Justia California Court of Appeals Opinion Summaries

The case involves a dispute over whether the proceeds of an Individual Retirement Account (IRA) should be included in the estate of a deceased individual, Thomas Reich, for the purpose of calculating the share of his surviving spouse, Pamela Reich, as an "omitted spouse" under California law. Thomas had created a revocable trust in 2003, which was amended in 2016, to distribute his assets upon his death. He designated his daughter and granddaughter as beneficiaries of the IRA, which had a balance of approximately $1.5 million at the time of his death. Thomas married Pamela in 2020 but did not update his trust to provide for her before his death in 2021.Pamela initially filed a petition seeking an omitted spouse's share of Thomas's estate, including the IRA proceeds. The Los Angeles County Superior Court overruled a demurrer by the trust's beneficiaries, suggesting that the IRA proceeds might be included in the estate. However, a partial settlement was reached, excluding the IRA proceeds from Pamela's share. Pamela then filed two new petitions regarding her entitlement to the IRA proceeds, which were assigned to a different judge.The California Court of Appeal, Second Appellate District, reviewed the case and affirmed the probate court's orders dismissing Pamela's petitions. The court held that the IRA proceeds are nonprobate assets and do not pass through the decedent's testamentary trust to the separate trusts created for the beneficiaries. Therefore, the IRA proceeds are not part of Thomas's "estate" for the purpose of calculating Pamela's omitted spouse's share. The court also noted that the prior demurrer ruling was not controlling in this context. View "Reich v. Reich" on Justia Law

Blake Wentworth, a former professor at the University of California, Berkeley, sued the Regents of the University of California, alleging violations of the Fair Employment and Housing Act (FEHA) and the Information Practices Act (IPA). Wentworth claimed that the Regents failed to engage in the interactive process, provide reasonable accommodations, and invaded his privacy by leaking information about student complaints and his disability accommodations to the media.The Alameda County Superior Court granted summary adjudication in favor of the Regents on three of Wentworth’s causes of action under FEHA and IPA, denied his motion to compel discovery responses, and denied his request for a retrial on a cause of action for which the jury left the verdict form blank. The court also denied Wentworth’s post-judgment request for attorney’s fees and costs.The California Court of Appeal, First Appellate District, reviewed the case. The court affirmed the summary adjudication on the claims for failure to engage in the interactive process and provide reasonable accommodations, finding that the Regents had offered reasonable accommodations and engaged in the interactive process in good faith. However, the court reversed the summary adjudication of the invasion of privacy cause of action, finding that there were triable issues of fact regarding whether the Regents violated the IPA by leaking a letter about student complaints and disclosing information about Wentworth’s disability accommodation.The court also reversed the trial court’s denial of Wentworth’s motion for attorney’s fees and costs, remanding for further proceedings to determine whether Wentworth was the prevailing party under the IPA and whether he was entitled to fees under the catalyst theory. The court affirmed the trial court’s denial of Wentworth’s motion for a retrial on the personnel file cause of action, finding that Wentworth had forfeited his right to object to the verdict form by failing to raise the issue before the jury was discharged. View "Wentworth v. UC Regents" on Justia Law

In 2006, the petitioner was admitted to the State Department of State Hospitals as a sexually violent predator (SVP). In 2022, the superior court found him suitable for conditional release. However, before placing him in the community, the court reconsidered its decision, held a new hearing, and found him unsuitable for release. The petitioner argued that the superior court erred by denying him the assistance of experts during the contested hearing and that the ruling was not supported by sufficient evidence. The real party in interest conceded that the court erred in denying expert assistance but maintained that the court had the authority to reconsider its order.The superior court initially found the petitioner suitable for conditional release in October 2022, but difficulties in securing housing led to multiple placement hearings. In July 2023, Liberty Healthcare expressed concerns about the petitioner’s readiness for release and requested additional time for further review. The court granted a six-month continuance. In November 2023, the court reconsidered its previous order based on new circumstances and found the petitioner unsuitable for conditional release, citing his behavior and a report from the Department of State Hospitals.The California Court of Appeal, Third Appellate District, reviewed the case and concluded that the superior court erred in finding the petitioner unsuitable for conditional release without providing him the assistance of experts, as required by law. The court held that the petitioner was entitled to a new hearing with the procedural protections outlined in section 6608, including the appointment of experts. The court issued a peremptory writ of mandate directing the superior court to vacate its order and, if reconsideration is sought, to conduct a new hearing consistent with the statutory requirements. View "Price v. Superior Court" on Justia Law

The plaintiffs, employees of the State of California providing dental care to inmates, filed a lawsuit seeking compensation for time spent on pre- and post-shift safety and security activities. These activities included going through security and handling alarm devices. The defendants, including the State of California and related departments, filed a demurrer, arguing that these activities were not compensable under the Portal-to-Portal Act of the Fair Labor Standards Act (FLSA). The trial court sustained the demurrer without leave to amend, leading to the plaintiffs' appeal.The trial court ruled that the activities in question were not integral and indispensable to the plaintiffs' principal work of providing dental care, thus not compensable under the FLSA. The plaintiffs argued that the trial court improperly decided a factual question and that their claims were viable. The defendants maintained that the trial court's decision was correct and also argued that the plaintiffs' claims were precluded by the Memorandum of Understanding (MOU) governing their employment, that the relevant statutes did not apply to government employers, that the plaintiffs failed to exhaust contractual remedies, and that the claims were time-barred.The California Court of Appeal, First Appellate District, Division Two, concluded that the trial court erred in not accepting the plaintiffs' allegations as true for the purposes of the demurrer. The appellate court found that the plaintiffs had stated a claim for breach of contract and that the defendants' affirmative defense of failure to exhaust contractual remedies could not be resolved at the demurrer stage. The court also determined that the plaintiffs' contract claim was not time-barred. Consequently, the appellate court affirmed the trial court's decision in part and reversed it in part, allowing the breach of contract claim to proceed. View "Bath v. State" on Justia Law

A nonprofit organization challenged the County of Los Angeles's approval of a residential housing development project in the Santa Clarita Valley. The project included a conditional use permit, an oak tree permit, and a vesting tentative tract map. The organization alleged that the County violated the California Environmental Quality Act (CEQA) by failing to adequately analyze and disclose the project's environmental impacts and by not providing proper procedural notices. They also claimed violations of the Subdivision Map Act (SMA) and local zoning laws.The Los Angeles County Superior Court granted the developer's motion for judgment on the pleadings, finding that the organization's claims were barred by the 90-day limitations period under Government Code section 66499.37 of the SMA. The court ruled that the organization failed to serve a summons within 90 days of the County's approval of the vesting tentative tract map, which was required for any action challenging a subdivision decision.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that section 66499.37 of the SMA did not bar the organization's CEQA claims to the extent they alleged procedural violations and failures to analyze and disclose environmental impacts, as these claims were unique to CEQA and could not have been brought under the SMA. However, the court found that the CEQA claims challenging the adequacy of mitigation measures imposed as conditions of the project's approval were barred by the SMA's 90-day limitations period. The court reversed the trial court's judgment and remanded the case, directing the trial court to deny the motion for judgment on the pleadings regarding the CEQA cause of action and grant it concerning the SMA and zoning law violations. View "Santa Clarita Organization for Planning v. County of L.A." on Justia Law

The case involves the People of the State of California, represented by the San Diego City Attorney, who filed a complaint against Kaiser Foundation Health Plan, Inc. The complaint alleged that Kaiser violated the unfair competition law (UCL) and false advertising law (FAL) by failing to maintain and update accurate health plan provider directories (PDs) as required by California Health and Safety Code section 1367.27. The People claimed that Kaiser’s inaccuracies in PDs misled consumers and harmed competitors.The Superior Court of San Diego County granted Kaiser’s motion for summary judgment, exercising its discretion to abstain from adjudicating the action. The court reasoned that the legislative framework did not impose an accuracy requirement but rather outlined procedural steps for maintaining PDs. The court concluded that adjudicating the People’s claims would require it to assume regulatory functions and interfere with policy judgments already made by the Legislature and the Department of Managed Health Care (DMHC).The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case and concluded that the trial court abused its discretion by applying the doctrine of judicial abstention. The appellate court found that section 1367.27 sets forth clear mandates for PD accuracy, which the trial court could enforce through its ordinary judicial functions. The appellate court held that the People’s enforcement of these statutory requirements would not interfere with the DMHC’s regulatory functions and that the trial court’s abstention was based on a mistaken view of the law. Consequently, the appellate court reversed the judgment and remanded the matter with directions to deny Kaiser’s motion for summary judgment. View "P. ex rel. Elliott v. Kaiser Foundation Health Plan" on Justia Law

A company, A.D. Improvements, Inc. (ADI), leased property from the California Department of Transportation (Caltrans). Caltrans had initially acquired the property, which was undeveloped at the time, for a freeway project. ADI used the property commercially as a staging area for equipment and machinery. In 2021, Caltrans deemed the property "excess real property" as it was no longer needed for the freeway project. ADI sought to purchase the property under Streets and Highways Code section 118.1, which requires Caltrans to offer to sell excess commercial property to the current occupant. Caltrans denied the application, arguing the property was not commercial when acquired.The Superior Court of San Bernardino County agreed with Caltrans, interpreting the statute to mean that the property had to be commercial at the time of acquisition. The court denied ADI's petition for a writ of mandate to compel Caltrans to offer the property for sale.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The appellate court found that the statute's plain language and legislative history indicated that the property only needed to be commercial at the time it was deemed excess, not when it was acquired. The court concluded that the trial court had erred in its interpretation of the statute.The appellate court reversed the trial court's decision and remanded the case with directions to issue a writ requiring Caltrans to offer the property for sale to ADI at fair market value. The court held that Caltrans must comply with its ministerial duty under section 118.1 to sell the excess commercial property to the current occupant. ADI was awarded its costs on appeal. View "A.D. Improvements v. Dept. of Transportation" on Justia Law

In 2008, Juan Alazar was charged with attempted murder, assault with a firearm, and possession of a firearm by a felon. The charges included allegations of premeditation and personal use of a firearm causing great bodily injury. At a preliminary hearing, a witness testified that Alazar shot at a new tenant, Rutilio Navarro Hernandez, hitting him in the arm. Alazar pleaded no contest to attempted murder and admitted to personally and intentionally discharging a firearm in exchange for a 29-year sentence, with other charges dismissed. His counsel stipulated that the preliminary hearing transcript contained a factual basis for the plea.The trial court denied Alazar's petition for resentencing under section 1172.6, which allows for resentencing if a conviction was based on the natural and probable consequences doctrine. The court found that Alazar was the sole perpetrator and thus ineligible for relief. Alazar argued that the court improperly engaged in judicial factfinding at the prima facie stage.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court held that the trial court erred in its prima facie determination. The appellate court found that the record did not conclusively establish that Alazar harbored the intent to kill, as required under the current versions of sections 188 and 189. The court noted that Alazar's West plea allowed him to maintain his innocence while accepting a plea bargain, and his stipulation to the preliminary hearing transcript did not equate to an admission of the facts therein.The appellate court reversed the trial court's order and remanded the case for an evidentiary hearing to determine whether to vacate Alazar's attempted murder conviction, recall his sentence, and resentence him. The court emphasized that it expressed no opinion on the merits of the resentencing petition. View "P. v. Alazar" on Justia Law

In November 2014, the plaintiff purchased a recreational vehicle (RV) from a dealership, with the defendant bank financing the purchase. The sales contract inaccurately reflected the downpayment as $19,100 in cash instead of $1,000 in cash and $18,100 in trade-in value. The plaintiff later discovered issues with the RV and filed a lawsuit in February 2017, alleging violations of the Automobile Sales Finance Act (ASFA) due to the incorrect downpayment disclosure.The Superior Court of Fresno County reviewed the case and concluded that the four-year statute of limitations for written contracts applied, rather than the one-year statute for statutory penalties. The court granted summary adjudication in favor of the plaintiff against the dealership for violating the ASFA, and the dealership's liability was extended to the bank under the Federal Trade Commission’s holder rule. The court entered judgment requiring the bank to accept the return of the RV and pay the plaintiff $42,263.64.The California Court of Appeal, Fifth Appellate District, reviewed the case and determined that the rescission and restitution remedy under the ASFA is a penalty. The court concluded that the one-year statute of limitations for actions upon a statute for a penalty or forfeiture applied. The court noted that the ASFA imposes strict liability without regard to actual damages or fault, and the legislative history indicated the remedy was intended as a penalty. Consequently, the appellate court reversed the trial court's decision and remanded the case for further proceedings consistent with its opinion. View "Pompey v. Bank of Stockton" on Justia Law

Dr. Laura Dean Head, a college professor, passed away in 2013, leaving behind her sisters, Della Hamlin and Helaine Head. Shortly before her death, Dr. Head executed a trust naming her former student and friend, Zakiya Jendayi, as the trustee and sole beneficiary. In 2020, Hamlin and Head petitioned the probate court to invalidate the trust, alleging undue influence, lack of capacity, and forgery. After a 17-day bench trial, the court found that Jendayi had exerted undue influence over Dr. Head and invalidated the trust.The probate court determined that Hamlin and Head, as intestate heirs disinherited by the trust, had standing to contest the trust. The court applied the common law presumption of undue influence, finding that Jendayi had a confidential relationship with Dr. Head, actively participated in procuring the trust, and would unduly benefit from it. The court also found substantial evidence supporting the presumption of undue influence and rejected Jendayi’s claims of judicial bias. The court concluded that any deficiencies in its statement of decision were harmless and affirmed the judgment.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court affirmed the probate court’s judgment, holding that Hamlin and Head had standing to contest the trust. The appellate court found substantial evidence supporting the probate court’s application of the presumption of undue influence and its finding of undue influence. The court also concluded that the probate court did not demonstrate judicial bias and that any deficiencies in the statement of decision were harmless. The judgment was affirmed. View "Hamlin v. Jendayi" on Justia Law