California Case Summaries

3rd District Court of Appeal

3rd District Court of Appeal, Criminal Law

People v. Hirschfield — Unsupported Aggravating Findings Require Full Resentencing

automatic / October 26, 2026

The Third District reversed the judgment for sentencing purposes and ordered a full resentencing. The upper term could not rest on aggravating findings that duplicated elements of the crimes or the firearm enhancement, and the relevant danger-to-society finding required a comparison showing that the manner of committing the offense was distinctively worse than other ways the crime could be committed. The record and findings did not provide a valid, harmless foundation for the sentence imposed.

3rd District Court of Appeal, Administrative Law, Criminal Law

In re C.M. — Adult Ward’s Juvenile Cases Could Not Be Shifted to Parents’ County

automatic / October 22, 2026

The Third District reversed both transfers. Although juvenile-court jurisdiction can continue after age 18, the Legislature used “minor” deliberately in section 750. Once C.M. became an adult, his residence could not automatically be derived from his parents’ residence. The transfer courts therefore erred at the threshold by treating Mariposa County as his residence without determining where C.M. himself resided.

3rd District Court of Appeal, Constitutional Law, Criminal Law

People v. Garner — A 50-Year Juvenile Sentence Is Not a De Facto Life Term When Parole Is Available Under Section 3051

automatic / July 8, 2026

The Third District held that a juvenile offender's 50-year determinate sentence is not the functional equivalent of life without parole — and therefore does not qualify for resentencing under Penal Code section 1170(d)(1) — because section 3051 gave him a meaningful parole opportunity during his 15th year of incarceration.

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

automatic / July 2, 2026

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.

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

automatic / June 29, 2026

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.

3rd District Court of Appeal, Criminal Law, Healthcare Law

People v. Russo — Prior Failure in the Same Treatment Program Justifies Denying Mental Health Diversion

automatic / June 12, 2026

A trial court may deny mental health diversion under Penal Code section 1001.36 when a defendant proposes returning to the same treatment program that previously failed to address his needs — even if the court frames its analysis in terms of treatment adequacy rather than the statutory suitability factors.

3rd District Court of Appeal, Civil Procedure, Criminal Law, Litigation

Nuanmanee v. Superior Court — Court of Appeal Holds Defendant Was Not ‘Brought to Trial’ When Court Policy Prevented Jury Empanelment on Last Statutory Day

automatic / May 18, 2026

The Third District Court of Appeal granted a writ of mandate ordering dismissal of a misdemeanor DUI case after the trial court’s policy of not empaneling juries on Mondays prevented the defendant from being brought to trial on the last statutory day under Penal Code section 1382.

3rd District Court of Appeal, Administrative Law, Labor & Employment Law

Dept. of Human Resources v. CCPOA — Court of Appeal Upholds Arbitrator’s Award Reversing Union Rep’s 60-Day Suspension

automatic / May 15, 2026

The Third District Court of Appeal reversed the trial court and upheld an arbitrator’s award that set aside a correctional officer’s 60-day suspension, holding that the award did not contravene any explicit public policy despite conflicting with the State Personnel Board’s earlier ruling.

3rd District Court of Appeal, Environmental Law, Litigation

People ex rel. Yolo-Solano Air Quality Management District v. Defty — Cross-Complaint Challenging Validity of Underlying Agency Policy Does Not Arise From Protected Activity for Anti-SLAPP Purposes

automatic / April 27, 2026

Third District affirms denial of anti-SLAPP motion to strike a cross-complaint challenging the validity of an air quality management district's underlying interpretive policy, holding that the cross-complaint did not arise from the district's protected enforcement activities.

3rd District Court of Appeal, Environmental Law, Real Estate Law

Department of Water Resources Cases — DWR may use precondemnation entry statutes to investigate properties without first authorizing or funding the underlying water project

automatic / March 26, 2026

Third District holds that the California Department of Water Resources may use the precondemnation entry statutes to investigate properties for a potential water conveyance project without first satisfying Water Code requirements for project authorization and funding.

Scroll to Top