Justia Government & Administrative Law Opinion Summaries

Michael Ayala, a correctional officer for California’s Department of Corrections and Rehabilitation (CDCR), was injured in a planned attack by inmates. He filed a workers’ compensation claim, asserting that his injuries were due to CDCR’s serious and willful misconduct in failing to address a credible threat of inmate violence. A workers’ compensation administrative law judge (WCJ) initially rejected this claim, but the Workers’ Compensation Appeals Board (Board) found in favor of Ayala, concluding that he was entitled to a 50 percent increase in compensation under Labor Code section 4553 due to CDCR’s serious and willful misconduct.The CDCR did not dispute the finding of serious and willful misconduct but argued that the 50 percent increase should be calculated based on the temporary disability (TD) benefits Ayala would have received under the workers’ compensation law, not the more generous industrial disability leave (IDL) and enhanced industrial disability leave (EIDL) benefits he received under the Government Code. The WCJ agreed with CDCR, but the Board reversed, including IDL and EIDL benefits in the calculation of the increased compensation.The California Supreme Court reviewed the case and agreed with the Court of Appeal, which had reversed the Board’s decision. The Supreme Court held that the term “compensation” under Labor Code section 4553, as defined in section 3207, is limited to benefits provided under the workers’ compensation law. Therefore, the 50 percent increase in compensation for serious and willful misconduct should be calculated based on the TD benefits Ayala was entitled to under the workers’ compensation law, not the IDL and EIDL benefits provided under the Government Code. The judgment of the Court of Appeal was affirmed. View "Dept. of Corrections & Rehabilitation v. Workers' Comp. Appeals Bd." on Justia Law

Victor Raul Tellez was charged with three counts of lewd or lascivious acts upon a child and faced a maximum prison term of 12 years. On the advice of his attorney, he accepted a plea deal, pleading guilty to one count and receiving a three-year prison sentence. Tellez was not informed that his conviction would make him eligible for civil commitment as a sexually violent predator (SVP) under the Sexually Violent Predator Act (SVPA). After completing his prison term, the District Attorney initiated SVPA proceedings for his involuntary commitment to a state hospital.Tellez filed a petition for writ of habeas corpus in the San Diego County Superior Court, claiming ineffective assistance of counsel for not being advised of the SVPA consequences. The superior court denied his petition, and the Court of Appeal also denied it, stating that prevailing norms did not require such advisement and that Tellez had not demonstrated prejudice. Tellez then petitioned the California Supreme Court for review.The California Supreme Court held that Tellez did not sufficiently demonstrate he was prejudiced by his counsel’s failure to advise him of the SVPA consequences. The court noted that Tellez provided insufficient evidence that he would not have accepted the plea deal had he been informed of the SVPA consequences. Therefore, the court did not address whether his counsel’s performance was constitutionally deficient. However, recognizing the significant liberty deprivation involved in SVPA commitments, the court exercised its supervisory powers to require trial courts to inform defendants of potential SVPA consequences when pleading guilty or no contest to a qualifying offense. The judgment of the Court of Appeal was affirmed on the ground that Tellez had not demonstrated prejudice. View "In re Tellez" on Justia Law

David Meinhardt, a police officer, was suspended for 44 hours by the City of Sunnyvale Department of Public Safety, a decision upheld by the City of Sunnyvale Personnel Board. Meinhardt filed a petition for a writ of administrative mandate in the Santa Clara County Superior Court, challenging the suspension. On August 6, 2020, the court issued an order denying the petition. The City served Meinhardt with a notice of entry of this order on August 14, 2020. Subsequently, on September 25, 2020, the court entered a formal judgment, which Meinhardt served on the City on September 22, 2020.The Fourth Appellate District, Division One, dismissed Meinhardt's appeal as untimely, holding that the August 6 order was the final judgment from which the appeal should have been taken. The court reasoned that the order was sufficiently final to constitute the judgment, thus starting the 60-day period for filing an appeal.The Supreme Court of California reviewed the case to resolve the issue of when the time to appeal begins in administrative mandate proceedings. The court held that the time to appeal starts with the entry of a formal judgment or the service of notice of entry of judgment, not with the filing of an order or other ruling. The court emphasized the importance of clear, bright-line rules to avoid confusion and ensure that parties do not inadvertently forfeit their right to appeal. Consequently, the Supreme Court reversed the judgment of the Court of Appeal, finding that Meinhardt's appeal, filed within 60 days of the entry of the formal judgment, was timely. View "Meinhardt v. City of Sunnyvale" on Justia Law

Plaintiffs, employees of a hospital operated by Alameda Health System (AHS), alleged that AHS violated California labor laws by denying meal and rest breaks, failing to keep accurate payroll records, and not paying full wages. They sought civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA).The Alameda County Superior Court sustained AHS’s demurrer without leave to amend, concluding that AHS, as a public entity, was not subject to the Labor Code provisions cited by plaintiffs. The court also dismissed the PAGA claim, reasoning that public entities are not “persons” subject to PAGA penalties.The California Court of Appeal reversed in part, holding that AHS was not exempt from the meal and rest break requirements or the wage payment statutes. It distinguished AHS from state agencies, noting that the enabling statute indicated AHS was not an agency, division, or department of the county. However, the court agreed that AHS was exempt from the wage statement requirements and that it was not a “person” subject to default PAGA penalties.The California Supreme Court reversed the Court of Appeal’s judgment. It held that the Legislature intended to exempt public employers, including hospital authorities like AHS, from the Labor Code provisions governing meal and rest breaks and related wage payment statutes. The Court also concluded that public entities are not subject to PAGA penalties for the violations alleged. The case was remanded to the trial court to reinstate its ruling on the demurrer and conduct any further proceedings as appropriate. View "Stone v. Alameda Health System" on Justia Law

The case involves Business and Professions Code section 7451, enacted through Proposition 22, which classifies app-based drivers for companies like Uber, Lyft, and DoorDash as independent contractors rather than employees, provided certain conditions are met. This classification exempts these drivers from California workers’ compensation laws, which typically apply to employees. Plaintiffs, including several individuals and unions, argue that section 7451 conflicts with article XIV, section 4 of the California Constitution, which grants the Legislature plenary power to create and enforce a complete system of workers’ compensation.The Alameda County Superior Court found Proposition 22 unconstitutional, reasoning that it improperly limited the Legislature’s power to govern workers’ compensation, a power deemed "unlimited" by the state Constitution. The court held that the people must amend the Constitution through an initiative constitutional amendment, not an initiative statute, to impose such limitations. Consequently, the court invalidated Proposition 22 in its entirety.The California Court of Appeal reversed the lower court’s decision, holding that article XIV, section 4 does not preclude the electorate from using its initiative power to legislate on workers’ compensation matters. The court reasoned that the Legislature’s power under article XIV, section 4 is not exclusive and that Proposition 22 does not conflict with this constitutional provision. The court did, however, affirm the invalidation of certain severable provisions of Proposition 22 not at issue in this appeal.The California Supreme Court affirmed the Court of Appeal’s judgment, agreeing that section 7451 does not conflict with article XIV, section 4. The court held that the Legislature’s plenary power under article XIV, section 4 is not exclusive and does not preclude the electorate from enacting legislation through the initiative process. The court did not address whether other provisions of Proposition 22 improperly constrain the Legislature’s authority, as those issues were not presented in this case. View "Castellanos v. State of California" on Justia Law

This case involves five large water utilities and an association representing investor-owned water utilities' interests, collectively referred to as the Water Companies. The Water Companies sought to overturn an order by the Public Utilities Commission (Commission) that eliminated a conservation-focused ratesetting mechanism known as the Water Revenue Adjustment Mechanism (WRAM). The WRAM was designed to encourage water conservation by decoupling a water company's revenue from the amount of water sold. The Commission's order to eliminate the WRAM was not based on the merits of the mechanism but on procedural issues.The Commission's decision to eliminate the WRAM was made in a proceeding that was ostensibly focused on improving the accuracy of water sales forecasts. The Water Companies argued that the Commission did not provide adequate notice that the elimination of the WRAM was one of the issues to be considered in the proceeding.The Supreme Court of California agreed with the Water Companies. The court found that the Commission's scoping memos, which are supposed to outline the issues to be considered in a proceeding, did not provide adequate notice that the WRAM's elimination was on the table. The court concluded that the Commission's failure to give adequate notice required the order to be set aside. The court did not rule on the merits of the WRAM itself. View "Golden State Water Co. v. Public Utilities Com." on Justia Law

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

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

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

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