Justia Civil Rights Opinion Summaries

Plaintiff worked as a driver for California Transit. After California Transit terminated his employment, Evenskaas filed this wage and hour class action against California Transit; its owner, and the company that administered California Transit’s payroll, Personnel Staffing Group, LLC (collectively, the California Transit defendants).   Because Plaintiff signed an arbitration agreement, in which he agreed to arbitrate all claims arising from his employment and waived his right to seek class-wide relief, the California Transit defendants filed a motion to compel arbitration. The trial court denied the motion. The California Transit defendants appealed, contending the FAA applies to the arbitration agreement.   The Second Appellate District reversed the order denying Defendants’ motion to compel arbitration is reversed. The court directed the trial court to enter a new order granting the motion and dismissing Plaintiff’s class claims. The court explained that because the paratransit services California Transit hired Plaintiff to provide involve interstate commerce for purposes of the FAA, the FAA applies to the arbitration agreement and preempts the Gentry rule that certain class action waivers in employment arbitration agreements are unenforceable. View "Evenskaas v. California Transit, Inc." on Justia Law

After the police saw Ayon commit two minor traffic violations, they stopped him in his car and detained him until a narcotics dog arrived, 12 minutes and 45 seconds into the stop. After the dog indicated the presence of drugs, the police searched the car, wherein they found cocaine, methamphetamine, currency, and a scale. The trial court denied Ayon’s motion to suppress, rejecting his argument that the police unlawfully prolonged the duration of the stop in violation of his Fourth Amendment rights.The court of appeal reversed. “A careful reading of the record shows the stop was actually part of a preexisting drug investigation, and the police used the traffic infractions as a pretext for the stop.” While that fact does not by itself render the search unconstitutional, based on the evidence in the record viewed objectively—including police body camera videos of the stop—the police unlawfully prolonged the traffic stop. One officer’s body camera continued to record for a total of 61 minutes, at which time the stop and search were still underway. View "People v. Ayon" on Justia Law

The Court of Appeal affirmed the judgment of the trial court convicting Defendant of the involuntary manslaughter of his girlfriend, holding that no violation of Brady v. Maryland, 373 U.S. 83 (1963), occurred in this case.During trial, the county medical examiner opined that the victim had been beaten to death, and the district court relied on that testimony in arguing that Defendant beat his girlfriend to death, thereby committing first-degree murder. On appeal, Defendant challenged the trial court's failure to disclose certain portions of redacted memoranda written by the office of the district attorney as material relevant to impeachment of the medical examiner's trial testimony. The Court of Appeal affirmed, holding that, although portions of the redacted memoranda qualified as impeachment material under Brady, the failure to disclose them was not material to the outcome at trial. View "People v. Deleoz" on Justia Law

In 2018, Cuenca pleaded guilty to false imprisonment of his girlfriend and to a related charge of resisting arrest resulting in serious bodily injury to an officer. The court imposed a split sentence: three years of formal probation plus county jail time that amounted to a single day, net of credit for time served. Two years later, while on probation, Cuenca was charged with assault and criminal threats arising out of a physical altercation with a male friend, A jury found Cuenca guilty of a lesser offense of assault. The court revoked probation and sentenced Cuenca to county jail for an aggregate term running a total of five years and two months for the three felony convictions in both cases. Cuenca pursued consolidated appeals.The court of appeal affirmed the convictions and sentence, rejecting an argument that Napa County’s failure to grant county jail inmates the same opportunities that state prison inmates have to earn rehabilitation program credits violated his constitutional right to equal protection. Napa County need not put forward evidence of the actual reasons justifying its policy choice; the challenged classification is presumed to be rational. View "In re Cuenca" on Justia Law

Plaintiffs, seven adults who claimed they were molested by a priest when they were children, brought suit against The Roman Catholic Archbishop of Los Angeles and related parties ("Defendants"). The Plaintiffs' claims were that the Defendants ratified the assaults and acted negligently in failing to supervise the priest who committed the assaults.In response, Defendants moved to strike the complaint, claiming that some of the acts that allegedly ratified the priest's conduct, as well as those serving as the basis for the allegations of negligence, constituted speech and litigation conduct that was protected under California's anti-SLAPP law (Code Civ. Proc. § 425.16). The district court rejected Defendants' anti-SLAPP motion.The Second Appellate District affirmed. As to the ratification claims, the court held that Defendants mischaracterized Plaintifffs' complaint, "cherry-picking allegations of litigation conduct, and, without support, suggesting that they are the only allegations incorporated by reference into the sexual abuse cause of action."As to the negligence claims, Defendants too narrowly construed Plaintiffs' complaint, focusing only on what Defendants claim was protected speech. Any allegations in Plaintiffs' complaint that may have been "conclusory" when taken out of context, were supported by factual allegations earlier in the complaint. View "Ratcliff v. Roman Catholic Archbishop of L.A." on Justia Law

Plaintiffs-appellants Alan Dohner and William Gerber were, when their lawsuits were filed, general population inmates living in dormitory housing at Chuckawalla Valley State Prison (CVSP). They claimed they had the right to possess a personal television in their cells, rather than being limited to shared televisions located in common areas. They raised various claims flowing from the enforcement of the regulations that prohibited them from doing so. The trial court rejected all the claims, denying their request for a writ of habeas corpus without issuing an order to show cause and sustaining respondents’ demurrer to their claims for a writ of mandate and declaratory relief. Finding no reversible error in the trial court's rulings, the Court of Appeal affirmed. View "In re Dohner" on Justia Law

After being terminated from a position with Sacramento County (the County), plaintiff-appellant Cynthia Vatalaro sued the County for unlawful retaliation under Labor Code section 1102.5. Vatalaro alleged that, in violation of this statute, the County retaliated against her after she reported that she was working below her service classification. The County moved for summary judgment, contending Vatalaro could not show that she had a reasonable belief, or any belief at all, that the information she disclosed evidenced a violation of any law. The County added that, regardless, Vatalaro’s claim still failed because the County had a legitimate, nonretaliatory reason for terminating her. The trial court, agreeing with the County on both these points, granted summary judgment in the County’s favor. On appeal, Vatalaro alleges that the trial court was wrong on both these issues. The Court of Appeal affirmed, though on a ground somewhat different than those raised at the trial level: "the relevant standard is not whether the County demonstrated it had such a [non-discriminatory] reason; it is instead whether the County 'demonstrate[d] by clear and convincing evidence that the alleged action would have occurred for legitimate, independent reasons even if the employee had not engaged in activities protected by Section 1102.5.'" View "Vatalaro v. County of Sacramento" on Justia Law

Under the 2020 Racial Justice Act, “[t]he state shall not seek or obtain a criminal conviction or seek, obtain, or impose a sentence on the basis of race, ethnicity, or national origin” (Pen. Code 745 (a)). The Act's discovery provision allows a defendant, “[u]pon a showing of good cause,” to obtain evidence from the prosecution relevant to a potential violation. Based on evidence presented at his preliminary hearing, Young argued that racial profiling in a traffic stop led to his arrest for possession of Ecstasy for sale. He cited statistics showing that, statewide, blacks are more likely to be searched during traffic stops than others. He sought discovery relating to charging decisions for the past five years concerning others who were charged with or could have been charged with possession of Ecstasy for sale and related drug offenses. The trial court denied the motion.The court of appeal vacated. Borrowing from the minimal threshold showing that is required to trigger an obligation to provide “Pitchess” discovery (Evid. Code 1043(b), Young may claim entitlement to discovery under the Act if he makes a plausible case, based on specific facts, that any of the enumerated violations of section 745(a) could or might have occurred. The court must engage in a discretionary weighing of the strength of Young’s factual showing, the potential probative value of the information he seeks, and the burdens of gathering the requested information. View "Young v. Superior Court of Solano County" on Justia Law

The value of shares of stock in Restoration Robotics, a Delaware corporation, dropped within months of the company’s 2017 initial public stock offering. Wong, having purchased the stock, sued Restoration in San Mateo County Superior Court, alleging that the company’s offering documents contained materially false and misleading statements in violation of the Securities Act of 1933 (15 U.S.C. 77). Although the 1933 Act generally allows a plaintiff to choose whether to file suit in state or federal court, and bars the removal to federal courts of a suit filed in state court, a “federal forum provision” (FFP) in Restoration’s certificate of incorporation states that 1933 Act claims must be brought in federal court unless Restoration consents to a different forum.The trial court declined jurisdiction on the basis of the FFP. The court of appeal affirmed, rejecting arguments that the FFP violates the 1933 Act, which states that both state and federal courts have jurisdiction over 1933 Act causes of action, that the Delaware statutory scheme permitting the FFP violates the Commerce Clause and the Supremacy Clause, and that the FFP is invalid and should not be enforced in any event because it is unfair and unreasonable. View "Wong v. Restoration Robotics, Inc." on Justia Law

Christopher Ross, a former prosecutor with the Riverside County District Attorney’s office (DA’s Office), sued the County of Riverside for whistleblower retaliation and disability discrimination after the DA’s Office allegedly demoted him and refused to accommodate medical issues in response to Ross raising concerns that the DA’s Office was prosecuting an innocent man for murder. During a deposition, the former district attorney who preceded then-District Attorney Paul Zellerbach, Rodric Pacheco, testified about a conversation he had with the district attorney who succeeded Zellerbach, Mike Hestrin. Pacheco testified that he and Hestrin shared the view that Zellerbach was one of the most unethical attorneys they had encountered as prosecutors. Ross subpoenaed Hestrin for a deposition about his communications with the unidentified County lawyers, as well as regarding advice Hestrin provided to Ross in Hestrin’s capacity as an official in the prosecutors’ union in which Ross was a member. The County moved to quash the subpoena, which the trial court granted. The trial court found Hestrin’s alleged communications with the unidentified County lawyers were irrelevant to Ross’s retaliation and discrimination claims, and that Ross could obtain evidence regarding his union rights from other sources. Ross sought a writ of mandate to direct the trial court to vacate its order granting the motion to quash and to enter a new order denying it. The Court of Appeal denied the petition as it related to evidence concerning Hestrin’s role counseling Ross regarding his union rights. The Court granted the petition as it related to alleged requests by the unidentified County lawyers that Hestrin alter his testimony regarding Zellerbach’s ethical character. “[A]lthough we agree with the trial court that the testimony is irrelevant to the merits of Ross’s substantive claims against the County, the testimony is relevant to Zellerbach’s credibility, and he will likely be a material trial witness. Testimony showing the unidentified County lawyers attempted to suppress or alter a witness’s testimony about the credibility of a material witness is also relevant to show the County’s consciousness of guilt.” View "Ross v. Super. Ct." on Justia Law