Justia Civil Rights Opinion Summaries

Augustine Caldera was a correctional officer at a state prison with a stutter. The prison’s employees mocked or mimicked Caldera’s stutter at least a dozen times over a period of about two years. Sergeant James Grove, a supervisor, participated in the mocking and mimicking of Caldera’s stutter. Such conduct reflected the prison’s culture, according to a senior prison official. Caldera sued the California Department of Corrections and Rehabilitation (CDCR) and Grove (collectively defendants) for disability harassment, failure to prevent the harassment, and related claims. A jury found the harassment to be both severe and pervasive and awarded Caldera $500,000 in noneconomic damages. The trial court found the damage award to be excessive and granted defendants’ motion for a new trial solely as to that issue. Defendants appealed and Caldera cross-appealed. Defendants claimed there was insufficient evidence the harassment was either severe or pervasive. Defendants also claimed the trial court committed two instructional and one evidentiary error. The Court of Appeal found substantial evidence to support the jury’s factual findings. The Court of Appeal also found no prejudicial instructional errors and the claimed evidentiary error was forfeited. Caldera claimed the trial court failed to file a timely statement of reasons after granting defendants’ motion for a new trial. To this, the Court of Appeal agreed, and reversed the trial court’s new trial order as to the damage award. In all other respects, the judgment was affirmed. View "Caldera v. Dept. of Corrections & Rehabilitation" on Justia Law

The Court of Appeal affirmed the trial court's order dismissing plaintiffs' challenge to an amendment to California law that eliminated the previously existing "personal beliefs" exemption from mandatory immunization requirements for school children. Senate Bill No. 277 eliminated the personal beliefs exemption from the requirement that children receive vaccines for specified infectious diseases before being admitted to any public or private elementary or secondary school, day care center or the like. The court held that plaintiffs failed to cite any authority for their assertion that SB 277 violated freedom of religion and plaintiffs' free exercise claim was meritless; SB 277 did not violate plaintiffs' constitutional right to attend school; SB 277 did not violate the equal protection clause where the statutory classifications and exemptions plaintiffs disputed did not involve similarly situated children, or were otherwise entirely rational classifications; SB 277 was not void for vagueness where it was sufficiently clear to give fair warning of the required conduct; and SB 277 did not violate Health and Safety Code 24175 subdivision (a). View "Brown v. Smith" on Justia Law

The South Orange County Community College District (the District) dismissed Carol Wassmann from employment as a tenured librarian at Irvine Valley College (IVC) in April 2011. Several years later, Wassmann obtained a right to sue notice from the California Department of Fair Employment and Housing (DFEH) and brought this lawsuit against the District, Karima Feldhus, Robert Brumucci, Glenn Roquemore, Lewis Long, and Katherine Schmeidler. Wassmann, who is African-American, alleged causes of action for racial discrimination, age discrimination, and harassment in violation of the California Fair Employment and Housing Act (FEHA), intentional infliction of emotional distress, and two other causes of action (not relevant here). The trial court granted two motions for summary judgment: one brought by the District Defendants and the other brought by Long and Schmeidler, on the ground the FEHA claims were barred by res judicata, collateral estoppel, or failure to exhaust administrative remedies, and the intentional infliction of emotional distress cause of action was barred by res judicata, collateral estoppel, or the statute of limitations. Wassmann appealed, but finding no reversible error in the grant of summary judgment, the Court of Appeal affirmed. View "Wassmann v. South Orange County Community College Dist." on Justia Law

Plaintiff-appellant Natasha Meeks contended that she suffered sexual harassment on the job. She brought suit against her employer, defendant-appellant AutoZone, Inc. (AutoZone), and the alleged harasser, defendant-appellant Juan Fajardo, raising claims of sexual harassment, failure to prevent sexual harassment, and retaliation in violation of the Fair Employment and Housing Act (FEHA). The trial court granted summary adjudication in favor of AutoZone on Meeks’s retaliation claim. A jury returned defense verdicts on her remaining claims. On appeal, Meeks argued that certain evidentiary rulings at trial were prejudicial errors, requiring reversal. She also claimed the trial court’s grant of summary judgment to AutoZone on her retaliation claim was erroneous. After review, the Court of Appeal affirmed the trial court’s grant of summary adjudication on the retaliation claim. However, the Court found several erroneous evidentiary rulings required reversal of the judgment and remand for new trial on the remaining claims. View "Meeks v. AutoZone, Inc." on Justia Law

Plaintiff-respondent Dawn Turnbull sued defendants-appellants the Lucerne Valley Unified School District (LVUSD), Tom Courtney, Suzette Davis, John Buchanan, and Keri Gasper. Turnbull brought causes of action for: (1) disclosing her private medical information; (2) invading her privacy; (3) interfering with her constitutional rights; (4) violating her civil rights; and (5) conspiring to deprive her of her right of privacy or right of free speech. Davis was the superintendent of LVUSD. Turnbull and Courtney were members of the LVUSD board. Although not explicit, it was inferred from the complaint that Buchanan was also a member of the LVUSD board. Gasper was an LVUSD volunteer. Turnbull opposed Davis’s alleged misappropriation of LVUSD funds. In retaliation for Turnbull’s opposition, Davis: (1) obtained confidential medical information about Turnbull from Turnbull’s employer; (2) generated false reports from the California Longitudinal Pupil Achievement Data System (CALPADS), concerning school lunch program eligibility; and (3) on July 8, 2015, falsely told LVUSD board members that evidence strongly suggested Turnbull illegally accessed CALPADS. Shortly after a LVUSD board meeting, Courtney and Buchanan, as private citizens, called Turnbull’s employer to report Turnbull’s allegedly unlawful access of CALPADS. Turnbull had legally accessed CALPADS to obtain a report concerning her stepchild. Courtney used his position as a LVUSD board member to obtain access to Turnbull’s private medical information. Courtney, as a private citizen, caused Turnbull’s private medical information to be published on social media or gave the information to people who published it on social media. Courtney intended to intimidate Turnbull to stop her from opposing Davis’s acts of misappropriation. Gasper received Turnbull’s private medical information from Courtney, Davis, or Buchanan. Gasper published the information on social media. LVUSD, Courtney, and Davis brought an anti-SLAPP motion, which the trial court denied. LVUSD, Courtney, and Davis contended the trial court erred by denying their motion. The Court of Appeals affirmed the order denying the anti-SLAPP motion; defendants failed to establish that the allegations in the complaint arose from protected activities. View "Turnbull v. Lucerne Valley Unified School Dist." on Justia Law

Plaintiff Adrian Camacho appealed after the trial court granted summary judgment in favor of defendant Target Corporation (Target) on Camacho's causes of action for discrimination based on sexual orientation, harassment causing a hostile work environment, failure to prevent harassment and discrimination, retaliation, constructive termination in violation of public policy, intentional infliction of emotional distress, negligent infliction of emotional distress, negligent hiring, supervision, and retention, and a violation of the Bane Act (Civ. Code sec. 52.1). The trial court concluded that language included in an addendum to a preprinted compromise and release form utilized to settle Camacho's workers' compensation action against Target constituted a broad release of any and all potential claims that Camacho may have had against Target, including claims falling outside the workers' compensation system. After reviewing the relevant language in the addendum and considering that language in the context of the entire settlement agreement, the Court of Appeal concluded that the trial court erred in determining that the language at issue contained in the addendum to the settlement agreement executed by the parties in Camacho's workers' compensation case constituted a general release of all of Camacho's civil claims. The Court therefore reversed the judgment and remanded for further proceedings. View "Camacho v. Target Corp." on Justia Law

Penal Code sections 3051 and 1170.1(c) are irreconcilable as they apply to a youth offender who commits an additional crime in prison after the age of 26, because section 3051, which specifically addresses youth offenders, dictates that the youth offender be immediately released upon being found suitable for parole. In contrast, section 1170.1(c) would require the same youth offender to serve any applicable Thompson term even after being found suitable for release. Because section 3051 is both later-enacted and more specific, section 3051 supersedes section 1170.1(c).The Court of Appeal granted a petition for writ of habeas corpus, ordering Ronald Jenson released. Jenson was convicted of first degree felony murder at age 19. Jenson committed three additional in-prison crimes during his first nine years of incarceration, but he has remained crime-free for the last 30 years of his sentence. The Board of Parole Hearings found Jenson suitable for release on parole at a youth offender parole hearing, but the CDCR ordered him to serve an additional sentence for his in-prison offenses. The court held that Jenson need not serve his Thompson term and was entitled to be released from prison. View "In re Jenson" on Justia Law

Rosa Jensen and Linda Kerr sued their former employer, The Home Depot, Inc., (Home Depot), and their former managers at Home Depot for disability discrimination, wrongful termination, and eight other related claims. Home Depot and the managers (collectively, defendants) demurred to the first amended complaint arguing misjoinder of Jensen and Kerr (collectively, plaintiffs). The trial court sustained the demurrer without leave to amend, and dismissed plaintiffs’ lawsuit with prejudice. Jensen contended on appeal the trial court erred by dismissing her lawsuit because the court could have ordered severance. “It is an abuse of the trial court’s discretion to sustain a demurrer without leave to amend if there is a reasonable possibility the plaintiff can amend the complaint to allege any cause of action.” At trial court, the Court of Appeal found plaintiffs made no showing as to how they would amend their complaint to fix the misjoinder issue. Accordingly, the trial court acted reasonably in sustaining the demurrer without leave to amend because plaintiffs failed to meet their burden. However, leave to amend may be requested for the first time on appeal; plaintiffs fixed the misjoinder issue by dismissing Kerr. Because the misjoinder issue has been fixed, the Court of Appeal ruled the case may proceed. The judgment of dismissal, as it pertains to Jensen, was reversed. The trial court was directed to enter an order vacating its order denying leave to amend as to the first through seventh causes of action, and enter an order granting leave to amend. The trial court was also directed to deem the first amended complaint to have been amended due to the dismissal of Kerr. View "Jensen v. The Home Depot, Inc." on Justia Law

Plaintiff Carl Taswell, M.D., who is certified in nuclear medicine, filed a complaint against the Regents of the University of California (the Regents). Taswell alleged he was retaliated against for his whistleblowing activities regarding patient safety at the brain imaging center during his employment by the University of California, Irvine. Taswell appealed after the trial court granted the Regents’ motion for summary judgment and summary adjudication. After review, the Court of Appeal reversed, finding that, following an administrative hearing, Taswell was not required to exhaust his judicial remedies (by seeking a writ of mandamus) to challenge the University’s rejection of his claims of retaliation. After exhausting his administrative remedies, Taswell was statutorily authorized to file this civil action and seek damages based on his statutory whistleblower retaliation claims; the administrative decision had no res judicata or collateral estoppel effect on this action. Also, a triable issue of material fact existed as to whether the University’s decisions to place Taswell on an investigatory leave of absence and to not renew his contract had a causal connection to Taswell’s whistleblowing activities. Therefore, summary judgment and/or summary adjudication should not have been granted on the theory that no triable issue of fact existed. View "Taswell v. The Regents of the Univ. of Cal." on Justia Law

The issue this case presented for the Court of Appeals’ review centered on the trial court’s partial denial of a special motion to strike pursuant to Code of Civil Procedure section 425.16, the anti-SLAPP statute, directed at causes of action arising out of the manner in which defendants, the Office of the Inspector General (OIG) and Robert Barton, in his capacity as Inspector General, conducted interviews with five correctional officers who previously worked at High Desert State Prison. The interviews were conducted as part of an investigation into that institution’s “practices . . . with respect to (1) excessive use of force against inmates, (2) internal reviews of incidents involving the excessive use of force against inmates, and (3) protection of inmates from assault and harm by others.” As relevant here, these officers and the California Correctional Peace Officers Association (CCPOA) alleged in their first and second causes of action that defendants violated Penal Code section 6126.5 and Government Code section 3300 et seq. (the Public Safety Officers Procedural Bill of Rights or the Act) by refusing the officers’ requests to be represented during the interviews. The trial court denied the anti-SLAPP motion as to these causes of action, concluding: (1) defendants carried their threshold burden of demonstrating the gravamen of these causes of action arose from protected activity; but (2) plaintiffs established a probability of prevailing on the merits of these claims. The Court of Appeal agreed defendants carried their burden on the threshold issue, but concluded plaintiffs failed to establish a probability of prevailing on the merits of these causes of action. The Court therefore reversed the portion of the trial court’s order denying the anti-SLAPP motion with respect to the first and second causes of action and remanded the matter to the trial court with directions to enter a new order granting the motion in its entirety and dismissing the complaint. View "Blue v. Cal. Office of the Inspector General" on Justia Law