4th District Court of Appeal

4th District Court of Appeal, Administrative Law, Environmental Law, Real Estate Law

Laguna Beach Historic Preservation Coalition v. City of Laguna Beach — City Could Not Remove Historic-Property Protections Wholesale

automatic / September 22, 2026

Laguna Beach could not eliminate CEQA protections for an entire historic inventory without determining property by property that the listed resources lacked historic significance.

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

People v. Cruz — Codefendant Trial Transcripts Did Not Violate Due Process at Resentencing

automatic / September 22, 2026

Using a codefendant’s trial transcripts at a Penal Code section 1172.6 hearing did not violate due process because the petitioner could present and test evidence.

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

Montes v. Superior Court — Prosecutors bear the burden to justify withholding jury-selection notes

automatic / September 21, 2026

A defendant may obtain prosecution jury-selection notes in postconviction discovery without first making a prima facie showing of racial bias.

4th District Court of Appeal, Family Law

F.L. v. Superior Court — Failed reunification with siblings can support bypass for a newborn

automatic / September 21, 2026

A juvenile court may bypass reunification services for a newborn based on a parent's failed reunification with siblings as of the new child's disposition hearing.

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

People v. Williams — Broad sentencing statistics did not establish a prima facie Racial Justice Act claim

automatic / September 17, 2026

A broad racial disparity statistic covering multiple kinds of enhancements did not establish a prima facie California Racial Justice Act violation without controlled analysis or comparable cases.

4th District Court of Appeal, Healthcare Law, Litigation

Sujan v. UHS Corona — Physician had to exhaust hospital peer-review remedies before damages suit

automatic / September 16, 2026

The Fourth District affirmed summary judgment because a physician failed to exhaust hospital peer-review remedies and upheld the related attorney-fee award.

4th District Court of Appeal, Administrative Law, Labor & Employment Law

Szewczyk v. OCERS — Regularly Scheduled Jail Overtime Counts Toward County Pensions

automatic / September 14, 2026

Mandatory overtime embedded in the normal schedule of Orange County jail deputies counted as compensation earnable for pension purposes.

4th District Court of Appeal, Family Law

Marriage of Jessica L. and Sammer Z. — Domestic-violence custody presumption must be independently applied

automatic / September 8, 2026

A California Court of Appeal held that a family court must independently apply the domestic-violence custody presumption rather than treat its rebuttal in another family case as binding.

4th District Court of Appeal, Criminal Law

In re Moore — Changed medical science required vacating child-abuse conviction

automatic / September 8, 2026

The Court of Appeal vacated a child-abuse conviction because later medical science undermined categorical expert testimony that a short fall could not have caused the fatal injuries.

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

In re N.S. — School police needed only reasonable suspicion to search student after gun remark

automatic / September 8, 2026

A school-assigned police officer could search a student on reasonable suspicion after a gun remark, and the student’s ten-minute physical obstruction supported a Penal Code section 148 finding.

4th District Court of Appeal, Criminal Law

People v. Solis — Knife-use admission and circumstantial evidence supported actual-killer finding

automatic / September 8, 2026

The Court of Appeal held that a knife-use admission plus the surrounding evidence supported an actual-killer finding and denial of Penal Code section 1172.6 relief.

4th District Court of Appeal, Criminal Law, Litigation

People v. Hawthorn — Guilty Plea Does Not Preclude Resentencing Issues, but Error Was Harmless

automatic / September 4, 2026

A guilty plea does not preclude factual litigation at a Penal Code section 1172.6 hearing, though Hawthorn failed to show the error changed the result.

4th District Court of Appeal, Estate Planning, Probate and Tax Law, Litigation, Probate

Sandford v. Sandford — Trust equalization clause cannot revive time-barred claims

automatic / September 2, 2026

A trust equalization clause covering loans and gifts did not permit a court to revive time-barred claims over decades of family property income.

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

Comite Civico del Valle v. County of Imperial — Lithium project EIR lacked support for long-term water supply

automatic / September 2, 2026

Imperial County’s lithium-project EIR lacked evidence of a 50-year water supply and failed to analyze related mitigation and air-quality risks.

4th District Court of Appeal, Healthcare Law, Litigation, Personal Injury & Tort

Godshall v. Peterson — Ongoing symptoms did not conclusively start malpractice limitations clock

automatic / September 2, 2026

Triable issues remained over when an injury from carpal-tunnel surgery manifested, so the malpractice action could not be dismissed on limitations grounds.

4th District Court of Appeal, Criminal Law

People v. Espinosa — Compassionate release may rely on practical medical evidence, but recall still requires resentencing

automatic / August 31, 2026

A California appellate court upheld compassionate release while clarifying that sentence recall must be followed by resentencing and that parole conditions belong to the parole board.

4th District Court of Appeal, Administrative Law, Real Estate Law

Parsons v. City of Indian Wells — City may let common-interest communities opt out of short-term-rental limits

automatic / August 31, 2026

Indian Wells may let qualifying common-interest communities opt out of its short-term-rental minimum because the program neither amends HOA documents nor delegates core lawmaking power.

4th District Court of Appeal, Family Law

In re A.H. — Intervening tribe is presumptively entitled to a guardian’s court-ordered psychological evaluation

automatic / August 31, 2026

An intervening tribe has presumptive statutory access to a guardian’s court-ordered psychological evaluation in an Indian child’s dependency case.

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

In re Pride — Specific racial-bias allegation entitled prisoner to counsel and discovery

automatic / August 28, 2026

A specific allegation that trial attorneys discussed conviction in racial terms cleared the low thresholds for appointed counsel and Racial Justice Act discovery.

4th District Court of Appeal, Civil Procedure, Labor & Employment Law, Litigation

Hickenbottom v. Medical Solutions — New Contract Theory Did Not Permit a Second Arbitration Motion

automatic / August 26, 2026

A second motion relying on a different arbitration agreement was still a renewed motion because it sought the same order and had to comply with Code of Civil Procedure section 1008.

4th District Court of Appeal, Family Law, Healthcare Law

Marriage of R.M. and P.N. — Parent’s IHSS Caregiver Pay Counts as Support Income

automatic / August 21, 2026

A California Court of Appeal held that IHSS caregiver pay received by a parent counts as gross income when the child’s need established eligibility for the services.

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

People v. Dumbrava — newly discovered evidence permitted a second large-capacity-magazine prosecution

automatic / August 20, 2026

The Fourth District allowed a second magazine-importation prosecution because a later-discovered purchase receipt supplied essential proof unavailable despite due diligence.

4th District Court of Appeal, Healthcare Law, Litigation, Personal Injury & Tort

Nassman v. Superior Court — PREP Act Shields Deliberate COVID-19 Treatment Allocation Decisions

automatic / August 18, 2026

The Fourth District held that PREP Act immunity covers a conscious decision not to administer a COVID-19 countermeasure when the decision reflects purposeful allocation.

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

In re P.C. — Juvenile Courts May Reject Pro Se Filings From Represented Parents

automatic / August 18, 2026

The Fourth District held that juvenile courts generally may reject substantive pro se filings from represented parties and upheld denial of a mother's section 388 petition.

4th District Court of Appeal, Civil Procedure, Healthcare Law, Personal Injury & Tort

Godshall v. Peterson — Persistent symptoms did not conclusively start the medical-malpractice clock

automatic / August 11, 2026

A patient's continuing symptoms after surgery did not establish as a matter of law that she had discovered a negligent incomplete carpal-tunnel release.