Year in Review: California Supreme Court

While the prior court year was a time of transition for the California Supreme Court, in which Chief Justice Patricia Guerrero assumed leadership of the judicial branch and Associate Justice Kelli Evans joined the court, the 2023-2024 court year reflected stability and focus on the work of the court.

During the 2023-2024 court year, in addition to resolving thousands of routine filings, the court issued written opinions grappling with legal issues arising out of voter initiative measures, the COVID-19 pandemic, environmental law, and equal protection, among other subjects.

"I am proud of the work of the court, and I want to thank my fellow justices and court staff for their deep commitment to fairness, equality, and access to justice. I look forward to continuing our work on behalf of all Californians," said Chief Justice Guerrero.

The Work of the Court

The court issued 58 written majority opinions during the September 2023-August 2024 court year (see chart and "High-Profile Cases" below).

The court received 5,013 filings, including 3,079 petitions for review, and resolved 4,784 filings, including 3,039 petitions for review.

Back on the Road

The court in December marked its return to hearing oral argument in Los Angeles, a tradition put on hold for nearly four years during the COVID-19 pandemic.

The court's tradition of hearing oral argument in Los Angeles-as one of three recurring locations for oral argument, along with Sacramento and San Francisco-dates to 1878.

The court also has resumed its practice of conducting special oral argument sessions in locations across the state, with the October 2024 oral argument to take place in Fresno. These special sessions provide students and other members of the public with opportunities to witness oral argument at nearby venues.

Strengthening State Bar Protections

The court also approved measures to further guard against conflicts of interest involving members of the State Bar Board of Trustees and the State Bar Court. In November, the court authorized changes to rules 9.11 and 9.90 of the California Rules of Court to ensure that candidates for the Board of Trustees and the State Bar Court, the latter of which rules on attorney disciplinary matters, are screened for actual and potential conflicts of interest. Relatedly, Chief Justice Patricia Guerrero approved an updated and amended conflict of interest code for the Board of Trustees.

In Memoriam: Associate Justice Edward A. Panelli

Former Associate Justice Edward A. Panelli died in July at age 92. Justice Panelli was an associate justice on the court from 1985 to 1994, after previously serving as a judge at the Santa Clara County Superior Court, as an associate justice at the First District Court of Appeal, and as presiding justice at the Sixth District Court of Appeal. Justice Panelli was a mentor to many attorneys, including several future justices and judges, during his long career as a practitioner, judge, mediator, and instructor. The court will conduct an in memoriam session at a future oral argument to recognize Justice Panelli and his contributions to California law.

High-Profile Cases

Castellanos v. State of California involved a challenge to Proposition 22, a voter initiative passed in 2020. The court unanimously decided that a provision within this measure that classifies drivers for app-based transportation or delivery companies as independent contractors rather than employees if certain conditions are met does not conflict with the Legislature's plenary authority under the state constitution "to create, and enforce a complete system of workers' compensation, by appropriate legislation." The court reasoned that the constitution's grant of authority to the Legislature "does not preclude the electorate from exercising its initiative power to legislate on matters affecting workers' compensation."

In Legislature v. Weber, the court considered whether a ballot proposition seeking to change the California Constitution could properly be placed before the voters by a citizen's initiative. Among other things, the proposition at issue would have prohibited the Legislature from raising taxes without voter approval and restricted the ability of state and local governments to delegate fee-setting authority to their executive or administrative officers. The court held that the ballot proposition could not be placed before voters by citizen's initiative, but rather had to follow the procedures for a constitutional revision, because the proposition's proposed changes "operate together to fundamentally rework the fiscal underpinnings of our government at every level" and would therefore "substantially alter our framework of government."

In Another Planet Entertainment v. Vigilant Insurance Co., the court agreed with "the vast majority of courts nationwide" and rejected a business's attempt to claim insurance coverage for "direct physical loss or damage to property" based on allegations that the presence of the COVID-19 virus led to pandemic-era business closures. The court held that "direct physical loss or damage to property requires a distinct, demonstrable physical alteration to property," with the mere presence of the COVID-19 virus not meeting that standard.

By a 5-2 vote, the court ruled in People v. Hardin that denying youth offender parole hearings to young adults convicted of special circumstance murder and sentenced to life without the possibility of parole did not violate equal protection. While leaving open "the possibility of other as-applied challenges to the statute," the majority in Hardin determined that the defendant had "not demonstrated that the Legislature acted irrationally in declining to grant the possibility of parole to young adult offenders convicted of special circumstance murder, even as it has granted youth offender hearings to young adults convicted of other offenses." The court also clarified in Hardin how an equal protection analysis should proceed, explaining that "when plaintiffs challenge laws drawing distinctions between identifiable groups or classes of persons, on the basis that the distinctions drawn are inconsistent with equal protection, courts no longer need to ask at the threshold whether the two groups are similarly situated for purposes of the law in question. The only pertinent inquiry is whether the challenged difference in treatment is adequately justified under the applicable standard of review."

In re Dezi C., also decided by a 5-2 vote, resolved a split of authority among Courts of Appeal regarding a recurring issue in juvenile dependency matters. Addressing how reviewing courts should approach a child welfare agency's failure to undertake an adequate inquiry under the California Indian Child Welfare Act into whether a child is, or may be, an Indian child, the majority concluded that "[w]hen there is an inadequate inquiry and the record is underdeveloped, it is impossible for reviewing courts to assess prejudice." The majority therefore held that an inadequate "inquiry requires conditional reversal of the juvenile court's order terminating parental rights with directions to the agency to conduct an adequate inquiry, supported by record documentation."

The court considered the impact of a new statute on a University of California, Berkeley housing project and development plan in Make UC a Good Neighbor v. The Regents of the University of California. In 2023, the Legislature passed a law specifying "noise generated by project occupants and their guests" did not constitute "a significant effect on the environment for residential projects" under the California Environmental Quality Act. In light of the new law, the court concluded that an environmental impact report was not inadequate for having failed to study the potential noisiness of future students at the university in connection with the housing project and the development plan.

Summary of Key Court Year Statistics
[September 1, 2023 - August 31, 2024] (pdf)

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