Hall v. County (2026)

Case details
Full caption
Anthony Jama Hall v. Superior Court of Sacramento County
Country
United States
Jurisdiction
California (CA)
Court
California Supreme Court
Decided
2026
Disposition
Affirmed
Majority
Robie (J.) (unanimous Court)
ANTHONY JAMA HALL, Plaintiff and Appellant, v. THE..., Not Reported in... © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 521913Not Officially Published(Cal. Rules of Court, Rules 8.1105 and 8.1110, 8.1115)Only the Westlaw citation is currently available.California Rules of Court, rule 8.1115, restrictscitation of unpublished opinions in California courts.NOT TO BE PUBLISHEDCourt of Appeal, Third District, California.(Sacramento).ANTHONY JAMA HALL, Plaintiff and Appellant,v.THE SUPERIOR COURT OFSACRAMENTO COUNTY, Defendant;SACRAMENTO COUNTY BOARD OFSUPERVISORS, Real Party in Interest and Respondent.C100087|Filed 2/25/2026Editor's Note: This decision contains discussion of citationreferences that are incorrect or do not actually exist. Theseinvalid citations appeared in the original court opinion andhave been preserved as written since they are part of theofficial record. Any links to these invalid citations have beenremoved.(Super. Ct. No. 34-2023-80004085-CU-WM-GDS)OpinionROBIE, J.*1 Appellant Anthony Jama Hall appeals the trial court'sorder denying his petition for writ of mandate seeking toreverse a prior order from the same court. We affirm.FACTUAL AND PROCEDURAL BACKGROUND1Appellant was arrested and incarcerated in December 2018;the charges were later dismissed. Appellant initiated agovernment tort claim related to the arrest against real partyin interest Sacramento County Board of Supervisors.2 Thesuperior court found his claim was untimely and deniedappellant's petition for relief from a late filing of claim onNovember 9, 2022.In 2023, appellant filed a second petition with the superiorcourt, this one for a writ of mandate asking the court to“[v]acate its [t]entative [r]uling [i]ssued November 8, 2022,”grant appellant's “[p]etition for ‘[r]ehearing,’ ” and considerthe merits of appellant's government tort act claim. Appellantstated he was taking “advantage of an avenue that was andremains available as the time to [a]ppeal the [e]rroneous[d]ecision has [l]apsed, and therefore [the] writ of [m]andate[p]etition filed herein is [a]dequate.” On November 17, 2023,the trial court, through a different judge than in the first case,denied this petition finding, “A superior court has no power,authority, or jurisdiction to issue a writ of mandate againstitself.”Appellant appeals.DISCUSSIONAppellant contends, “The trial court erroneously held that itlacked the power ... to issue a writ of mandate against itself,citing the incorrect proposition that a writ of mandate mayonly be issued to an inferior tribunal.” We disagree.We review this legal issue de novo. (Earnest v. Commissionon Teacher Credentialing (2023) 90 Cal.App.5th 62, 73.)Code of Civil Procedure section 1085, subdivision (a) states:“A writ of mandate may be issued by any court to anyinferior tribunal, corporation, board, or person, to compel theperformance of an act which the law specially enjoins ... andfrom which the party is unlawfully precluded by that inferiortribunal, corporation, board, or person.” (Italics added.)The statute's plain language permits a court to issue a writ onlyto an “inferior tribunal,” necessarily disallowing a superiorcourt from issuing a writ against itself. (Code Civ. Proc.,§ 1085, subd. (a); see Legg v. Superior Court (1958) 156Cal.App.2d 723, 725 [“Obviously a petition for mandamusdirected by the [s]uperior [c]ourt to itself will not lie”]; Peoplev. Davis (2014) 226 Cal.App.4th 1353, 1371 [“The superiorcourt does not have the authority or jurisdiction to issuemandamus or prohibition against itself”]; Alvarez v. SuperiorCourt (2010) 183 Cal.App.4th 969, 982-983 [explaining “thegeneral rule that a judge may not overrule a judge of equal
ANTHONY JAMA HALL, Plaintiff and Appellant, v. THE..., Not Reported in... © 2026 Thomson Reuters. No claim to original U.S. Government Works.2authority”].) The trial court therefore did not err in denyingappellant's petition on this ground.*2 Appellant also seeks to litigate the merits of hisgovernment tort claim and related petition for relief froma late filing of claim. But appellant concedes he did nottimely appeal the court's order in that matter. Appellant'sfailure to timely appeal that order forecloses our jurisdictionto review. (Norman I. Krug Real Estate Investments, Inc. v.Praszker (1990) 220 Cal.App.3d 35, 46 [“ ‘If a judgmentor order is appealable, an aggrieved party must file a timelyappeal or forever lose the opportunity to obtain appellatereview’ ”]; People v. Ramirez (2008) 159 Cal.App.4th 1412,1420-1421 [“ ‘A timely notice of appeal, as a general matter,is “essential to appellate jurisdiction” ’ ”].) The scope of ourreview is therefore limited to whether the trial court properlydenied appellant's petition for writ of mandate to review itsprior order in appellant's government tort claim case. For thereasons stated above, we conclude it did.We finally address appellant's citations to several nonexistentsources. For example, appellant argues, “[T]he trial court'srefusal to consider attachments to a late claim petition[is] a violation of due process rights and an abuse ofdiscretion, as provided under Government Code section911.5[, subdivision ](b) and contrary to the holding in Countyof Sacramento v. Superior Court (2014) 232 Cal.App.4th305.” (Boldface omitted, italics added.) Neither of these legalauthorities exist. Real party in interest identifies appellant'sfabricated legal authorities but appellant persists, stating in hisreply, “The authorities cited by [a]ppellant in the [o]pening[b]rief are accurate, controlling, and properly cited, andeach supports the legal propositions advanced.” (Boldfaceomitted.) This is demonstrably false because at least 11authorities cited in appellant's briefs are either nonexistent orwholly inaccurate for the propositions asserted.We admonish appellant for fabricating legal authorities orfailing to review citations created by generative artificialintelligence that tend to “ ‘hallucinate’ ” legal authority.(Noland v. Land of the Free L.P. (2025) 114 Cal.App.5th426, 443-444 [detailing the increased usage of generativeartificial intelligence and its tendency to hallucinate fakecases].) “Pro[pria] per[sona] litigants are held to the samestandards as attorneys.” (Kobayashi v. Superior Court (2009)175 Cal.App.4th 536, 543.) And “ ‘ “[h]onesty in dealingwith the courts is of paramount importance, and misleading ajudge is, regardless of motives, a serious offense.” ’ ” (Peoplev. Alvarez (2025) 114 Cal.App.5th 1115, 1119.) Appellantis warned that by using fabricated legal authorities in legalfilings, his filings may be stricken (Cal. Rules of Court,rule 8.204(e)(2)(B)), and he could be subject to sanctions.(Noland, at p. 445 [“relying on fabricated legal authority issanctionable”].)DISPOSITIONThe judgment is affirmed. Real party in interest shall recoverits costs on appeal. (Cal. Rules of Court, rule 8.278(a)(1)-(2).)We concur:EARL, P. J.MESIWALA, J.All CitationsNot Reported in Cal.Rptr., 2026 WL 521913Footnotes1We deny appellant's request for judicial notice because he failed to attach the documents in his request.(Ross v. Creel Printing & Publishing Co. (2002) 100 Cal.App.4th 736, 744 [“The burden is on the party seekingjudicial notice to provide sufficient information to allow the court to take judicial notice”].) We also deny asmoot Sacramento County Board of Supervisors's request for judicial notice of appellant's notice of appealbecause this document is already in our records.
ANTHONY JAMA HALL, Plaintiff and Appellant, v. THE..., Not Reported in... © 2026 Thomson Reuters. No claim to original U.S. Government Works.32Real party in interest stated in filings with the trial court and in its brief it was erroneously named by appellantand should be the County of Sacramento.End of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
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