Frank C. Newman

The case concerned a 1981 California statute that expanded the state's Court of Appeal system by adding new divisions and judgeships across several districts, with section 6 directing that library and equipment costs for one new division come from existing resources, local funding, or donations rather than new state appropriations. Taxpayers sued, and a superior court judge issued a permanent injunction declaring the statute unconstitutional on separation-of-powers grounds under the California Constitution, ordering the Governor, Controller, and Administrative Director of the Courts to halt implementation. The Supreme Court granted mandate petitions to vacate the injunction, holding that the Legislature's authority under article VI, section 3 to create appellate districts and divisions was unchallenged and that the funding provisions did not materially impair judicial functions or violate separation of powers. The court further reasoned that the salary and appropriation provisions did not trigger a two-thirds vote requirement and that judicial review is limited to constitutional defects rather than policy concerns over legislative processes.

procedure

This case is part of the long-running Serrano litigation challenging California's public school financing system on equal protection grounds. After plaintiffs prevailed on the merits and obtained an initial fee award under the private-attorney-general statute (Code Civ. Proc., § 1021.5), the parties disputed whether that award could include compensation for the attorneys' time spent litigating the fee itself. The California Supreme Court held that, absent special circumstances making an award unjust, fees under section 1021.5 should compensate all hours reasonably expended, including time devoted solely to securing the fee award. The court affirmed the trial court's principal fee award but remanded for reconsideration of the portion that had denied compensation for services on the fee motions.

civil rightsprocedure

The case involved resident taxpayers in Butte County who sued local and state government entities, alleging improper allocation of Transportation Development Act funds to street and road projects without first determining unmet public transit needs for the elderly, disabled, and low-income residents. The parties reached a settlement under which defendants agreed to establish four transit systems in exchange for plaintiffs dismissing the action with prejudice, but the agreement was silent on costs and attorney fees. The court held that such a silent settlement does not bar the trial court from awarding costs under Code of Civil Procedure section 1032 or fees under section 1021.5, that fees may be awarded to publicly funded legal services organizations, and that a settling plaintiff may qualify as a 'successful party' if the lawsuit substantially contributed to remedying the targeted conditions. The reasoning centered on the statutory purposes of fee-shifting provisions in public interest cases and the principle that settlement agreements do not automatically merge or extinguish preexisting claims for fees and costs unless expressly addressed.

civil rightsprocedure

The case concerned an insurance company's refusal to hire or retain a sales agent whose elevated blood pressure posed no current impairment to job performance but was viewed by the employer as increasing future health risks, prompting a complaint under the Fair Employment Practice Act (Labor Code section 1420 et seq.). The Fair Employment and Housing Commission determined that high blood pressure qualified as a protected physical handicap and ordered reinstatement with back pay; the superior court upheld this ruling after applying the substantial-evidence standard of review. On appeal, the Supreme Court examined the statutory definition of physical handicap, which encompasses physiological conditions affecting body systems including the cardiovascular system, and confirmed that the commission's findings were supported by undisputed evidence that the employer's blanket policy was unrelated to the applicant's actual ability to work safely.

labor & employmentcivil rights

In People v. Gzikowski, the defendant was convicted of two first-degree murders and sentenced to death based on special circumstances involving multiple murders and his personal presence and intent during the killings, along with a firearm enhancement; he was tried jointly with a codefendant convicted of second-degree murder. The trial court denied a continuance after the defendant's chosen cocounsel withdrew shortly before trial, leaving only his less-experienced counsel who had not prepared for the guilt or penalty phases and who had sought time to secure replacement counsel. The California Supreme Court reversed the judgment, holding that the denial of the continuance deprived the defendant of his right to representation by counsel of his choice.

criminal lawprocedure

This case concerned whether punitive damages could be awarded in a superior court lawsuit alleging racial job discrimination under California's Fair Employment and Housing Act (FEHA). Two Black employees sued their employer, Commodore Home Systems, claiming they were fired due to race and seeking compensatory and punitive damages after receiving right-to-sue letters from the Department of Fair Employment and Housing. The employer moved to strike the punitive damages claims, arguing that FEHA limited remedies to those available from the Fair Employment and Housing Commission, such as back pay and reinstatement. The California Supreme Court held that FEHA does not restrict the relief available in court actions and that punitive damages may be recovered under general civil law provisions (Civ. Code § 3294) for oppression, fraud, or malice, as the statute's remedial limits apply only to agency proceedings, not judicial suits.

civil rightslabor & employmentprocedure