This case concerned whether a timber harvesting plan approved by the Department of Forestry and Fire Protection in 1988 for Louisiana-Pacific Corporation had to be set aside after the Board of Forestry later adopted permanent regulations protecting the northern spotted owl. The Court of Appeal had directed the department to vacate its approval so the plan could be updated or shown exempt due to substantial liabilities. The Supreme Court held that the timber operations, which were stayed by court order, qualified as proposed operations under the permanent rules and thus must follow one of the specified owl-protection procedures. However, the Forest Practice Act allows the operator to comply by resubmitting the plan, filing an amendment, or notifying the department of a minor deviation, without requiring the department to vacate the original approval. The judgment directing vacation of the approval was therefore reversed.
This case involved an 11-year-old minor charged in juvenile court under Welfare and Institutions Code section 602 with receiving stolen property and assault after incidents involving a bicycle and shooting glass. The central issue was the meaning of the "clear proof" standard in Penal Code section 26, which presumes children under 14 are incapable of committing crimes unless they knew the wrongfulness of their acts at the time. The California Supreme Court held that the prosecution must establish by clear and convincing evidence that the minor appreciated the wrongfulness of the conduct, affirming the wardship adjudication based on a psychiatrist's report. The court reasoned from the 1872 statutory language and historical usage that "clear proof" denoted a standard equivalent to clear and convincing evidence, distinct from proof beyond a reasonable doubt, and determined this satisfied due process in the juvenile context.
This case concerns the University of California's compliance with the California Environmental Quality Act (CEQA) in relocating its School of Pharmacy biomedical research facilities to a site in the Laurel Heights neighborhood of San Francisco. The dispute centers on whether the Regents were required to recirculate the final environmental impact report (EIR) for additional public comment due to new information about potential noise impacts from the project. The Supreme Court of California held that recirculation is mandated only when added information deprives the public of a meaningful opportunity to comment on substantial adverse environmental effects or feasible alternatives or mitigation measures that the project proponents have declined to implement. The Court further determined that decisions not to recirculate must be supported by substantial evidence and concluded that such evidence supported the Regents' decision not to recirculate the EIR in this instance, reversing the Court of Appeal's judgment.
The case involved Charles Hunter, who sued his former employer Up-Right, Inc. after his 1987 termination, claiming breach of an implied contract not to terminate without good cause as well as fraud based on alleged misrepresentations about the reasons for his dismissal. The California Supreme Court held that its prior decision in Foley v. Interactive Data Corp. precludes tort recovery for fraud or deceit when the misrepresentation is made merely to effectuate an employment termination. The court reasoned that the employment relationship is fundamentally contractual, so contract damages are the ordinary remedy for wrongful termination absent a public-policy violation; tort damages require proof of all fraud elements with respect to a misrepresentation entirely separate from the termination itself. The record did not support such a separate fraud claim, so the judgment awarding tort damages was reversed.
The case concerned whether the Operations Committee of the Orange County Employees Retirement System Board, an advisory body composed of four board members (less than a quorum), was subject to the open meeting requirements of the Ralph M. Brown Act. Freedom Newspapers sought access to a committee meeting on travel policy changes, but the committee denied entry, leading to a petition for writ of mandate. The California Supreme Court held that the committee was not a "legislative body" under Government Code section 54952.3 and thus exempt from the Act's open meeting rules. The court reasoned that the statute explicitly excludes advisory committees made up solely of less than a quorum of the governing body, as these groups only make recommendations without any decision-making authority.
The case involved the City of San Diego's eminent domain action to condemn two commercial parcels owned by the defendants for a road-widening project. The defendants also owned a nearby trailer park on separate but contiguous lots and sought severance damages for alleged injury to those remaining parcels, arguing they could be combined with the taken land for future commercial development as a single integrated unit. The trial court denied the claim, finding no present unity of use between the properties. The California Supreme Court held that separate legal parcels under common ownership may be treated as one larger parcel for severance damages purposes when the owner shows a reasonable probability that the lots will be available for development or use as an integrated economic unit in the reasonably foreseeable future. The court remanded the case to allow the owners an opportunity to make that showing before proving any actual damages.