Case Law Updates: What’s New in California’s Legal Scene?

Case Law Updates: What’s New in California’s Legal Scene?

Estimated reading time: 9 minutes

Norman v. Ross, No. B316971 (Cal. App. 5th Apr. 23, 2024)

Plaintiff Hayley Marie Norman filed a complaint alleging that her idea for a television series was used without her permission to create a sitcom by Tracee Ellis Ross and other defendants. The defendants include Kenya Barris, Brian Dobbins, Artists First, ABC Studios, and Big Breakfast LLC. Norman claimed that she pitched her series idea, which included her involvement as a star, writer, and producer, but the concept was allegedly taken and developed into a spin-off of an existing series, Mixed-ish, by the defendants without her involvement or compensation.

The lawsuit involved several legal claims including breach of implied contract, breach of confidence, and promissory estoppel. In its decision, the Norman Court delved into the complexities of intellectual property in the entertainment industry, particularly how ideas are shared, developed, and credited. The Court’s review focused on whether Norman’s ideas were used without proper compensation and acknowledgment, and the legal responsibilities of the defendants concerning confidential idea submission and contract obligations. 

Ultimately, the Court affirmed the lower court’s judgments in favor of defendants Barris, Dobbins, and ABC, essentially dismissing some of Norman’s claims, but reversed the order regarding Ross and Artists First and remanded the matter with instructions. In rendering this decision, the Court analyzed whether Norman’s claims were sufficient to proceed past a motion to strike under California’s anti-SLAPP statute, which is designed to prevent litigation that might chill valid exercises of the constitutional rights of freedom of speech and petition.

Implications: The outcome indicates a mixed result, where some defendants successfully had claims against them dismissed, while others will face continued litigation to address the specific allegations of using Norman’s intellectual property without authorization. This case highlights the complex nature of intellectual property rights in the entertainment industry in California, particularly regarding how ideas are handled, shared, and compensated.

National Labor Relations Bd. v. Siren Retail Corp. (9th Cir., Apr. 24, 2024, No. No. 22-1969) 

This federal case involved a dispute over the unionization of employees at the Starbucks Reserve Roastery in Seattle. The National Labor Relations Board (NLRB) sought enforcement of its order that required Starbucks to recognize and bargain with the union, Workers United, which sought to represent the employees.

Workers United filed a petition in February 2022 to represent about 90 employees at the location. Due to rising COVID-19 cases, a mail-ballot election was ordered instead of an in-person one, which took place in April 2022. Starbucks challenged the decision and later refused to recognize the union’s victory, leading to allegations of unfair labor practices. The NLRB found Starbucks in violation of Section 8(a)(5) of the National Labor Relations Act for failing to recognize and bargain with the union.

The Ninth Circuit upheld the NLRB’s decision, rejecting Starbucks’ claims that the NLRB lacked jurisdiction and that the mail-ballot election was improperly conducted. The court determined that the NLRB had correctly applied its own law and that the regional director had not abused his discretion in ordering a mail-ballot election under the circumstances presented by the COVID-19 pandemic.

Implications: This decision reinforces the NLRB’s authority and discretion in determining the appropriate methods for union elections, especially under extraordinary circumstances like a pandemic. The ruling may lead to more robust protections for workers seeking to unionize, particularly when health and safety issues complicate traditional election procedures.

The case also highlights the legal responsibilities of employers to comply with the decisions of the NLRB regarding unionization efforts. It sets a precedent that could influence how future disputes over union elections and employer compliance are handled, particularly in situations where public health concerns affect the normal conduct of elections. This decision thus plays a crucial role in shaping the landscape of labor relations and union rights in the United States

Meinecke v. City of Seattle, (9th Cir., Apr. 18, 2024, No. No. 23-35481)

Plaintiff Matthew Meinecke was arrested for his involvement in two incidents during public events in Seattle. Meinecke, a devout Christian, was reading Bible passages at an abortion rally and an LGBTQ pride event when he faced hostility from other attendees. The police intervened and asked him to move to a different location, ultimately arresting him for obstruction when he refused. Meinecke filed suit against the City of Seattle and certain police officers, asserting that his First Amendment rights were violated. The district court denied Meinecke’s request for a preliminary injunction. 

On appeal, the Ninth Circuit reversed the lower court’s decision, finding that the restrictions placed on Meinecke’s speech were indeed content-based, as they were imposed in response to the audience’s reactions. The Court found that these restrictions constituted a “heckler’s veto,” which is generally impermissible under the First Amendment, and directed the district court to issue a preliminary injunction consistent with their findings. In so doing, the Meinecke Court emphasized that any action taken by the government that suppresses speech due to audience reaction violates First Amendment protections.

Implications: Meinecke has significant implications for how public authorities manage free speech, especially in situations where the speaker faces hostility from the public. The decision underscores the principle that law enforcement cannot suppress speech simply to ease their management of public order or to avoid confronting disruptive behaviors by hostile audiences. This reinforces the protection of free speech, particularly in traditional public forums such as streets and parks.

For public authorities, this ruling serves as a reminder of the importance of upholding constitutional rights and the need for training law enforcement on handling situations where speech provokes strong reactions without resorting to censorship or undue restriction. It also highlights the need for municipalities to consider alternative measures that do not infringe upon free speech rights when aiming to maintain public safety and order.

People v. Hurt, (Jan. 22, 2024, C096740)

In August of 2021, police found defendant Sarah Rachel Hurt in possession of suspicious items including a loaded “ghost gun,” methamphetamine, and items suggesting drug sales activities. Additional searches on other dates and at other locations revealed more contraband in Hurt’s possession, including firearms and significant quantities of methamphetamine, all suggesting ongoing involvement in drug trafficking. The incidents took place when Hurt was on bail for prior offenses, leading to additional on-bail enhancements under California Penal Code section 12022.1. 

After the trial court consolidated the charges into one trial, Hurt was convicted on multiple counts, including unlawful possession of methamphetamine while armed, being a felon in possession of a firearm, and possession of a controlled substance for sale. On appeal, Hurt argued that the trial court erred by consolidating the trial for all offenses and admitting evidence of uncharged acts. She also argued against the imposition of multiple on-bail enhancements.

The appeals court affirmed the judgment but modified it by striking one of the on-bail enhancements. It held that while the consolidation of offenses and the admission of evidence were appropriate, only one on-bail enhancement should apply when the defendant is released on one case involving multiple charges.

Implications: The Hurt Court’s decision to allow the consolidation of separate offenses for trial reinforces the judicial preference for efficiency in handling cases with connected offenses. This can impact how similar future cases are tried, particularly in managing multiple charges stemming from related incidents. The ruling also affirmed that evidence of uncharged acts can be admitted to show a pattern or intent, reinforcing the use of such evidence under circumstances similar to those in Hurt’s case. 

The clarification that only one on-bail enhancement applies per case, regardless of the number of charges, is significant. It impacts sentencing in cases where multiple offenses are committed while a defendant is out on bail for another case. This could lead to more nuanced considerations of on-bail enhancements in future cases.

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