F.People v. Monier
225 Cal. Rptr. 3d 504
| Cal. | 2017Background
- F.P. sued Joseph Monier for sexual battery arising from conduct when she was a child; claims against Monier’s parents were settled before trial. The nonjury trial focused on causation and damages amid evidence that plaintiff’s father also abused her.
- The trial court issued a tentative decision finding Monier liable and announcing intended damages of $305,096; counsel was told to prepare judgment.
- Monier timely requested a statement of decision specifying several controverted issues (special damages, emotional distress, medical expenses, lost wages), but the court signed the judgment two days later without issuing a separate statement of decision.
- The judgment itself recited factual findings and awarded $305,096 (including $250,000 general damages and $55,096 special damages).
- On appeal Monier argued the trial court’s failure to issue a requested statement of decision was reversible per se because it prevented apportionment and meaningful review; the Court of Appeal found error but applied harmless-error review and affirmed.
- The Supreme Court granted review limited to whether failure to issue a requested statement of decision is reversible per se and affirmed the Court of Appeal: such error is generally subject to harmless-error analysis under article VI, §13 and related statutes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a trial court’s failure to issue a timely requested statement of decision is reversible per se | The error does not automatically require reversal when the record (including the judgment) permits meaningful review | The failure is a structural defect (equivalent to no verdict) that defies harmless-error analysis and mandates automatic reversal | Not reversible per se; generally subject to harmless-error review under article VI, §13 and section 475, though rare structural errors may require per se reversal |
Key Cases Cited
- People v. Cahill, 5 Cal.4th 478 (1993) (constitutional reversible‑error provision requires case‑specific prejudice analysis and disfavors categorical automatic reversal)
- Soule v. General Motors Corp., 8 Cal.4th 548 (1994) (civil instructional errors are not categorically reversible; article VI, §13 requires individualized harmless‑error review)
- People v. Breverman, 19 Cal.4th 142 (1998) (overruled automatic reversal rule for certain omitted jury instructions; applied harmless‑error analysis)
- Winslow v. Gohransen, 88 Cal. 450 (1891) (failure to find on an issue is not grounds for reversal if omitted finding could only be adverse to appellant)
- McCourtney v. Fortune, 57 Cal. 617 (1881) (no reversal for omitted findings absent prejudice under then‑applicable statutory prejudice rule)
- Russel v. Armador, 2 Cal. 305 (1852) (early decision suggesting decisions in writing were mandatory; discussed in historical context)