Justia Civil Rights Opinion Summaries

A man parked his car in San Francisco's Sutter-Stockton Garage, leaving his dog in the car. When he returned, he saw his dog had been brutally killed. A security guard viewed video clips from the incident and recognized Best, who was charged with second-degree burglary of a vehicle; killing, maiming, or abusing an animal; and vandalism of the vehicle, plus four misdemeanors. The trial court declared a doubt about Best’s competency; Best apparently refused to face the judge in order to avoid having her image recorded. Experts evaluated Best; the court found Best mentally competent to stand trial.The matter was continued for a Faretta hearing. A different judge confirmed that Best had read and initialed each portion of an “Advisement and Waiver of Right to Counsel” and inquired into Best’s education and awareness of the charges. The court engaged in extensive questioning. Some of Best’s responses betrayed a lack of understanding of legal concepts and procedures. When the court asked Best about possible defenses, her discussion verged on incoherence. Best gave clear, accurate answers to simpler questions. The court denied her motion. Best was convicted.The court of appeal reversed; the trial court erred in denying Best the right to represent herself on the grounds she had not knowingly and voluntarily made that choice. The court rejected arguments that the Faretta motion was untimely and that Best was disruptive and disobedient and noted that the transcript does not show Best was advised of the maximum punishment she faced. View "People v. Best" on Justia Law

The Contra Costa County Public Guardian was appointed as the conservator of J.Y.’s person in 2004. The conservatorship was continued 12 times. The guardian filed a petition for reappointment in November 2018. J.Y. objected, requested a jury trial, and objected to the guardian calling her as a witness at trial, arguing that such compelled testimony would violate her due process and equal protection rights. The court overruled that objection. A jury trial was held and J.Y. testified. A psychiatrist testified that J.Y. suffered from schizophrenia; a licensed psychologist testified that J.Y was gravely disabled. The court reappointed the guardian as the conservator of her person and imposed special disabilities depriving J.Y. of the rights to refuse treatment, enter into contracts, and possess or own firearms. The court also designated her current placement in a skilled nursing facility, where she had lived for 10 years, as the least restrictive alternative placement.The court of appeal dismissed an appeal as moot because the one-year conservatorship has terminated but agreed that conservatees are similarly situated to persons found not guilty by reason of insanity in proceedings to extend their civil commitment. Considering the serious liberty interests at stake in involuntary civil commitments, the guardian did not offer a compelling reason why conservatees’ procedural protections should not include the right against compelled testimony. View "Conservatorship of J.Y." on Justia Law

Plaintiff-appellant James Willis, a peace officer employed by the Carlsbad Police Department (Department), sued defendant-respondent City of Carlsbad (City) alleging in part that it engaged in whistleblower retaliation against him in violation of Labor Code section 1102.5 (b) by denying him promotions after he reported what he perceived was misconduct by another officer and complained about a Department program he believed was an unlawful quota system. Before trial, City successfully moved to strike allegations of other retaliatory acts within Willis's cause of action on grounds he had not timely presented a government tort claim within six months of the acts as required by the Government Claims Act. The trial court in limine excluded evidence of any violations by City of the Public Safety Officers Procedural Bill of Rights Act while at the same time permitting City to present evidence Department had denied Willis promotion because of a June 2012 e-mail he wrote under an assumed name lodging the officer misconduct accusations. The jury returned a verdict finding in favor of Willis that his reporting of City's violation of law was a contributing factor in City's decision to deny him the promotion. However, it also found City would have denied Willis his promotion anyway for legitimate independent reasons. Accordingly, the court entered judgment in City's favor on the whistleblower retaliation claim. On appeal, Willis argued the trial court erred as a matter of law by striking those portions of his section 1102.5 cause of action because the Government Claims Act's six-month statute of limitations was either equitably tolled or his cause of action had not accrued by reason of the continuing tort/continuing violation doctrine. Furthermore, he argued the court's evidentiary rulings were a prejudicial abuse of discretion. We conclude the trial court did not err, and accordingly affirm the judgment. Finding no reversible error, the Court of Appeal affirmed the trial court's judgment. View "Willis v. City of Carlsbad" on Justia Law

Augustine Caldera was a prison correctional officer who sometimes stuttered when he spoke. In 2010, Caldera filed a lawsuit against the California Department of Corrections and Rehabilitation (CDCR) and his supervisor alleging disability discrimination. The trial court granted defendants’ motion for summary judgment. The Court of Appeal reversed, holding a stutter constituted a disability under the Fair Employment and Housing Act (FEHA). A jury found in Caldera’s favor and awarded $500,000. The court granted a motion for new trial because it found the damage award excessive. The Court of Appeal reversed on procedural grounds. After nearly a decade of litigation, Caldera sought about $2.4 million in statutory attorney fees (a $1.2 million “lodestar” and a 2.0 “multiplier”). The court awarded a little over $800,000. Caldera appealed. The Court of Appeal determined Caldera could not find a local attorney to take his discrimination lawsuit, so he hired an out-of-town firm. But when calculating attorney fees, the court set the attorneys’ hourly rate based on a lower local rate, rather than a higher out-of-town rate. The court then applied the extrinsic "Ketchum" factors to the hourly rate, rather than applying a multiplier to the lodestar. "In sum, Caldera’s attorneys were not adequately compensated consistent with the purposes of the FEHA." Thus, the Court reversed the trial court’s order for attorney fees. View "Caldera v. Dept. of Corrections & Rehabilitation" on Justia Law

Where, as here, there is a dispute over what facts the previously suing parties knew at the time they brought suit, a trial court faced with an anti-SLAPP motion by those parties must decide whether the malicious prosecution plaintiff has shown that her allegation that those parties lacked probable cause has "minimal merit." The Court of Appeal held that a trial court should do so by (1) resolving all factual disputes regarding what the previously suing parties knew by accepting the plaintiff's evidence as true and (2) through that lens, evaluating whether the prior claim(s) were legally and factually tenable.In this case, the court held that plaintiff has proven that her malicious prosecution claim has minimal merit and that the trial court acted properly in denying the anti-SLAPP motions to dismiss that claim. Plaintiff alleged that defendants filed a 2016 suit against her to, among other things, exact vengeance on her for filing for divorce. Accordingly, the court affirmed the trial court's order denying the anti-SLAPP motions. View "Gruber v. Gruber" on Justia Law

Plaintiffs appealed the trial court's order granting defendant's motion to strike plaintiffs' complaint against defendant under the anti-SLAPP statute, Code of Civil Procedure section 425.16.The Court of Appeal held that the Anti-SLAPP statute applies to 42 U.S.C. 1983 claims brought in state court. Therefore, the trial court correctly applied the anti-SLAPP statute to plaintiff's section 1983 claims. Under the first prong of the anti-SLAPP analysis, the court held that all claims against defendant arose from protected conduct. Under the second prong, the court held that the trial court correctly concluded that plaintiffs failed to establish a probability of success on their claims against defendant. Accordingly, the court affirmed the trial court's judgment. View "Patel v. Chavez" on Justia Law

T-Mobile USA, Inc. (T-Mobile) appeals a judgment entered on a $5 million jury verdict in favor of former employee Stephen Colucci in a workplace retaliation case. T-Mobile primarily challenged the punitive damages award, arguing insufficient evidence was presented at trial that a T-Mobile agent engaged in retaliatory conduct, or that the agent's actions were malicious or oppressive. Alternatively, T-Mobile argued the $4 million punitive damages award was constitutionally excessive. Stephen Colucci worked for T-Mobile from 2007 until 2014 as the manager of a store in Ontario, California. A series of incidents ranging from a medical accommodation request, defamatory comments made by co-workers, and an allegation that Colucci was running a side business while on duty for his T-Mobile store. On day, complaining of back pain, Colucci was permitted to leave work for the day; while away, Robson recommended to HR that T-Mobile terminate Colucci for "cause" (conflict of interest), notwithstanding no loss prevention investigator interviewed Colucci or any co-workers about Colucci's alleged side-dealings while on T-Mobile time. In making this decision, Robson admittedly bypassed T-Mobile's progressive discipline policy, which might have included a warning or less severe consequence before resorting to termination. Information about the alleged conflict of interest had come almost entirely from the associate; at no point did anyone speak to Colucci about a purported conflict. Unaware of any pending termination, Colucci submitted a formal request to HR for a medical leave of absence. Colucci also lodged a second complaint to T-Mobile's integrity line, reporting that Robson was discriminating against him and neglecting to resolve the defamation incident. Undeterred, Robson proceeded with processing Colucci's termination. Ultimately, a jury returned a unanimous verdict in Colucci's favor on his claim of retaliation, awarding $1,020,042 in total compensatory damages for past and future economic losses, and past and future noneconomic damages and/or emotional distress. After review, the Court of Appeal reduced the punitive damages award to an amount one and one-half times the amount of compensatory damages, but otherwise affirmed the judgment. View "Colucci v. T-Mobile USA, Inc." on Justia Law

Plaintiff filed suit against The Regents for gender discrimination based on a series of events that took place while she was a Professor of Medicine at UCLA. The jury found in favor of plaintiff, awarding her economic and noneconomic damages.The Court of Appeal reversed and held that the trial court committed a series of grave errors that significantly prejudiced The Regents' right to a fair trial by an impartial judge. In this case, the trial court delivered a presentation to the jury highlighting major figures in the civil rights movement, and told the jury their duty was to stand in the shoes of Dr. Martin Luther King and bend the arc of the moral universe toward justice; the trial court allowed the jury to hear about and view a long list of discrimination complaints from across the entire University of California system that were not properly connected to plaintiff's circumstances or her theory of the case; the trial court allowed the jury to learn of the contents and conclusions of the Moreno Report, which documented racial discrimination occurring throughout the entire UCLA campus; and the trial court allowed plaintiff to resurrect a retaliation claim after the close of evidence despite having summarily adjudicated that very claim prior to trial. The court held that these errors were cumulative and highly prejudicial, and were evidence of the trial court's inability to remain impartial, creating the impression that the trial court was partial to plaintiff's claims. View "Pinter-Brown v. The Regents of the University of California" on Justia Law

In 1993, Shelton was sentenced to a prison term of 19 years to life after pleading no contest to the second-degree murder of his mother-in-law and assault with a firearm on her sister-in-law. Shelton had no prior criminal history. Parole hearings in 2016 and 2018, were his fifth and sixth. Shelton’s “Comprehensive Risk Assessment,” from 2016, concluded he presented a low risk of violence. The psychologist who evaluated Shelton noted “confusion and memory loss secondary to multiple traumatic brain injuries” Shelton had suffered in the military. Shelton, 64 years old in 2019, was permanently mobility impaired and blind/vision impaired. Shelton filed a habeas corpus petition. TIn November 2019, Shelton was again denied parole.The court of appeal ordered a new hearing for consideration of all of the relevant factors. The record suggests Shelton’s cognitive condition will never allow him to demonstrate the kind of insight into his crimes that the panels have been demanding. According to the doctor, Shelton’s neurocognitive disorder was a significant contributing factor in his commission of the offense and “it is unlikely that his disorder will ever allow him to give a coherent narrative about his motivations at the time of the crime.” That lack of insight had not led to violent outcomes in prison. The panel also failed to adequately consider Shelton’s elderly status and the magnitude of his disabilities. View "In re Shelton" on Justia Law

In 1997, Frederic Sannmann pleaded guilty to felony robbery which rendered him ineligible to own firearms. In 2003, he successfully moved to set aside his conviction for most purposes: by statute, this relief did not restore Sannmann's right to own firearms. In 2011, Sannmann successfully moved, with the prosecutor's concurrence, to set aside the earlier set-aside order, to withdraw his 1997 felony guilty plea, and to instead plead guilty to misdemeanor theft nunc pro tunc to the date of his original plea. Sannmann immediately notified the California Department of Justice (DOJ) of these changes and the DOJ eventually updated its records accordingly. However, six years later, when Sannmann tried to buy a shotgun from a gun store, the DOJ blocked the purchase based on Sannmann's original 1997 felony conviction. Sannmann filed a petition for writ of mandamus seeking an order directing the DOJ to release any holds on his ability to purchase firearms based on the 1997 felony conviction. The trial court believed it lacked the authority to determine the validity of the 2011 set-aside order entered by another superior court judge. Thus, finding Sannmann's record in the criminal case disclosed only a misdemeanor conviction (by virtue of the 2011 set-aside order), the court entered judgment for Sannmann and ordered the DOJ to release its hold on Sannmann's purchase. On appeal, the DOJ contended the trial court erred by awarding mandamus relief based on the 2011 set-aside order because the 2011 order was an unauthorized act in excess of the superior court's jurisdiction. The DOJ did not otherwise seek to invalidate the 2011 set-aside order. On the narrow issue before it, the Court of Appeal agreed the trial court erred by granting mandamus relief based on the 2011 set-aside order and reversed the judgment. View "Sannmann v. Dept. of Justice" on Justia Law