1st District Court of Appeal

1st District Court of Appeal, Civil Procedure, Constitutional Law, Family Law

Irvine v. Irvine — A pending criminal case did not automatically require delaying a domestic-violence restraining-order hearing

automatic / September 18, 2026

A DVRO respondent facing related criminal charges is not automatically entitled to a continuance; courts must balance self-incrimination concerns against safety, delay, and statutory objectives.

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

People v. Adam — Witness travel and unexplained courtroom unavailability did not justify missing the misdemeanor speedy-trial deadline

automatic / September 18, 2026

The court reversed a misdemeanor conviction because witness travel ending before the last day and unexplained courtroom unavailability did not establish good cause to exceed section 1382’s deadline.

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

In re Haney — Racial Justice Act claim fails under Hazlett’s defendant-focused standard

automatic / September 16, 2026

The First District denied a Racial Justice Act jury-selection claim because the evidence did not meet Hazlett’s requirement of bias directed toward the defendant.

1st District Court of Appeal, Administrative Law, Civil Procedure

Sakach v. County of Marin — Clerk’s Improper Rejection Did Not Make Administrative Appeal Late

automatic / September 14, 2026

A clerk’s unsupported rejection of a timely administrative appeal did not make the appeal late; the notice was deemed filed when first submitted.

1st District Court of Appeal, Business Transactions, Litigation, Personal Injury & Tort

Caltrans v. Herc Rentals — Cargo Shipper May Share Fault for Unsafe Loading

automatic / September 14, 2026

A cargo shipper may share negligence liability when its own loading choices create an unsafe load, despite duties imposed on the carrier and driver.

1st District Court of Appeal, Criminal Law

People v. Putallez — Probation Officer May Select Treatment Programs Within Court-Defined Limits

automatic / September 11, 2026

The Court of Appeal upheld a probation condition allowing an officer to select drug and mental-health programs because the sentencing court set the treatment categories and did not authorize residential confinement.

1st District Court of Appeal, Constitutional Law, Real Estate Law, Tax (non-estate)

Debbane v. City and County of San Francisco — Ellis Act Preempts Proposition M Vacancy Tax

automatic / September 11, 2026

The Court of Appeal held San Francisco’s Proposition M vacancy tax preempted because it penalized residential owners for exercising the Ellis Act right to leave the rental business.

1st District Court of Appeal, Family Law, Litigation

Marriage of Trousset and Kelley — Family Court Must Make Express Need-Based Fee Findings

automatic / September 4, 2026

A family court must expressly compare access to litigation funds and ability to pay before denying need-based fees under Family Code section 2030.

1st District Court of Appeal, Civil Procedure, Litigation

Ari Law v. Autonation.com — Rescheduled Hearing Did Not Defeat Sanctions Safe Harbor

automatic / August 26, 2026

A later court-assigned hearing date did not invalidate a sanctions motion that was substantively identical to the version served before the 21-day safe harbor.

1st District Court of Appeal, Construction Law, Personal Injury & Tort, Real Estate Law

Schurman Family Company TIC v. Superior Court — Landlord Was Protected by Privette Delegation

automatic / August 26, 2026

A warehouse owner was protected by the Privette doctrine because its lease placed it upstream in the chain delegating the work and workplace safety to contractors.

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

Mitchell v. Lilac Solutions, Inc. — extensive court litigation waived arbitration rights

automatic / August 20, 2026

The First District held that defendants waived arbitration by extensively litigating an employment case before changing forums after an anti-SLAPP motion.

1st District Court of Appeal, Criminal Law

In re Jose S. — Juvenile Court Could Place Former DJJ Ward in Adult Jail

automatic / August 19, 2026

A published First District decision holds that section 875(k) permitted adult-jail placement for a former DJJ ward who had also received a state-prison sentence.

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

M.W. v. Superior Court — Amnesia Alone Does Not Establish Juvenile Incompetence

automatic / August 18, 2026

The First District held that a juvenile's amnesia did not establish incompetence where he otherwise understood the proceedings and could assist counsel.

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

In re C.M. — Probation Officers Cannot Impose Juvenile Electronic Monitoring Without Court Review

automatic / August 14, 2026

A published California decision holds that probation officers cannot impose juvenile electronic monitoring without judicial review and clear standards.

1st District Court of Appeal, Civil Procedure, Litigation, Personal Injury & Tort

Mary D. v. McCauley — Incarcerated Civil Defendant Entitled to Meaningful Trial Access

automatic / August 12, 2026

The Court of Appeal reversed for a new trial. Once McCauley met the threshold showing governing incarcerated civil litigants, the trial court had to meaningfully consider practical measures that would permit access to court; denying additional time to secure counsel under these circumstances was an abuse of discretion and violated constitutional access rights.

1st District Court of Appeal, Labor & Employment Law, Personal Injury & Tort

Simerley v. Golden Gate Bridge District — Maritime law bars spouse’s loss-of-consortium claim for seaman’s injury

automatic / August 11, 2026

The spouse of a seaman injured on a public ferry cannot recover loss-of-consortium damages under the Jones Act or general maritime law.

1st District Court of Appeal, Business Transactions, Litigation, Real Estate Law

Nasey v. Fell Holdings LLC — Contract addenda placed failed property-closing risks on buyer

automatic / August 10, 2026

A buyer who agreed to an all-cash, no-contingency repurchase could not use disclosure and inspection arguments to excuse missing the closing deadline.

1st District Court of Appeal, Administrative Law, Environmental Law

Russian Riverkeeper v. County of Sonoma — Well-permit ordinance survives public-trust review but requires CEQA compliance

automatic / August 4, 2026

Sonoma County adequately considered public-trust impacts when revising its groundwater-well ordinance, but lacked substantial evidence for exempting the revision from CEQA.

1st District Court of Appeal, Criminal Law

People v. Keene — Section 654 Bars Multiple Punishment for the Same Drug-and-Firearm Possession

automatic / August 3, 2026

The Court of Appeal required stays for overlapping drug and firearm possession terms but upheld the upper term as harmless error.

1st District Court of Appeal, Civil Procedure, Constitutional Law, Healthcare Law

Conservatorship of C.O. — Counsel may communicate conservatee’s jury-trial waiver

automatic / August 3, 2026

An LPS conservatee may knowingly waive a jury trial through counsel, although the trial court should personally advise the conservatee of that right.

1st District Court of Appeal, Business Transactions, Litigation

Salamon v. Orchid Global — Delaware Forum Clause Cannot Reduce California Shareholder Inspection Rights

automatic / July 31, 2026

A published California decision refuses to enforce a Delaware forum clause because the corporation failed to show that Delaware litigation would preserve nonwaivable California shareholder inspection rights.

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

Thompson v. Superior Court — Mental-health diversion may include rehabilitative search conditions

automatic / July 30, 2026

Trial courts may impose reasonable, rehabilitation-focused conditions when granting pretrial mental-health diversion.

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

Saberin v. Alation, Inc. — California arrest-record protections did not cover a Utah remote worker

automatic / July 30, 2026

California employment laws restricting use of arrest records did not apply to a Utah employee whose arrest and termination decision occurred outside California.

1st District Court of Appeal, Administrative Law, Constitutional Law, Litigation

Toy v. City and County of San Francisco — Water-Rate Challenges Must Follow California’s Validation Procedure

automatic / July 24, 2026

A challenge to San Francisco water rates failed because California's mandatory reverse-validation procedure could not be waived by the city or replaced with refund and declaratory-relief claims.

1st District Court of Appeal, Civil Procedure, Insurance Law, Litigation

Kumar v. Mid-Century Insurance Co. — Closed insurance claim started the one-year suit deadline

automatic / July 22, 2026

Closed insurance claim started the one-year suit deadline.