The case involved a citizens' group suing a state agricultural district for violating the California Environmental Quality Act by making substantial changes to a planned amphitheater without preparing a subsequent environmental impact report or providing public notice. The trial court had dismissed the suit as untimely under the 180-day statute of limitations from the start of construction. The California Supreme Court reversed, holding that the limitations period begins when plaintiffs knew or should have known of the substantial project changes, and the facts alleged could support a finding that this occurred only after the first noisy concert.
This case concerned Angelita Hoffman's application for a service-connected disability retirement pension under Government Code section 31720 from her clerical position with Los Angeles County, where the Board of Retirement awarded only a nonservice-connected pension after finding her conditions of hypertension, diabetes, depression, and anxiety were not sufficiently tied to her employment. The superior court applied the 1980 amendment's 'substantial contribution' test to deny her petition, the Court of Appeal reversed on grounds that the amendment should not apply retroactively, and the California Supreme Court reversed the Court of Appeal. The Court held that the amendment clarified rather than changed existing law on the causation standard for service-connected benefits, allowing retroactive application to Hoffman's pre-amendment application, and remanded for the superior court to apply the clarified test consistent with the companion Bowen decision.
Thomas Bowen, a Los Angeles County employee, sought service-connected disability retirement benefits under Government Code section 31720 after mental and physical health issues he linked to workplace stress, but the retirement board granted only nonservice-connected benefits. The California Supreme Court considered whether a 1980 amendment requiring that employment "contributes substantially" to the incapacity had altered the causation standard for qualifying for service-connected retirement. The court concluded the amendment merely clarified existing law and did not impose a stricter test, reversing the trial court and Court of Appeal decisions that had denied the service-connected pension. It remanded the case, reasoning that prior precedent such as Heaton v. Marin County Employees Retirement Bd. required only that the incapacity result from employment-related injury or disease, and that tort-based causation standards were not appropriate here given the statute's alignment with workers' compensation principles.
The case involved a challenge to San Marino's Ordinance No. 851, which imposed a special tax for police and fire services based on zoning classifications determined by real property parcel size, with flat rates per zone approved by over two-thirds of voters. Plaintiff Philip Heckendorn, a property owner, sued for declaratory relief and injunction, arguing the tax violated article XIII A of the California Constitution by functioning as an ad valorem tax exceeding the one-percent limit on real property taxes. The trial court sustained the city's demurrer without leave to amend, and the California Supreme Court affirmed. The court held that the ordinance did not create an ad valorem tax because it applied fixed amounts based on parcel size zones rather than a rate applied to assessed property value, consistent with the constitutional definition and voter intent behind Proposition 13. The opinion clarified that ad valorem taxes are those derived from applying a property tax rate to assessed value, distinguishing them from the parcel-based special tax at issue.
The case involved a worker who developed a progressive lung disease from long-term asbestos exposure at work and sought workers' compensation benefits. The Workers' Compensation Appeals Board awarded ongoing temporary total disability payments because the disease was not yet stationary, but the Court of Appeal had annulled that decision, suggesting the disease could be rated as permanent under certain conditions. The California Supreme Court reversed, holding that the Board may make a tentative rating of permanent disability for a progressive disease, provide advances based on that rating, and reserve jurisdiction to make a final determination later when the condition stabilizes or reaches total disability. This approach addresses the mismatch between the standard definition of permanent disability, which assumes a stationary condition, and the nature of insidious progressive diseases, while respecting the statutory five-year limit on the Board's jurisdiction.
The case concerned whether Los Angeles County and its cities could refuse to apply a state tax exemption under Revenue and Taxation Code section 225 to Star-Kist Foods' inventory of canned tuna of foreign origin that was stored in California for transshipment elsewhere. The court first determined that counties and municipalities have standing to challenge the constitutionality of a state statute on Commerce Clause grounds, even though they are political subdivisions of the state. It then held that the exemption violated the Commerce Clause because it discriminated against interstate commerce by favoring goods moving in foreign commerce. The reasoning relied on the principle that the Commerce Clause protects free trade among the states and on precedents showing that the exemption created unequal tax burdens based on the origin and destination of the goods.