David Eagleson

The case involved whether a homeowner's insurance policy covered damages awarded against a man who sexually molested a five-year-old girl on multiple occasions. The insurer sought declaratory relief that it had no duty to indemnify under the policy's exclusion for intentional acts and Insurance Code section 533. The California Supreme Court held that the insurer was not required to pay the judgment because section 533 precludes coverage for willful acts, and the sexual molestation of a child is willful as a matter of law regardless of the molester's claimed intent not to harm the child. The court reasoned that the insured's admissions and the nature of the acts established intentional misconduct, consistent with precedents from this and other states.

criminal lawtorts & liability

The case involved Hydrotech, a New York corporation without a California contractor's license, which contracted to design and build a wave pool in California for Oasis Waterpark and later sued for unpaid retainage amounts plus fraud after the project was completed. The trial court dismissed most claims on demurrer for failure to allege proper licensing under Business and Professions Code section 7031, and the Court of Appeal affirmed in part while allowing the fraud claim to proceed. The Supreme Court of California held that section 7031 strictly bars recovery of compensation for unlicensed contracting work with no exceptions for isolated transactions, nonresidents, or exceptional circumstances, and that the statute also precludes a fraud claim where the alleged deceit is a false promise to pay and damages are measured by the value of the work performed. The court's reasoning centered on the legislative intent to deter unlicensed contractors by denying them access to courts for compensation, regardless of the form of the action or equitable considerations.

business & regulatorytorts & liability

The case involved a challenge to Measure H, a voter initiative adopted by the City of Walnut Creek that imposed a building moratorium triggered when traffic volume-to-capacity ratios on specified roads exceeded 0.85. Plaintiffs argued that the measure was invalid as a zoning ordinance inconsistent with the city's existing general plan, which was growth-oriented and anticipated increased development and congestion. The California Supreme Court held that Measure H did not amend the general plan and was therefore invalid under the state Planning and Zoning Law, which requires all zoning ordinances to be consistent with the adopted general plan. The court affirmed the trial court's issuance of a writ directing the city to cease enforcing the measure.

business & regulatoryenvironment

The case involved defendant Bronte Lament Wright, who was convicted of first-degree murder, rape, attempted robbery, and burglary of 76-year-old Patricia Hunter, along with related enhancements and three special circumstances that made the murder eligible for the death penalty. The jury imposed a death sentence, which the California Supreme Court initially affirmed as to guilt but reversed as to penalty before granting rehearing. On rehearing, the court affirmed the judgment in full, concluding that the evidence—including the defendant's confession, palm prints at the scene, witness identifications, and prior criminal history—supported the convictions and special circumstances, and that any errors in the admission of penalty-phase evidence or jury instructions were not prejudicial.

criminal lawprocedure

In Curl v. Superior Court, the defendant faced a capital murder charge with a prior-murder special circumstance based on a 1977 guilty plea; he sought to strike that allegation pretrial by collaterally attacking the prior conviction as involuntary due to drug influence and inadequate Boykin-Tahl advisements. The California Supreme Court held that such a challenge is permitted via a pretrial motion to strike, triggering an evidentiary hearing under the procedures from People v. Coffey and People v. Sumstine. The court further ruled that the defendant bears the burden of proving the prior conviction's constitutional invalidity by a preponderance of the evidence, and that the trial court properly denied the motion here because the available testimony and records supported the plea’s validity. This outcome rested on the statutory scheme for special circumstances and the allocation of proof in collateral attacks on priors.

criminal lawprocedure

The case involved Jesse Edward Gonzalez, who was convicted of first-degree murder of a deputy sheriff and assault on another officer during the execution of a search warrant at his residence, where he used a shotgun. The jury found a special circumstance that he intentionally killed a peace officer in the performance of duty, leading to a death sentence after penalty phase proceedings. The California Supreme Court affirmed the guilt and penalty judgments, denied the defendant's habeas corpus petition, and granted the People's petition for a writ of mandate to overturn a postjudgment discovery order related to informant testimony.

criminal lawprocedure