Justia Government & Administrative Law Opinion Summaries

Articles Posted in Supreme Court of California
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The Supreme Court of California reviewed a case involving the University of California, Berkeley's (UC Berkeley) plan to build a housing project on a site called People's Park. The plaintiffs, Make UC a Good Neighbor and People’s Park Historic District Advocacy Group, challenged the certification of an environmental impact report (EIR) for the project, arguing that it failed to consider the environmental impacts of "student-generated noise" and did not adequately consider alternatives to the People’s Park location. The Court of Appeal agreed with the plaintiffs.The Supreme Court of California granted review of the Court of Appeal’s decision. During the review, the Legislature passed Assembly Bill No. 1307, which added sections to the Public Resources Code stating that noise generated by project occupants and their guests is not a significant environmental effect for residential projects, and that public higher education institutions are not required to consider alternatives to the location of a proposed residential or mixed-use housing project if certain requirements are met. The plaintiffs conceded that this new law applied to the case and made clear that the EIR was not required to examine "social noise" or potential alternative locations to People’s Park.The Supreme Court of California concluded that none of the plaintiffs' claims had merit in light of the new law. The court held that the new law applied to both the People’s Park housing project and the development plan, and the EIR was not inadequate for having failed to study the potential noisiness of future students at UC Berkeley in connection with this project. The court declined to consider the plaintiffs' alternative locations argument with respect to potential future housing projects. The court reversed the Court of Appeal’s judgment. View "Make UC a Good Neighbor v. The Regents of the University of California" on Justia Law

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A group of non-convicted individuals detained at the Santa Rita Jail in Alameda County, California, filed a lawsuit against the county and a private contractor, Aramark Correctional Services, LLC. The detainees were working in the jail's kitchen, preparing meals for the jail population and staff under an agreement between the county and Aramark. They were not paid for their labor. The detainees sued for failure to pay minimum wage and overtime.The case was initially heard in a federal district court, which granted in part and denied in part the defendants' motions to dismiss. The court reasoned that while the Penal Code addresses employment and wages of state prisoners, it does not address such matters for pretrial detainees confined in county jails. The court also agreed with the County that government entities are exempt from state overtime laws and therefore granted the County's motion to dismiss the claim for overtime wages. The district court certified for interlocutory appeal the legal question of pretrial detainees’ entitlement to minimum and overtime wages.The Supreme Court of California was asked by the United States Court of Appeals for the Ninth Circuit to decide whether non-convicted incarcerated individuals working in a county jail for a private company have a claim for minimum wage and overtime under California law. The Supreme Court of California concluded that non-convicted incarcerated individuals performing services in county jails for a for-profit company do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code, even in the absence of a local ordinance prescribing or prohibiting the payment of wages for these individuals. View "Ruelas v. County of Alameda" on Justia Law

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In this case, the Supreme Court of California was asked to interpret the "collective engagement" requirement under the California Penal Code section 186.22(f) and its application to the proof of predicate offenses. This requirement was introduced through Assembly Bill 333, which amended gang sentencing provisions. The defendant, Kejuan Darcell Clark, a member of the Northside Parkland street gang, was charged with several offenses related to a home invasion and assault. The prosecution sought to apply gang enhancements under section 186.22, subdivision (b).The court held that the term "collective engagement" in section 186.22(f) does not require that each predicate offense must have been committed by at least two gang members acting in concert. Rather, the court interpreted the term to require a showing that links the two predicate offenses to the gang as an organized, collective enterprise. This can be demonstrated by evidence linking the predicate offenses to the gang's organizational structure, its primary activities, or its common goals and principles.The court reversed the judgment of the Court of Appeal as to Clark's gang enhancement and remanded the case for further proceedings to apply this interpretation of the collective engagement requirement. View "P. v. Clark" on Justia Law

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A person identified as O.R. appealed the decision of the Los Angeles County Superior Court to place his child, N.R., under the jurisdiction of the Los Angeles County Department of Children and Family Services (the Department) based on allegations of substance abuse. The Supreme Court of California reviewed two issues concerning the interpretation of the Welfare and Institutions Code section 300, subdivision (b)(1)(D), which allows for jurisdiction over a child in cases where the parent’s substance abuse results in an inability to provide regular care for the child and causes or could cause the child serious physical harm or illness.First, the court clarified the term “substance abuse” as used in the statute. It rejected O.R.’s argument that “substance abuse” must be shown through a medical diagnosis or by meeting the criteria for a substance use disorder as outlined in the Diagnostic and Statistical Manual of Mental Disorders (DSM). The court held that “substance abuse” in this context should be given its ordinary meaning, which refers to the excessive use of drugs or alcohol. The court cautioned that to establish dependency jurisdiction, the abuse must render the parent unable to provide regular care for the child and either cause the child serious physical harm or illness, or place the child at substantial risk of such harm or illness.Second, the court rejected the so-called “tender years presumption,” which holds that substance abuse by a parent is prima facie evidence of an inability to provide regular care and a substantial risk of serious physical harm when the child is very young. The court held that this presumption is not supported by the language of the statute or the legislative intent, and improperly simplifies the analysis required under section 300(b)(1)(D). Instead, the court held that the government must establish each element of the statute separately, without shifting the burden to the parent to rebut a presumption created by a finding of substance abuse.The court reversed the decision of the Court of Appeal and remanded the case for further proceedings consistent with its opinion. View "In re N.R." on Justia Law

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The Supreme Court held, in response to a request by the United States Court of Appeals for the Ninth Circuit, that Cal. Publ. Util. Code 1759 bars a lawsuit that seeks damages resulting from public safety power shutoffs (PSPS) events where the suit alleges that a utility's negligence in maintaining its grid necessitated shutoffs but does not allege that the shutoffs were unnecessary or violated the regulations of the California Public Utilities Commission (PUC).To reduce the risk that its utility infrastructure would ignite a wildfire during extreme weather conditions Pacific Gas and Electric Company (PG&E) conducted a series of emergency power shutoffs that Plaintiff alleged were necessitated by PG&E's negligence in maintaining its power grid. Plaintiff filed a class action complaint against PG&E requesting class damages of $2.5 billion. At issue before the Supreme Court was whether section 1759 barred this lawsuit. The Supreme Court answered the question in the positive, holding that allowing suit under the circumstances here would interfere with the PUC's comprehensive regulatory and supervisory authority over PSPS. View "Gantner v. PG&E Corp." on Justia Law

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The Supreme Court held that under California's Motor Carriers of Property Permit Act, Cal. Veh. Code 34600 et seq., a commercial automobile insurance policy does not continue in full force and effect until the insurer cancels a corresponding certificate of insurance on file with the Department of Motor Vehicles (DMV).Insured was driving a truck covered by his policy with Insurer when he collided with a car, killing its driver. The driver's parents sued Insured for wrongful death, and Insured tendered his defense to Insurer. Insurer settled the claim for its policy limits and then sued Insured's former insurer (Defendant) for declaratory relief, equitable contribution, and equitable subrogation. The trial court held that Defendant's policy remained in effect on the date of the collision because one of Defendant's cancellation notices was rejected by the DMV as incomplete. The Court of Appeals for the Ninth Circuit certified a question of law to the Supreme Court, which answered that the Act does not require a commercial auto insurance policy to remain in effective indefinitely until the insurer cancels the certificate of insurance on file with the DMV. View "Allied Premier Insurance v. United Financial Casualty Co." on Justia Law

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The Supreme Court held that a claim for reimbursement of emergency medical services may be maintained against a health care service plan when the plan is operated by a public entity and that the Government Claims Act, Cal. Gov. Code 810 et seq., did not immunize the County of Santa Clara from such a claim in this case.Two hospitals submitted reimbursement claims for the emergency medical services they provided to three individuals enrolled in a County-operated health care service plan. The hospitals sued for the remaining amounts based on the reimbursement provision of the Knox-Keene Act, and the trial court concluded that the hospitals could state a quantum merit claim against the County. The court of appeal reversed, determining that the County was immune from suit under the Government Claims Act. The Supreme Court reversed, holding that the County was not immune from suit under the circumstances of this case and that the hospitals' claims may proceed. View "County of Santa Clara v. Superior Court" on Justia Law

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The Supreme Court reversed the judgment of the court of appeal affirming an award of attorney's fees under Cal. Gov. Code 91003(a) to a prevailing defendant, holding that a prevailing defendant under the Political Reform Act "should not be awarded fees and costs unless the court finds the action was objectively without foundation when brought, or the plaintiff continued to litigate after it clearly became so."Plaintiffs, two residents of the City of Redondo Beach, sought injunctive relief against certain supporters of a local initiative to compel their compliance with the Political Reform Act. The trial court ruled in favor of Defendants on all claims and awarded Defendants costs and attorney's fees as prevailing parties under 91003(a). The court of appeal affirmed the award of attorney's fees, holding that the statute grants trial courts discretion to award attorney's fees and costs to either a plaintiff or a defendant who prevailed. The Supreme Court reversed, holding that section 91003(a) imposes an asymmetrical standard, which constrains the trial court's discretion to award a prevailing defendant attorney's fees. View "Travis v. Brand" on Justia Law

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The Supreme Court reversed the decision of the court of appeal affirming the judgment of the probate court denying Petitioner's petition to issue the predicate findings he needed to support an application to the federal government for special immigrant juvenile (SIJ) status, holding that the probate court applied an incorrect legal framework in ruling on Petitioner's petition.Petitioner, who left his native El Salvador at the age of sixteen to escape gang violence, filed an SIJ petition the day after he turned eighteen. The probate court denied the petition, and the court of appeal affirmed. The Supreme Court reversed and remanded with direction that the case be remanded to the probate court for issuance of SIJ predicate findings, holding that returning Petitioner to live in El Salvador would be detrimental to his best interest under California law. View "In re Guardianship of Saul H." on Justia Law

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In this lawsuit challenging the sufficiency of an environmental impact report (EIR) prepared by California's Department of Water Resources (DWR) the Supreme Court affirmed in part and reversed in part the decision of the court of appeal finding that the claims brought by Butte and Plumas Counties under the California Environmental Quality Act (CEQA), Cal. Pub. Res. Code 21000 et seq., were preempted, holding that the court of appeal erred in part.The Counties brought a challenge to the environmental sufficiency of a settlement DWR prepared as part of the Federal Energy Regulatory Commission (FERC) proceedings, 16 U.S.C. 817(1), and to the sufficiency of the EIR more generally. The court of appeals found that the action was preempted by the Federal Power Act, 16 U.S.C. 791a et seq. The Supreme Court reversed in part, holding (1) the Counties' claims were preempted to the extent they attempted to unwind the terms of a settlement agreement reached through a federal process and sought to enjoin DWR from operating certain facilities; but (2) the court of appeals erred in finding the Counties' CEQA claims entirely preempted. View "County of Butte v. Dep't of Water Resources" on Justia Law