement was recorded in the minute order. However, the minute order only documented the setting of the trial and related conferences, and contained no indication of any oral stipulation or agreement. The Superior Court of Butte County found that the plaintiff had not demonstrated a valid oral agreement to extend the deadline under section 583.330, subdivision (b), and granted the motion to dismiss with prejudice.On appeal, the California Court of Appeal, Third Appellate District, reviewed the trial court’s decision under the abuse of discretion standard, and interpreted the statute de novo. The appellate court held that an oral agreement to extend the statutory trial deadline under section 583.330, subdivision (b), must be reflected in the court’s minutes or a transcript. Because the record did not include any such evidence, the exception did not apply. The court affirmed the judgment of dismissal and awarded costs to the defendants. View "Randolph v. Trustees of the Cal. State University" on Justia Law

A nonprofit organization challenged the validity of the City of La Habra’s February 2023 revision to its housing element, arguing that the modifications were adopted by the City Manager rather than the City Council and without additional public hearings. The housing element, part of the city’s general plan, is subject to periodic revision and state review. In this instance, after several public meetings and hearings on earlier drafts, the City Council adopted the housing element in September 2022 and authorized the City Manager to make further technical or clerical changes necessary for state certification. The City Manager subsequently approved additional revisions in February 2023, which were submitted to and certified by the Department of Housing and Community Development.In the Superior Court of Orange County, the nonprofit filed a petition for writ of mandate, seeking to prohibit the City from treating the February 2023 version as validly adopted. The court denied the petition, finding that the City had met public participation requirements through hearings on prior drafts and online posting of the revised element. The trial court also ruled that the City Council validly delegated authority to the City Manager for minor revisions and determined that any procedural errors were harmless, as required by Government Code section 65010, subdivision (b).The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the judgment. The court held that additional public hearings were not required for the February 2023 modifications since they constituted part of the ongoing revision and certification process, rather than a distinct amendment. It further held that the City Council’s delegation of authority to the City Manager was valid and consistent with local law. Finally, the court found no prejudicial error or substantial harm resulted from the process used, upholding the presumption of validity following state certification. The judgment was affirmed. View "Californians for Homeownership v. City of La Habra" on Justia Law

Plaintiffs alleged that the City of Berkeley violated the Ralph M. Brown Act during three city council meetings in late 2023 and early 2024. At each meeting, disruptions from attendees prevented the council from conducting business. The mayor determined that order could not be restored by removing disruptive individuals but did not order the meeting room cleared. Instead, the meetings were recessed and reconvened in a different, smaller room. The press was allowed to attend in person, while the public could join by video, but the new location could not accommodate all nondisruptive members of the public. No attempt was made to restore order by removing disruptive individuals, nor was the meeting room ordered cleared.The Alameda County Superior Court sustained the defendants’ demurrer without leave to amend, holding that section 54957.9 of the Brown Act does not require the city council to first attempt to remove disruptive individuals before determining that order cannot be restored. The trial court further found that the city council complied with the statute by recessing and reconvening the meetings in a different room with press attendance. The case was dismissed with prejudice, and plaintiffs appealed.The Court of Appeal of the State of California, First Appellate District, Division Four, reviewed the case. It held that, under section 54957.9, a legislative body may order the meeting room cleared and continue in session, but the statute does not authorize relocating the meeting to another room. The court found that recessing and reconvening in a new location is not equivalent to ordering the original meeting room cleared. Plaintiffs stated a claim for relief by alleging that the city council failed to order the meeting room cleared and instead moved the meetings. The judgment was reversed. View "Berkeley People's Alliance v. City of Berkeley" on Justia Law

In this case, Raul Rodriguez was charged in 1994 with several crimes, including the murder of Jose Alvaro Salavia. During the preliminary hearing, three police officers testified, primarily relaying hearsay statements from Rodriguez’s mother and uncle, indicating Rodriguez admitted to the shooting. No other evidence implicated Rodriguez, and the defense presented none. The court found probable cause, and Rodriguez subsequently pleaded guilty to second degree murder. The plea hearing did not include admissions to specific facts or a stipulation to the preliminary hearing transcript; the court found a factual basis based on counsel’s stipulation.Years later, in 2022, Rodriguez petitioned for resentencing under Penal Code section 1172.6, arguing that recent changes to California homicide law made him ineligible for a murder conviction under the prior theory. The Superior Court of Los Angeles County appointed counsel, ordered briefing, and reviewed the preliminary hearing transcript, which contained the police officers’ hearsay testimony. The People argued Rodriguez was the sole perpetrator, making him ineligible for relief. Rodriguez did not provide specific factual allegations in response and submitted on the papers. The court denied the petition, finding Rodriguez had not established a prima facie case for resentencing.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the order. It held that, at the prima facie stage of a section 1172.6 resentencing petition, courts may rely on hearsay statements admitted at the preliminary hearing, even if they would be inadmissible at a later evidentiary hearing, because the transcript serves to frame the issues rather than resolve factual disputes. The court affirmed the denial of Rodriguez’s petition but remanded the case to allow him thirty days to file an amended petition with nonconclusory factual allegations. View "People v. Rodriguez" on Justia Law

John Ross Craig, along with two accomplices, entered a clothing store in 2012 and robbed employees at gunpoint, ordering them to lie on the floor and taking their wallets and phones. After being surrounded by police, the group negotiated for two hours before surrendering. Craig was charged with multiple counts, including kidnapping to commit robbery and second degree robbery, with firearm and gang enhancements, as well as allegations of prior serious felony convictions. In 2015, he pleaded no contest to two counts of second degree robbery, admitted to the firearm enhancement and prior felony allegations, and was sentenced to 23 years in prison.In 2024, Craig petitioned the Superior Court of Los Angeles County to recall and resentence him under Penal Code section 1172.1, citing several legislative changes giving courts discretion to strike certain enhancements and asking for consideration of his post-conviction rehabilitation, youth at the time of the offense, and parole plans. The prosecution opposed, highlighting Craig’s prison rule violations. The superior court denied the petition, reasoning that Craig should be held to the plea agreement he entered and expressing skepticism about his rehabilitation and employment plans.On appeal, the California Court of Appeal, Second Appellate District, Division Seven, reviewed whether the superior court’s order denying Craig’s petition was appealable and whether the court erred in its decision. The appellate court held that the denial affected Craig’s substantial rights and was therefore appealable. Importantly, it found the superior court abused its discretion by applying an incorrect legal standard—relying on Craig’s plea agreement rather than the statutory criteria for resentencing under section 1172.1. The appellate court reversed the denial and directed the superior court to conduct a new resentencing hearing in accordance with the proper legal standard. View "People v. Craig" on Justia Law

Several individuals who were employed by the City and County of San Francisco and were at least 40 years old when hired brought a class action lawsuit alleging that the City’s method for calculating disability retirement benefits under its retirement system discriminated against employees based on age. The system employs two formulas; Formula 1 is used if it yields a benefit exceeding a percentage threshold, while Formula 2 is used if the threshold is not met. Plaintiffs argued that Formula 2, which imputes years of service until age 60, resulted in lower benefits for those who entered the retirement system at age 40 or older, in violation of the California Fair Employment and Housing Act (FEHA).After initial proceedings in the San Francisco City and County Superior Court—including a demurrer sustained on statute of limitations grounds and subsequent reversal by the Court of Appeal—the plaintiffs filed an amended complaint asserting FEHA claims for disparate treatment and disparate impact, as well as claims for declaratory relief, breach of contract, and equal protection violations. The trial court certified a class and denied summary judgment due to triable issues of fact. A bench trial followed, where both parties presented expert testimony on whether Formula 2 disparately impacted older employees.The Court of Appeal of the State of California, First Appellate District, Division Four, reviewed the trial court’s findings. It affirmed the judgment, holding that plaintiffs failed to prove intentional age discrimination or disparate impact under FEHA. The court found that Formula 2 was motivated by pension status and credited years of service, not by age, and that plaintiffs’ evidence was insufficient as it was based on hypothetical calculations rather than actual data. The trial court’s denial of plaintiffs’ request to amend their complaint after trial was also upheld, as any alleged error was not reversible on the record. The judgment in favor of the City was affirmed. View "Carroll v. City and County of San Francisco" on Justia Law

A law enforcement agency served an electronic service provider with a search warrant for data associated with an email account belonging to a university graduate student under investigation for rape. The warrant was accompanied by a nondisclosure order (NDO) prohibiting the provider from notifying the student or anyone at the university about the warrant for 90 days. The provider did not contest the restriction against notifying the account holder but sought permission to inform a trusted contact at the university about the warrant's existence, citing concerns under the California Electronic Communications Privacy Act (CalECPA) and the First Amendment.The Superior Court of Los Angeles County reviewed a sealed affidavit and found that several statutory criteria for “adverse results” under CalECPA were present, justifying the NDO. When the provider requested to modify the order to allow notification of a university contact, the court considered the proposal but ultimately declined after law enforcement objected, noting the court lacked jurisdiction over the university and could not ensure compliance with the NDO. The order was extended once and later lifted after the target was arrested. The provider’s initial petition for writ of mandate was summarily denied by the California Court of Appeal. The California Supreme Court then granted review and transferred the matter back to the appellate court for further consideration.The California Court of Appeal, Second Appellate District, reviewed the case de novo and held that the trial court made the required findings under CalECPA before issuing the NDO and that the NDO did not violate the provider’s First Amendment rights. The court found the NDO served a compelling government interest and was narrowly tailored to protect the integrity of an ongoing investigation. The petition for writ of mandate was denied. View "Microsoft Corp. v. Superior Ct." on Justia Law

Jessica Garcia and other former employees brought a class action against The Merchant of Tennis, Inc., alleging failure to pay wages and other employment violations under California and federal law. In response, Merchant entered into approximately 954 individual settlement agreements (ISAs) with current and former employees, providing cash payments in exchange for waivers of their claims. Garcia, who had not signed an ISA, sought class certification and also moved to invalidate the ISAs, arguing that Merchant had obtained them through fraud and coercion, such as misrepresenting the scope of litigation and the claims being released.The Superior Court of San Bernardino County partially granted Garcia’s motion, finding the ISAs voidable at the election of each settling putative class member. The court ordered that curative notices be sent to those who had signed ISAs, allowing them to revoke their agreements and join the class action. However, the parties could not agree on the notice’s language, specifically whether it should inform class members that they might be required to repay the settlement amount if Merchant prevailed in the action. The trial court ruled that the notice did not need to include such repayment language, reasoning that federal cases suggested repayment was not required before joining the suit and that repayment could be treated as an offset to any judgment.The Court of Appeal of the State of California, Fourth Appellate District, Division Two reviewed the trial court’s order. It held that under California Civil Code sections 1689, 1691, and 1693, class members who rescind their ISAs may be required to repay Merchant the consideration received if Merchant prevails, but such repayment can be delayed until the conclusion of litigation. The trial court retains discretion to adjust equities between the parties at judgment. The writ of mandate was granted, directing the trial court to reconsider the curative notice in accordance with these principles. View "The Merchant of Tennis v. Superior Ct." on Justia Law

The case concerns the approval of the Giovannioni Logistics Center Project, a large warehouse development in the City of American Canyon, California. The project requires American Canyon to certify an Environmental Impact Report (EIR) under the California Environmental Quality Act (CEQA), specifically addressing water supply issues since the city relies on outside sources, including water purchased from the neighboring City of Vallejo under a longstanding agreement. Vallejo’s water comes from the State Water Project and its own appropriative water right (License 7848). Vallejo objected to the EIR, asserting that it did not adequately disclose limitations on water availability, including place of use restrictions on License 7848 and ongoing contract litigation between the cities.Vallejo filed a petition for writ of mandate in Napa County Superior Court, later transferred to Sacramento Superior Court, contending that the EIR failed to meet CEQA and Water Code requirements regarding water supply disclosures and contingency planning. The trial court reviewed Vallejo’s arguments, which included claims that the EIR did not account for actual water delivered, failed to assess legal restrictions on water use, neglected the implications of curtailments during drought, and ignored the impact of contract disputes. After argument, the trial court denied Vallejo’s petition and entered judgment for American Canyon and the project developer, Buzz Oates LLC.The California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. It held that the EIR and water supply assessment complied with CEQA and the Water Code. The court found that the EIR provided sufficient detail about water supply sources and reliability, reasonably addressed foreseeable uncertainties, and did not require more specific disclosures or contingency planning absent evidence of insufficient supply. The court also concluded that any technical omissions were harmless and that Vallejo failed to demonstrate prejudice or a legal deficiency in the environmental review process. View "City of Vallejo v. City of American Canyon" on Justia Law

The petitioner is an inmate serving an indeterminate sentence of 45 years to life for first degree murder, who challenged the timing of his initial youth offender parole hearing under Penal Code section 3051. His main contention was that, under regulations adopted by the California Department of Corrections and Rehabilitation (CDCR) following Proposition 57 and Assembly Bill 965, only educational merit credits are counted toward advancing his youth parole eligible date (YPED), whereas a wider range of credits—including good conduct, milestone completion, rehabilitative achievement, and extraordinary conduct credits—may be applied to advance the minimum eligible parole date (MEPD) for other indeterminately sentenced inmates. The petitioner claimed this distinction deprived him of thousands of days of credit and delayed his parole hearing compared to similarly situated inmates.Previously, the California Court of Appeal, First Appellate District summarily denied the petitioner’s habeas corpus petition. The California Supreme Court then granted review, transferring the case back to the Court of Appeal with instructions to issue an order to show cause and reconsider the petitioner’s claims.Upon review, the California Court of Appeal, First Appellate District considered both statutory and constitutional arguments, including equal protection and due process claims. The court applied rational basis review to the equal protection claim, emphasizing the deferential standard and the need for a rational relationship between the regulatory distinction and a legitimate state interest. The court concluded that limiting credits for youth offender parole hearings to educational merit credits serves administrative and operational needs, promoting certainty and stability in scheduling, and is rationally related to legitimate governmental objectives. The court found no merit to the statutory, equal protection, or due process challenges and denied habeas corpus relief, discharging the petition. View "In re Thai" on Justia Law