California Case Summaries

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2nd District Court of Appeal, Constitutional Law, Criminal Law

In re Melson — Murder Conviction Vacated After Prosecution Failed to Correct False Eyewitness Testimony and Defense Counsel Did Not Review Police Interview Transcripts

The Second District Court of Appeal grants habeas corpus and vacates a second-degree murder conviction after finding the prosecution allowed false eyewitness testimony to stand uncorrected — and defense counsel failed to cross-examine the witnesses with their own prior contradictory police statements — in a gang-related retrial.

2nd District Court of Appeal, Family Law

In re Landon M. — Appeal Dismissed as Moot; Court Clarifies That Allowing Armed Father Access Does Not Constitute Reportable ‘Severe Neglect’ Under CACI

The Second District dismisses a mother's dependency appeal as moot after the juvenile court terminated jurisdiction and granted her sole custody, holding that allowing a father with known guns access to children constitutes 'general neglect' — not the 'severe neglect' that would trigger a reportable CACI listing.

3rd District Court of Appeal, Civil Procedure, Labor & Employment Law

Phan v. Knight Sacramento SU Inc. — Car Dealership Arbitration Agreements Struck as Unconscionable Under Cook v. USC Standard

The Third District Court of Appeal affirms the trial court's refusal to compel arbitration of an auto dealership employee's wage and hour claims, finding the employer's adhesive arbitration agreements unconscionable under Cook v. University of Southern California (2024) due to high economic coercion and one-sided third-party beneficiary provisions.

Ninth Circuit Court of Appeals, Administrative Law, Environmental Law

Rinnai America Corp. v. South Coast Air Quality Management District — Federal Energy Law Does Not Preempt SCAQMD’s Zero-NOx Gas Appliance Rule

The Ninth Circuit, 2-1, holds that the Energy Policy and Conservation Act (EPCA) does not preempt the South Coast Air Quality Management District's Rule 1146.2, which phases in zero-NOx emission standards for gas water heaters and boilers to bring the Los Angeles Basin into compliance with federal ozone standards under the Clean Air Act.

Ninth Circuit Court of Appeals, Criminal Law

United States v. Shi — Ninth Circuit Rejects ‘Sophisticated Laundering’ Sentencing Stack Where Required Predicate Enhancement Was Never Applied

The Ninth Circuit affirms money laundering convictions and most sentencing enhancements in a $2.5 million Target gift-card laundering scheme, but vacates and remands because the district court improperly applied the sophisticated-laundering enhancement under USSG § 2S1.1(b)(3) without first applying the required predicate enhancement under § 2S1.1(b)(2)(B).

Ninth Circuit Court of Appeals, Administrative Law, Constitutional Law, Environmental Law

Rinnai America Corp. v. South Coast Air Quality Management District — Federal Energy Law Does Not Block California’s Zero-Emission Appliance Rules

The Ninth Circuit ruled 2-1 that the federal Energy Policy and Conservation Act (EPCA) does not preempt SCAQMD's Rule 1146.2, which phases out gas-fired water heaters and boilers across Southern California to achieve compliance with federal ozone standards — dealing a major setback to appliance manufacturers challenging the ban.

Ninth Circuit Court of Appeals, Criminal Law, Litigation

United States v. Shi — Ninth Circuit Vacates Sophisticated-Laundering Enhancement Where Required Guideline Step Was Skipped

The Ninth Circuit vacated a sophisticated-laundering sentencing enhancement because the district court applied the enhancement without first working through the required preceding step in U.S.S.G. § 2S1.1(b)(2), remanding for limited resentencing of three defendants convicted in a large-scale gift-card laundering scheme.

1st District Court of Appeal, Constitutional Law, Criminal Law

People v. DePape — California Double Jeopardy Bars Three State Charges After Federal Conviction in Paul Pelosi Attack

The First District affirms dismissal of three state charges against David DePape — including attempted murder — under California's statutory double jeopardy protection, holding that mental-state elements cannot save a state charge when the required physical act was already proved in a prior federal conviction.

1st District Court of Appeal, Criminal Law, Litigation

People v. Powell — Trial Court Can Correct Presentence Credit Math Errors Without Triggering Full Resentencing

The First District holds that a trial court's mathematical error in calculating presentence custody credits is a clerical error the court can correct at any time — but that correction does not render the judgment nonfinal or entitle the defendant to full resentencing under ameliorative legislation, rejecting a contrary line of cases.

1st District Court of Appeal, Civil Procedure, Labor & Employment Law, Litigation

Smith v. Superior Court — Court of Appeal Allows 440 Tesla Racial Discrimination Plaintiffs to Proceed in Joint Complaints

The First District grants a writ of mandate requiring Tesla to face five joint complaints from 440 Black factory workers, holding that permissive joinder under CCP § 378 is proper where all plaintiffs allege injury from the same factory-wide pattern of racial discrimination — and that manageability concerns cannot justify ordering mass individual re-filings.

3rd District Court of Appeal, Administrative Law, Environmental Law, Tax (non-estate)

Garst v. Tehama County Flood Control District — Countywide Groundwater Registration Charge Is an Unconstitutional Tax

The Third District struck down a Tehama County groundwater district's per-acre annual charge as an unconstitutional tax rather than a valid regulatory fee, ruling that Proposition 26 bars a fee imposed on parcels with no groundwater wells for a well-registration program that provides no direct service to those parcels.

Ninth Circuit Court of Appeals, Civil Procedure, Criminal Law

Cannon v. United States — Government Cannot Keep Cash Stolen by Its Own Agent After Recovering It in Restitution

The Ninth Circuit ruled that sovereign immunity does not block a person from recovering seized cash that a federal agent stole and the government later recouped in restitution proceedings, reversing summary judgment for the government in a case where an FBI agent pocketed $218,200 of money seized during a drug investigation.

4th District Court of Appeal, Civil Procedure, Family Law

In re N.J. — Implied Findings Doctrine Supplies Missing Presumed Father Finding in Dependency; ICWA Remand Required

The Fourth District holds that where a juvenile court treats a father as a presumed father throughout dependency proceedings without expressly saying so, the implied findings doctrine satisfies the requirement — but an explicit finding must be directed on remand, alongside mandatory ICWA compliance.

4th District Court of Appeal, Administrative Law, Environmental Law, Litigation

Protect Our Communities Foundation v. City of San Diego — SDG&E Franchise Upheld; CEQA, Prop. 26, and Charter Bidding Challenges Rejected

The Fourth District upholds the City of San Diego's 20-year gas and electric franchise agreements with SDG&E, rejecting challenges under CEQA, Proposition 26, and the City Charter's competitive bidding rules, while striking a supermajority termination clause as inconsistent with the Charter.

4th District Court of Appeal, Constitutional Law, Criminal Law

In re I.H. — Mistaken Identity Arrest Upheld; Firearm Discovered Incident to Resisting-Arrest Charge Is Admissible

The Fourth District holds that officers who reasonably but mistakenly identified a juvenile as a murder-warrant fugitive had probable cause to arrest him, and that after realizing the mistake they lawfully searched him incident to a resisting-arrest charge, making the discovered firearm admissible.

Ninth Circuit Court of Appeals, Criminal Law, Immigration

Leon-Briviesca v. Blanche — Ninth Circuit Defines “Crime of Child Abuse” for Immigration Removal After Loper Bright, Covers California Penal Code § 273a

In its first post-Loper Bright interpretation of the federal immigration removal ground for crimes of child abuse, the Ninth Circuit holds that the statute covers child endangerment, requires criminal negligence mens rea, and applies regardless of whether the defendant is the child's parent — and that California Penal Code § 273a(a) falls within its scope.

Ninth Circuit Court of Appeals, Immigration, Litigation

Ibarra-Perez v. United States — Ninth Circuit Refuses En Banc Review of Ruling That FTCA Suit for Wrongful Removal to Unspecified Third Country Is Not Barred by § 1252(g)

The Ninth Circuit denies en banc review of a panel ruling that 8 U.S.C. § 1252(g) does not strip federal district courts of jurisdiction over an FTCA damages claim by a noncitizen removed to Mexico when his removal order did not name Mexico as the destination.

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