Cruz Reynoso

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.

environmentprocedure

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.

labor & employment

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.

labor & employment

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.

taxesproperty

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.

labor & employmentprocedure

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.

taxesfederal powerbusiness & regulatory

In Perez v. Van Groningen & Sons, Inc., a minor plaintiff sued the defendant employer after being injured when he fell from a tractor driven by the employer's worker and was run over by the attached disking equipment; the worker had invited the plaintiff along to learn tractor operation while performing his assigned task of disking an orchard, despite a company rule against passengers. The trial court let the jury decide whether the worker was acting within the scope of employment, and the jury found for the defendant. The California Supreme Court reversed, holding that the worker was acting within the scope of employment as a matter of law. The court reasoned that respondeat superior liability applies because the worker remained engaged in the employer's business of disking, and violating the no-passenger rule did not constitute a substantial deviation from that employment.

torts & liabilitylabor & employment

This case involved the dissolution of the marriage of Kathleen and C. James Fabian, focusing on the characterization and division of the Villa Viejo Motel, a community property asset to which James had contributed $275,000 from his separate property. The trial court found the motel to be community property and James's contribution a gift to the community with no right to reimbursement, ordering the property sold and proceeds divided equally. While the appeal was pending, Civil Code section 4800.2 was enacted, providing for reimbursement of separate property contributions to community assets unless waived in writing. The California Supreme Court held that retroactive application of section 4800.2 to cases pending before its effective date impairs vested property rights without due process of law, following its prior decision in In re Marriage of Buol, and thus the statute could not apply here.

family lawproperty

In People v. Davenport, the defendant was convicted by a jury of first-degree murder with the special circumstance that the murder was intentional and involved the infliction of torture, for which the jury imposed a death sentence. The defendant challenged the constitutionality of the 1978 torture-murder special circumstance statute, argued that the jury instructions on the special circumstance conflicted with those defining first-degree murder by torture, and contended that the special verdict failed to satisfy statutory requirements under Penal Code sections 190.2 and 190.4. The California Supreme Court affirmed the murder conviction and special circumstance finding, holding that the statute was susceptible to a constitutional construction, the instructions were consistent and accurate, and the verdict met all legal standards. However, the court reversed the death judgment due to separate instructional errors during the penalty phase and remanded for new penalty proceedings.

criminal lawprocedure

In People v. Phillips, the defendant was convicted of two counts of robbery, one count of attempted murder, and one count of first-degree murder with a robbery special circumstance, along with firearm use enhancements, after robbing and shooting two associates involved in a purported drug trafficking and stolen insulation scheme, resulting in a death sentence. The California Supreme Court affirmed the guilt-phase convictions and the special circumstance finding after reviewing the evidence of the crimes and the defendant's participation. However, the court reversed the penalty phase judgment, holding that the trial court erred by failing to instruct the jury on the reasonable doubt standard for evidence of other criminal activity and by admitting evidence of criminal activity without limiting it to proof of actual crimes committed.

criminal lawprocedure

The case involved a high school student, William G., declared a ward of the juvenile court after an assistant principal searched his calculator case without a warrant and found marijuana, leading to a finding that he unlawfully possessed the drug for sale. The California Supreme Court reversed the adjudication, ruling that while public school officials may search students based on reasonable suspicion rather than probable cause due to the school setting, the search here failed even that standard because the assistant principal had no prior information or specific facts indicating the student possessed contraband. The court applied the exclusionary rule to bar the evidence in the juvenile proceeding under both the Fourth Amendment and article I, section 13 of the California Constitution.

criminal lawcivil rightsprocedure

The case concerned the constitutionality of Public Resources Code section 25531, which channels judicial review of Energy Commission decisions certifying thermal power plant sites and facilities (when also requiring PUC approval) exclusively to the California Supreme Court in the same manner as PUC certificate decisions. Sonoma County petitioned for review of the Energy Commission's approval of a geothermal plant and transmission line, raising substantive challenges but alternatively arguing the review provisions violated the state constitution by divesting other courts of jurisdiction. The court upheld the statute, reasoning that the Legislature has broad authority over PUC-related matters and that the Energy Commission's certifications form an integral part of the PUC process for public utilities, allowing the Legislature to direct review accordingly without conflicting with constitutional grants of jurisdiction.

environmentbusiness & regulatoryprocedure

This case involved buyers who entered into an installment land sale contract to purchase acreage from a family member, made most of the payments over several years, then willfully stopped paying after a separation; the seller later elected to terminate the contract and refused tender of the remaining balance. The trial court denied the buyers' request for specific performance, ruled they had forfeited any interest in the property, and limited their recovery to restitution of amounts paid. The Supreme Court of California reversed, holding that a vendee who has paid a substantial portion of the purchase price under such a contract retains an absolute right to redeem the property by paying the full balance due, even after willful default, because the seller retains title only as security; this right may be exercised before judgment or within a reasonable time set by the court. The decision drew on analogies to mortgage law and policies against forfeiture to conclude that the buyers had timely exercised their redemption right by tendering the balance.

property

The case concerned whether wholesaler Wallace Berrie & Company owed California use tax on disposable cardboard display racks it provided to retailers at no separate charge when they made minimum purchases of novelty items. Berrie had issued resale certificates to the rack manufacturers and stored the racks as inventory but did not collect or report sales tax on the racks, which the State Board of Equalization treated as a taxable use under its regulation governing marketing aids (Regulation 1670(c)). The trial court upheld the assessment, and the Court of Appeal affirmed, holding that the regulation is valid because it supplies objective criteria—such as whether the supplier recouped at least 50 percent of the rack’s cost—to distinguish a true sale from a giveaway, and Berrie’s transfers did not meet those criteria. The court rejected arguments that the racks should instead be taxed as premiums under a different regulation, noting that marketing aids serve a distinct advertising purpose that justifies separate treatment.

taxesbusiness & regulatory

Homeowners adjacent to the Burbank-Glendale-Pasadena Airport sued the airport authority for inverse condemnation and nuisance based on aircraft noise, smoke, and vibrations. The trial court dismissed both claims, ruling that the authority could not face inverse condemnation because it lacked eminent domain power and that the nuisance claim was time-barred as a permanent nuisance. The California Supreme Court reversed, holding that inverse condemnation liability arises from the state constitution's prohibition on taking or damaging property without compensation regardless of eminent domain authority, and that plaintiffs may elect to treat the interference as a continuing nuisance. The decisions rested on the constitutional basis of inverse condemnation actions and precedents allowing election between permanent and continuing nuisance characterizations when abatement is possible.

propertytorts & liability

In In re Marriage of Buol, a divorcing couple disputed whether a home purchased during marriage and titled in joint tenancy was community property or the wife's separate property based on an oral agreement regarding her earnings. The trial court found an enforceable oral agreement making the home the wife's separate property, but while the appeal was pending, the Legislature enacted Civil Code section 4800.1 requiring a writing to rebut the community property presumption for jointly titled assets. The California Supreme Court held that section 4800.1 cannot constitutionally apply retroactively to cases pending on its effective date. The core reasoning was that retroactive application would impair the wife's vested separate property rights, acquired under prior law recognizing oral agreements, without due process of law under the state constitution.

family lawpropertyprocedure

This case involved two codefendants, Jeremiah Trevino and Leonard Rivas, charged with murder during a robbery. During jury selection, the prosecutor used peremptory challenges to remove multiple Spanish-surnamed prospective jurors, prompting a defense motion under People v. Wheeler alleging exclusion of a cognizable group in violation of the right to a jury drawn from a representative cross-section of the community. The California Supreme Court concluded that the term "Spanish surnamed" sufficiently identifies Hispanics as a cognizable class and that the prosecution failed to meet its burden of showing the exclusions were not based on group bias, requiring reversal of Trevino's conviction. Separately, the court determined that the evidence against Rivas was insufficient as a matter of law, so the trial court's later grant of a new trial was effectively an acquittal that barred retrial under double-jeopardy principles. The opinion addressed the standards for both peremptory-challenge objections and post-trial acquittal rulings in criminal proceedings.

criminal lawcivil rights

This case involved a paternity dispute over a child named Michelle, born while her mother was married to and cohabiting with Ronald W.; Donald R., who later married the mother, claimed to be the biological father and challenged the constitutionality of Evidence Code section 621, which presumes such a child to be of the marriage. The trial court applied the presumption and granted summary judgment establishing Ronald W. as the legal father, and the California Supreme Court affirmed. The court held that the statute did not violate due process or equal protection as applied, because the public interest in protecting the stability of the existing family unit outweighed the interests of the putative father and child in establishing biological paternity. The prerequisites of the presumption were met, including the two-year period after birth during which no timely challenge was raised.

family law

The case concerned William Hittle, a Santa Barbara County employee injured on the job in 1977, who withdrew his modest retirement contributions from the county employees' retirement association after receiving form letters offering only a refund or deferred retirement. When he later sought disability retirement, the association denied the request on the ground that withdrawal had ended his membership, a prerequisite for such benefits. The trial court upheld the denial and dismissed Hittle's mandamus petition as untimely. The California Supreme Court held that an employee's withdrawal of contributions terminates membership only if the choice was informed, and that the association, as fiduciary, had a duty to disclose all options—including disability retirement—especially when on notice of a potential qualifying disability. The court further ruled the petition timely and remanded for further proceedings.

labor & employmentprocedure

The case involved a California resident who operated an illegal farming business in Mexico by using Mexican citizens as nominal owners to circumvent Mexican prohibitions on foreign control of agricultural enterprises. He entered into marketing and financing agreements with a California produce broker (a Tenneco subsidiary) that knew of the arrangement's illegality; after the broker ceased remitting sales proceeds to the grower and the Mexican operation collapsed, the grower sued for breach of contract, tort, and related claims seeking millions in damages, while the broker cross-complained for repayment of loans secured by California property. The California Supreme Court held that the grower could not obtain relief in California courts for losses stemming from the illegal Mexican venture. The court reasoned that principles of comity required deference to Mexican law and policy, so California would not assist a party in recovering from or enforcing rights dependent on a scheme that violated another sovereign's laws; it further concluded there was no true conflict of laws because California's only relevant interest was its policy against aiding such violations.

business & regulatoryprocedure