Justia California Court of Appeals Opinion Summaries

The case involves a challenge to the adequacy of an Environmental Impact Report (EIR) prepared for a project proposing significant changes to the California State Capitol. The Department of General Services (DGS) and the Joint Committee on Rules of the California State Senate and Assembly (Joint Rules Committee) prepared both an EIR and a revised EIR under the California Environmental Quality Act (CEQA). The project includes demolishing the existing Capitol Annex, constructing a new attached Annex, building an underground visitor center, and constructing a new underground parking garage.The Superior Court of Sacramento County initially rejected challenges to the EIR brought by Save Our Capitol! and Save the Capitol, Save the Trees. On appeal, the Court of Appeal found certain aspects of the EIR flawed and remanded the case. After DGS revised the EIR and reapproved the project without the visitor center, the trial court discharged the writ. Save the Capitol, Save the Trees appealed, arguing the trial court prematurely discharged the writ. The Court of Appeal agreed and reversed the trial court's decision. Save Our Capitol! then filed a new petition challenging the revised EIR, which the trial court also rejected.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court's decision. The court held that recent legislation, Senate Bill No. 174, exempts the Capitol Annex Project from CEQA’s requirements. The court found that Senate Bill 174, which took effect immediately, dictates that all work performed under the Annex Act is exempt from CEQA. Consequently, Save Our Capitol!'s claims that DGS violated CEQA were rejected. The court also addressed and dismissed Save Our Capitol!'s argument that Senate Bill 174 is unconstitutional under article IV, section 28 of the California Constitution, finding that the bill explicitly bars funds from being used inconsistent with this constitutional provision. View "Save Our Capitol! v. Dept. of General Services" on Justia Law

Kenneth and Janet Lathrop purchased a motorhome from a dealer in California, manufactured by Thor Motor Coach, Inc. They later sued the dealer and Thor under the Song-Beverly Consumers Warranty Act and the Consumer Legal Remedies Act (CLRA), alleging defects in the motorhome and failure to perform necessary repairs. Thor moved to stay the action based on a forum selection clause in its warranty, which designated Indiana as the exclusive forum for disputes and included a jury trial waiver and an Indiana choice-of-law clause. Thor acknowledged these provisions were unenforceable under California law and offered to stipulate that California substantive rights would apply in an Indiana court.The Superior Court of Los Angeles County granted Thor’s motion to stay, finding the forum selection clause mandatory and not unreasonable. The court placed the burden on the Lathrops to show that enforcing the clause was unreasonable. The Lathrops appealed, arguing that the trial court applied the wrong standard and that Thor did not meet its burden to show that litigating in Indiana would not diminish their unwaivable rights under California law.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case and concluded that the trial court erred by placing the burden on the Lathrops instead of Thor. The appellate court held that Thor did not meet its burden to show that litigating in Indiana would not substantially diminish the Lathrops’ rights under the Song-Beverly Act and the CLRA. The court also found that enforcing the forum selection clause based on Thor’s proposed stipulation would violate California public policy and that the stipulation was insufficient to protect the Lathrops’ unwaivable statutory rights. Consequently, the appellate court reversed the trial court’s order granting the motion to stay and directed the trial court to deny the motion. View "Lathrop v. Thor Motor Coach, Inc." on Justia Law

A former employee, Liu, sued her employer, Miniso, alleging various employment-related claims, including sexual harassment, sex discrimination, and wage and hour violations. Liu claimed that she faced severe and pervasive harassment and discrimination based on her sexual orientation and gender identity, and that she was misclassified as an exempt employee, leading to unpaid wages and denied breaks. Liu also alleged that she was retaliated against for refusing to participate in illegal practices and for whistleblowing, which led to her constructive termination.The Superior Court of Los Angeles County denied Miniso's motion to compel arbitration of Liu's claims. Miniso argued that Liu's allegations of sexual harassment were insufficient to state a claim and that the arbitration agreement should be enforced for the non-sexual harassment claims. The trial court found that Liu had adequately stated a claim for sexual harassment and, based on the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), ruled that the arbitration agreement was unenforceable for all of Liu's claims.The California Court of Appeal, Second Appellate District, affirmed the trial court's decision. The appellate court held that under the EFAA, if a plaintiff's case includes at least one claim of sexual harassment, the entire case is exempt from arbitration at the plaintiff's election. The court emphasized that the EFAA's language invalidates arbitration agreements with respect to the entire case, not just the sexual harassment claims. This interpretation avoids the inefficiency of having separate proceedings for different claims and aligns with the legislative intent to protect plaintiffs from being compelled into arbitration for sexual harassment disputes. View "Liu v. Miniso Depot CA, Inc." on Justia Law

Plaintiffs, who are users of Coinbase's cryptocurrency platform, filed a complaint against Coinbase, Inc. alleging violations of the Consumer Legal Remedies Act (CLRA), the California False Advertising Law (FAL), and the California Unfair Competition Law (UCL). They sought public injunctive relief, claiming Coinbase misrepresented its security features to the public. Coinbase's user agreement, which plaintiffs accepted, included an arbitration clause. Coinbase moved to compel arbitration, arguing the plaintiffs sought private injunctive relief, which is subject to arbitration.The San Francisco Superior Court denied Coinbase’s motion to compel arbitration, finding that the plaintiffs sought public injunctive relief, which is not subject to arbitration under California law. The court noted that the complaint exclusively sought public injunctive relief and did not request any relief that would solely benefit the plaintiffs or existing Coinbase customers. The court also referenced a related federal case, Aggarwal I, where plaintiffs sought individual relief, supporting the conclusion that the current complaint sought public injunctive relief.The California Court of Appeal, First Appellate District, reviewed the case de novo. The court affirmed the trial court’s decision, holding that the plaintiffs’ complaint indeed sought public injunctive relief. The court explained that public injunctive relief under the CLRA, FAL, and UCL is intended to prohibit unlawful acts that threaten future injury to the public, rather than redress individual wrongs. The court found that the plaintiffs’ allegations and requests for relief were aimed at preventing Coinbase from continuing its allegedly deceptive practices, which primarily benefit the public. Consequently, the arbitration provision in Coinbase’s user agreement could not compel arbitration of the plaintiffs’ claims for public injunctive relief. View "Kramer v. Coinbase, Inc." on Justia Law

Romeo Deonte Knowles, a 23-year-old unhoused individual, attacked a security guard, William Bullock, at a homeless shelter. The altercation led to Bullock falling, hitting his head, and subsequently dying from blunt force trauma. Knowles claimed self-defense, citing intimidation by Bullock. He was charged with murder but later pleaded no contest to voluntary manslaughter.The Los Angeles County Superior Court received various reports and memoranda before sentencing. These included a mitigation packet detailing Knowles's traumatic childhood and mental health issues, a diagnostic report from the Department of Corrections and Rehabilitation, and sentencing memoranda from both the defense and prosecution. The defense argued for the low term of three years, citing Knowles's age, mental health, and lack of a criminal record. The prosecution recommended the midterm of six years, emphasizing Bullock's non-aggressive behavior and Knowles's failure to take full responsibility.The Superior Court sentenced Knowles to the midterm of six years, finding that the aggravating factors, such as the victim's vulnerability and Knowles's behavior while in custody, outweighed the mitigating factors. Knowles appealed, arguing that the court erred by not imposing the low term.The California Court of Appeal, Second Appellate District, reviewed the case and found no abuse of discretion by the lower court. The appellate court held that the trial court correctly understood the scope of its sentencing discretion and appropriately weighed the aggravating and mitigating factors. The judgment of conviction was affirmed. View "People v. Knowles" on Justia Law

A 17-year-old, M.L., challenged a civil harassment restraining order issued to protect E.G., a former romantic partner of M.L.’s mother. E.G. sought the order after M.L. posted E.G.’s personal information on social media, alleging E.G. supported M.L.’s mother in abusive conduct against M.L. and her younger brother. The restraining order prohibited M.L. from publishing E.G.’s contact information online and from defaming or harassing her. M.L. contended there was no clear and convincing evidence of harassment and argued that the trial court failed to consider circumstances making future harassment unlikely.The Santa Cruz County Superior Court issued a temporary restraining order and later a three-year civil harassment restraining order against M.L. The court found that M.L.’s social media posts, which included E.G.’s contact information and accusations of supporting child abuse, constituted harassment. The court concluded that E.G. had met her burden of proof by clear and convincing evidence and that the harassment was likely to continue without a restraining order.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found substantial evidence supporting the restraining order, including M.L.’s repeated social media posts and the resulting threats and harassment E.G. received from third parties. The court concluded that M.L.’s conduct was not for a legitimate purpose and was not constitutionally protected. However, the court modified the restraining order to expire on M.L.’s 18th birthday, reasoning that the circumstances leading to the harassment were tied to M.L.’s status as a minor and her parents' custody dispute. The order was affirmed as modified. View "E.G. v. M.L." on Justia Law

The defendant was convicted of 20 counts of aggravated sexual assault, rape, sexual penetration, and oral copulation of unconscious or intoxicated persons involving four different victims. The crimes occurred after the defendant provided the victims with alcoholic beverages, rendering them intoxicated and unconscious. The jury found the defendant guilty of multiple offenses against each victim, including aggravated sexual assault, rape of an unconscious person, and rape of an intoxicated person.The Superior Court of San Diego County initially sentenced the defendant to 40 years in prison, including several upper-term sentences based on aggravating factors not admitted by the defendant or found true by a jury. The Court of Appeal vacated the sentence and remanded for resentencing under new sentencing reforms, Assembly Bill 518 and Senate Bill 567, which affected the court's discretion under Penal Code sections 654 and 1170, respectively. At resentencing, the trial court imposed mandatory full-term consecutive sentences for three counts of rape of an intoxicated person under Penal Code section 667.6(d) because they involved different victims. The court also imposed upper-term sentences based on the same fact that the crimes involved multiple victims, despite the defendant's objection to this dual use of facts.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case and held that the trial court erred by using the same fact (multiple victims) to impose both upper-term and mandatory consecutive sentences under section 667.6(d). The appellate court concluded that the dual use prohibition applies even when consecutive sentencing is mandatory. As a result, the court vacated the sentence and remanded for a full resentencing hearing on the record as it stands, without allowing the prosecution to seek a trial on aggravating factors. The judgment was affirmed in all other respects. View "People v. Dorado" on Justia Law

In the 1980s, Robert Edward Maury was convicted of multiple crimes, including three counts of first-degree murder and forcible rape. A jury sentenced him to death in 1989. The California Supreme Court affirmed his conviction and death sentence in 2003, and his initial state habeas corpus petition was denied in 2011. In 2021, Maury filed a second state habeas corpus petition, which the Shasta County Superior Court dismissed as procedurally barred. Maury appealed, focusing on a claim under McCoy v. Louisiana, arguing that his Sixth Amendment rights were violated when his counsel presented mitigating evidence against his wishes during the penalty phase.The Shasta County Superior Court dismissed Maury’s second habeas petition, finding it untimely and successive. The court did not address the merits of Maury’s McCoy claim, which argued that his counsel violated his Sixth Amendment rights by presenting mitigating evidence over his objection, thus conceding guilt. Maury also claimed that the trial court erred in denying his motions to represent himself during the penalty phase, which he argued forced him to proceed with counsel burdened by an irreconcilable conflict of interest.The California Court of Appeal, Third Appellate District, reviewed the case and found no McCoy error. The court concluded that Maury’s counsel did not concede guilt over his objection but instead presented mitigating evidence and argued for life without parole while maintaining Maury’s innocence. The court also found that any error in presenting a defense against Maury’s wishes was harmless, as Maury achieved his objective of obtaining a death verdict by personally addressing the jury. The court affirmed the trial court’s order denying Maury’s second habeas corpus petition, concluding that Maury failed to demonstrate prejudice or an actual conflict of interest that adversely affected his counsel’s performance. View "In re Maury" on Justia Law

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). The professor claimed that the university failed to engage in the interactive process and provide reasonable accommodations for his bipolar II disorder, and that it 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 the claims of failure to engage in the interactive process, failure to provide reasonable accommodations, and invasion of privacy. The court also denied the professor’s motion to compel responses to certain discovery requests and his request for a retrial on the cause of action for which the jury left the verdict form blank. The jury found in favor of the Regents on all other claims except for the personnel file cause of action, which the jury did not address due to the instructions on the verdict form.The California Court of Appeal, First Appellate District, Division Four, affirmed the trial court’s rulings on the claims of failure to engage in the interactive process and failure to provide reasonable accommodations, finding no prejudicial error. The court also upheld the trial court’s denial of the motion to compel discovery, agreeing that the requests were overly broad and protected by the reporter’s privilege. However, the appellate 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 information to the media. The court also reversed the trial court’s denial of attorney’s fees and costs, remanding for further proceedings consistent with its opinion. View "Wentworth v. UC Regents" on Justia Law

In 2022, Congress amended the Federal Arbitration Act (FAA) by passing the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA), which renders arbitration agreements unenforceable at the plaintiff’s election in sexual assault and sexual harassment cases arising on or after March 3, 2022. Jane Doe filed a lawsuit in 2023 against her employer, Second Street Corporation, and two supervisors, alleging sexual harassment, discrimination, and wage-and-hour violations. The defendants moved to compel arbitration based on an arbitration provision in the employee handbook. The trial court denied the motion, concluding that the EFAA rendered the arbitration provision unenforceable for all of Doe’s claims and allowed her to file a first amended complaint adding additional claims, including constructive wrongful termination.The Superior Court of Los Angeles County denied the defendants' motion to compel arbitration, finding that Doe’s sexual harassment claims, which included conduct both before and after the EFAA’s effective date, were exempt from mandatory arbitration. The court also ruled that all of Doe’s other claims were exempt from arbitration under the EFAA because they were part of the same case. Additionally, the court permitted Doe to file a first amended complaint.The California Court of Appeal, Second Appellate District, affirmed the trial court’s order. The appellate court held that under the EFAA’s plain language, Doe’s sexual harassment claims, which alleged continuing violations both before and after the EFAA’s effective date, were not subject to mandatory arbitration. The court also held that the EFAA invalidates an arbitration clause as to the entire case, not just the claims alleging sexual harassment. Therefore, the trial court properly denied the motion to compel arbitration and did not abuse its discretion by allowing Doe to file a first amended complaint. View "Doe v. Second Street Corp." on Justia Law