Justia Civil Rights Opinion Summaries

Nancy Wood, an indigent homeless woman, was residing in Mile Square Park in Fountain Valley, near the hospital where she received treatment for cancer and heart disease. The City of Fountain Valley, which had no homeless shelter at the time, sought to prohibit her from living in the park, citing violations of city ordinances. Wood argued necessity as a defense, claiming her health conditions required her to stay near the hospital.The City initially filed a criminal complaint against Wood, where she was represented by appointed counsel. While the criminal case was pending, the City also filed a civil lawsuit for nuisance against her. In the civil case, Wood, representing herself, again argued necessity. The trial court conducted the proceedings remotely due to COVID-19 restrictions. Despite Wood's claims that she had not received the City's trial exhibits, the court proceeded, ultimately finding her culpable for public nuisance and issuing an injunction prohibiting her from residing in the park. Shortly after the civil judgment, Wood was acquitted in the criminal case.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that the trial court abused its discretion by not staying the civil case pending the outcome of the criminal case. The appellate court noted that the simultaneous civil and criminal proceedings placed an unfair burden on Wood, especially given her indigent status and lack of legal representation in the civil case. The court also found that the trial court failed to consider all relevant evidence, including Wood's necessity defense, in issuing the injunction. The judgment was reversed, and the case was remanded with instructions for the trial court to reconsider the propriety of the injunction, taking into account Wood's acquittal in the criminal case and all relevant equitable factors. View "People v. Wood" on Justia Law

The petitioner, Milton Jonas Arias Molina, was charged with special circumstances murder, conspiracy to commit murder, and street terrorism. During the preliminary examination, Molina and his two co-defendants were required to share a single Spanish-language interpreter. Molina sought relief after the trial court denied his motion to dismiss based on the failure to provide him with his own interpreter throughout the preliminary examination.The charges arose from a homicide that occurred in October 2018. The Santa Cruz County District Attorney charged Molina and his two co-defendants with murder, conspiracy to commit murder, and street terrorism. The complaint also alleged two special circumstances—that the murder was committed by means of lying in wait and that the murder was committed for the benefit of a criminal street gang—along with various other firearm and gang sentencing enhancements.The preliminary examination was conducted in 13 sessions over the course of 15 months. During the first day of the preliminary examination, Molina’s counsel objected that the hearing would be conducted with a single interpreter for all three defendants. The prosecutor also voiced her concerns about the lack of interpreters. The magistrate stated that he intended to proceed with the hearing, with the understanding that if any of the defendants needed to speak with counsel, he would interrupt the proceedings to permit that.The Court of Appeal of the State of California Sixth Appellate District concluded that the failure to provide an individual interpreter for Molina at his preliminary examination reasonably might have affected the outcome. The court issued the writ of mandate instructing the trial court to vacate its order denying Molina’s motion to dismiss and enter a new order granting that motion, without prejudice to the Santa Cruz County District Attorney refiling the charges and conducting a new preliminary examination. View "Molina v. Superior Court" on Justia Law

The case involves Erika Paleny, who sued her employer, Fireplace Products U.S., Inc., and her manager, Sabah Salah, alleging harassment, discrimination, and retaliation after she informed them of her plans to undergo oocyte (egg) retrieval procedures for donation and future personal use. Paleny claimed that her manager disapproved of the procedures and subsequently harassed her for needing time off for the procedures, which eventually led to her termination.The Superior Court of Sacramento County granted the defendants' motion for summary judgment, finding that the egg retrieval and freezing procedures did not qualify as a pregnancy-related medical condition or disability and were therefore not protected by the California Fair Employment and Housing Act (FEHA). Paleny appealed this decision, arguing that the lower court's ruling erroneously interpreted the relevant statutes and denied her protection under the FEHA.The Court of Appeal of the State of California Third Appellate District affirmed the lower court's decision. The court found that Paleny was not pregnant nor disabled by pregnancy during her employment, and thus could not claim entitlement to the protections afforded under section 12940 et seq. of the FEHA. The court also found that Paleny was not suffering from a medical condition related to pregnancy. The court concluded that the egg retrieval procedure did not constitute a medical condition related to pregnancy under the FEHA, as Paleny was undergoing an elective medical procedure without an underlying medical condition related to pregnancy. Therefore, Paleny did not have a protected characteristic under the FEHA. View "Paleny v. Fireplace Products U.S., Inc." on Justia Law

The case involves Xingfei Luo, who twice sought a restraining order against Professor Eugene Volokh under the Code of Civil Procedure section 527.6. Luo wanted to prevent Volokh from identifying her in his writings. After the trial court dismissed the first petition, Luo moved to "strike" exhibits she filed in support of that failed petition. The trial court denied that motion and granted Volokh’s motion to preclude her from proceeding pseudonymously in that case. Luo appealed these orders. The second case involves Luo’s second petition for a restraining order where the trial court granted Volokh’s anti-SLAPP (strategic lawsuit against public participation) motion and dismissed Luo’s second petition. Luo also appealed from a subsequent order granting Volokh’s motion to preclude Luo from proceeding pseudonymously in her second petition.The Superior Court of Los Angeles County denied Luo's first petition for a restraining order, concluding that the alleged harmful conduct was "likely protected free speech." The court also found that the alleged facts did not comprise acts of violence, threats of violence, or a course of conduct that seriously alarmed, annoyed, or harassed the petitioner and caused substantial emotional distress. Luo did not appeal from the order discharging that petition. However, Luo filed an "ex parte application for an order to strike and withdraw improperly filed exhibits." The trial court denied Luo’s ex parte motion to “strike” her exhibits because Luo had not completed the proper forms for submitting an ex parte motion. Luo filed a new motion and Volokh again opposed it, and also filed a separate motion to preclude Luo from proceeding pseudonymously in that case. The trial court denied Luo’s motion to strike her exhibits and granted Volokh’s motion to preclude Luo from proceeding pseudonymously.In the Court of Appeal of the State of California Second Appellate District Division One, the court affirmed the order granting Volokh’s anti-SLAPP motion and dismissing Luo’s second petition. The court dismissed Luo’s appeals as to the trial court’s ruling on her motion to strike exhibits in her first petition and the court’s granting of Volokh’s motions in both cases to use her actual name. The court concluded that these rulings are based on nonappealable orders. View "Luo v. Volokh" on Justia Law

The case involves Cailin Hardell, who sued Adrian Vanzyl, Waleed Mohsen, and Blumberg Capital for sexual assault and battery, sexual harassment, and retaliation, among other claims, related to an incident in Miami, Florida in March 2022. Vanzyl, a non-resident defendant, moved to quash service of summons of the first amended complaint, arguing that he had insufficient contacts with California for the trial court to exercise either specific or general personal jurisdiction over him. The trial court agreed and also denied Hardell’s request to conduct jurisdictional discovery.The trial court's decision was based on its finding that Vanzyl was not domiciled or continuously and systematically present in California in March 2022, and that Vanzyl had insufficient suit-related contacts with California. Hardell appealed this decision, arguing that the trial court erred in its findings and that it should have granted her request for jurisdictional discovery.The Court of Appeal of the State of California First Appellate District Division Four concluded that the connection between Hardell’s claims against Vanzyl and his contacts with California was too attenuated to support specific jurisdiction. However, it also concluded that the trial court erred in failing to consider whether it could exercise general jurisdiction over Vanzyl notwithstanding its finding that he was not domiciled in California in March 2022, and that it abused its discretion in denying Hardell’s request for discovery. The case was remanded, with Hardell being allowed to conduct limited discovery addressing whether the trial court may exercise general jurisdiction over Vanzyl. View "Hardell v. Vanzyl" on Justia Law

The case involves two former faculty members at the University of California, Los Angeles (UCLA), who were accused of serious misconduct. An independent law firm was hired to investigate the allegations, and the resulting report concluded that the professors had engaged in improper activities. The professors resigned their positions as part of a settlement agreement, with no findings of misconduct or admissions of liability. A former UCLA employee requested the report under the California Public Records Act (CPRA), and the professors objected, leading to a series of legal actions known as "reverse-CPRA" actions.The Superior Court of Los Angeles County denied the professors' petitions to withhold the report, concluding that the public interest in disclosure outweighed the professors' privacy interests. The court found that the allegations of misconduct were serious and substantial, and that the public had a strong interest in knowing how the university handled such complaints. The professors appealed this decision.While the appeal was pending, the Los Angeles Times made its own CPRA request for related documents, including the investigation report and the settlement agreements. The professors sought a preliminary injunction to prevent the release of these documents, but the trial court denied their request. The court found that the professors were unlikely to succeed on the merits of their claim, as the analysis for the disclosure of these documents was the same as for the investigation report. The professors appealed this decision as well.The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court agreed with the trial court's analysis and found no reason to delay a decision on a matter concerning public transparency. The court concluded that the professors had not established a likelihood of success on the merits of their claim and were therefore not entitled to injunctive relief. View "Doe v. The Regents of the University of California" on Justia Law

The case involves a developmentally disabled woman, referred to as A.L., who was sexually assaulted by an employee of a transportation service. The transportation service was contracted by Harbor Developmental Disabilities Foundation, a regional center under the Lanterman Developmental Disabilities Services Act. The regional center's role is to assess the needs of developmentally disabled individuals and contract with service providers to meet those needs. A.L. sued the employee, the transportation service, and the regional center, arguing that the regional center had a duty to protect her from sexual assault by the transportation service's employees.The trial court granted summary judgment in favor of the regional center, concluding that the regional center did not have a duty to protect A.L. from sexual assault by the transportation service's employees unless the regional center had actual knowledge of the employee's propensity to engage in such conduct. The trial court's decision was based on the fact that the regional center had no such knowledge in this case.On appeal, the Court of Appeal of the State of California Second Appellate District affirmed the trial court's decision. The appellate court agreed that the regional center had a duty to protect A.L. from sexual assault by the transportation service's employees only if the regional center had actual knowledge of the employee's propensity to engage in such conduct. The court concluded that imposing a broader duty on the regional center would effectively convert regional centers into insurers of all harm to consumers, which could potentially shut down these centers and deny essential services to the entire population of developmentally disabled persons. View "A.L. v. Harbor Developmental Disabilities Foundation" on Justia Law

The case involves two students, Chad Ayach and Joseph Nofal, who were expelled from the University of California Riverside (UC Riverside) following an administrative hearing. The university's Student Conduct and Academic Integrity Programs office (SCAIP) initiated an investigation into the Phi Gamma Delta fraternity (PGD) after receiving a report expressing concern for the health of a member of the fraternity's pledge class. During the investigation, it was revealed that the fraternity engaged in activities that appeared to meet UC Riverside's definitions of hazing. Ayach and Nofal, who held leadership roles in the fraternity, were subsequently expelled.The Superior Court of Los Angeles County reviewed the case after Ayach and Nofal filed a petition for writ of mandate challenging their expulsions. They argued that the university's administrative hearings did not afford them due process because the charging documents and evidence presented used pseudonyms to identify witnesses, and they were purportedly denied the opportunity to confront or cross-examine these witnesses at the hearing. The court denied the petition, and Ayach and Nofal appealed.The Court of Appeal of the State of California, Second Appellate District, Division One, affirmed the lower court's decision. The appellate court concluded that the administrative proceedings afforded Ayach and Nofal the process they were due, given the nature of the charges and their response. The court found that the hearings before the committee provided Ayach and Nofal with a full opportunity to present their defenses, which is what due process requires. The court also noted that the credibility of the witnesses was not central to the disciplinary decision, and therefore, the lack of cross-examination, lack of witness confrontation, and the use of pseudonyms in the description of witness statements did not prejudice Ayach's and Nofal's ability to present a meaningful defense. View "Ayach v. The Regents of the University of California" on Justia Law

The case involves David Arias, who was convicted of two counts of sexual abuse against a minor. During the trial, the defense challenged the prosecutor's use of a peremptory strike against a prospective Black female juror. The trial court ruled that a prima facie case of discrimination was established, but accepted the prosecutor's reasons for the strike without further discussion. Arias was convicted and sentenced to 15 years to life in prison.The trial court's decision was appealed to the Court of Appeal of the State of California, First Appellate District. The appellate court found that the trial court's denial of the defense's challenge to the prosecutor's peremptory strike was improper. The prosecutor's reasons for the strike did not withstand scrutiny. The appellate court concluded that the record lacked sufficient evidence on which the trial court could have reasonably relied to accept the prosecutor's reasons for striking the juror without further probing and explanation. As a result, the appellate court reversed the trial court's decision. View "P. v. Arias" on Justia Law

The case involves a defendant who was convicted of first-degree murder with special circumstances and an enhancement for personally and intentionally discharging a firearm causing great bodily injury or death. The defendant appealed his conviction, arguing that his trial counsel exhibited racial bias towards him in violation of the California Racial Justice Act of 2020 (RJA) by advising him to use Ebonics and slang when he testified. He also contended that the trial court erred in imposing two sentence enhancements and a parole revocation restitution fine after sentencing him to life without the possibility of parole.The Court of Appeal of the State of California, First Appellate District, Division Five, found that the defendant's trial counsel did not exhibit racial bias. The court noted that the counsel's advice to the defendant to "speak how you speak" when testifying was a valid tactical decision aimed at ensuring the defendant appeared authentic and genuine before the jury. The court also found that the defendant had not demonstrated by a preponderance of the evidence that his counsel's advice indicated racial animus or bias towards him. Therefore, the court concluded that there was no violation of the RJA.The court also found that the defendant's claim that his enhancements should have been stricken was forfeited for failure to request that the trial court strike the enhancements under section 1385. However, the court agreed with the defendant and the People that the trial court improperly imposed a parole revocation restitution fine. The court modified the judgment to strike the parole revocation restitution fine and affirmed the judgment in all other respects. View "P. v. Coleman" on Justia Law