Justia California Supreme Court Opinion Summaries

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Defendant was charged with criminal offenses. Defendant filed a renewed motion to suppress pursuant to Cal. Penal Code 1538.5(i). Judge Vincent Chiarello granted the renewed motion, and the case was dismissed at the People’s request. Thereafter, the People filed a new complaint alleging the same offenses. Defendant filed a motion to suppress, asserting that the proper venue for the motion was before Judge Chiarello pursuant to section 1538.5(p). The matter came before Judge Vanessa Zecher after Judge Jerome Nadler concluded that Judge Chiarello was not available. Judge Zecher denied Defendant’s motion. Defendant filed a renewed motion to suppress, arguing that Judge Chiarello should have heard the relitigated motion to suppress. The trial court concluded that a renewed motion to suppress under section 1538.5(i) was not the proper vehicle for setting aside Judge Zecher’s order. Defendant was found guilty of child pornography. The Court of Appeal affirmed. The Supreme Court reversed, holding (1) a trial court’s discretion to make determinations concerning the availability of judges must be exercised in a manner consistent with constraints imposed by section 1538.5(p); and (2) in this case, the trial court abused its discretion by not taking reasonable measures to ensure compliance with section 1538.5(p), and the error was prejudicial. View "People v. Rodriguez" on Justia Law
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Defendant was charged by criminal complaint with unpermitted use of a suction dredge. Suction dredging is a technique used by miners to remove matter from the bottom of waterways, extract minerals, and return the residue to the water. Defendant demurred, arguing (1) state law aimed at environmental conservation effectively banned suction dredging in California, thereby preventing him from using the only commercially practicable method of extracting gold from his mining claim; and (2) because federal law promoted mining on federal land, the state’s contrary legislation should be preempted. The trial court overruled the demurrer. The Court of Appeal reversed and remanded for consideration of additional evidence and argument. The Supreme Court reversed, holding that Congress did not guarantee miners a right to mine immunized from exercises of the states’ police powers. View "People v. Rinehart" on Justia Law

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After a jury trial, Defendant was convicted of one count each of murder, robbery, burglary, conspiracy to commit robbery, conspiracy to commit burglary, and the unlawful driving or taking of a vehicle. The trial court sentenced Defendant to death for the murder. Defendant appealed, arguing that the trial court erred in excluding certain statements made by the actual killer of the murder victim in which the killer claimed that he acted alone in committing the murder and that Defendant was not involved. Specifically, Defendant asserted that the hearsay statements were admissible as declarations against interest. The Supreme Court reversed the judgment of death, holding that the trial court erred in excluding the testimony and that the error was harmless at the guilt phase but was not harmless at the penalty phase. View "People v. Grimes" on Justia Law
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Plaintiff, a retired employee of the State Department of Justice, filed suit against the State and State Controller’s Office on behalf of herself and a class of resigned and retired state employees who did not receive their final wages within the time period set out in Cal. Labor Code 202 and 203. Under these statutes, an employer must make prompt payment of the final wages owed to an employee who is “discharged” or “quits” his or her employment. The trial court sustained Defendants’ demurrer, concluding that because Plaintiff had “retired” from her job, she had not stated a claim for statutory penalties under section 203. The Court of Appeal reversed, holding that sections 202 and 203 apply when an employee “quits to retire.” The Supreme Court affirmed, holding (1) sections 202 and 203 apply when employees “retire” from their employment; and (2) Plaintiff’s decision to name the State as a defendant rather than the Department of Justice was not a basis for dismissing her suit. View "McLean v. State" on Justia Law

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After a jury trial, Defendant was convicted of both larceny and embezzlement based on the same course of conduct. The Court of Appeal struck Defendant’s larceny conviction, holding that a defendant cannot be convicted of both larceny and embezzlement for the same course of conduct because they not “different offenses” within the meaning of Cal. Penal Code 954. The Supreme Court affirmed, holding (1) larceny and embezzlement are different statements of the same offense within the meaning of section 954; and (2) section 954 does not permit multiple convictions for different statements of the same offense. View "People v. Vidana" on Justia Law
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After a jury trial, Defendant was convicted of two counts of first-degree murder. The jury also found true the special circumstance allegations that Defendant committed multiple murders and that the murders were committed while lying in wait. The jury was unable to reach a penalty verdict, and a second penalty phase was held. The jury returned a verdict of death, and the trial court entered a judgment of death. The Supreme Court (1) reversed the lying-in-wait special-circumstance, holding that the evidence was insufficient to support the inference that Defendant arrived at the murder scene before the victims arrived; (2) reversed the penalty judgment and remanded for retrial of the penalty phase, holding that the trial court’s investigation into the penalty phase retrial jury’s announce deadlock was so intrusive that it prejudicially invaded the deliberations and created a coercive effect on those deliberations; and (3) otherwise affirmed the convictions. View "People v. Nelson" on Justia Law

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This dispute concerned a 1.66-acre strip of Defendants’ land that the City of Perris condemned in order to build a road. The City offered to pay Defendants the agricultural value of the strip, relying on City of Porterville v. Young. The trial court agreed with the City, concluding that Porterville applied in this case and that Defendants were entitled to a stipulated agricultural value of $44,000 for the taking. In so deciding, the trial judge concluded that the City’s dedication requirement was lawful under Nollan v. California Coastal Commission and Dolan v. City of Tigard. The Court of Appeal remanded the case to revisit the legality of the dedication requirement, concluding that the lawfulness of the dedication and requirement under Nollan and Dolan should have been decided by a jury, not a judge. The Supreme Court reversed, holding (1) the constitutionality of a dedication requirement under Nollan and Dolan is a question for a court, rather than a jury; and (2) the project effect rule generally applies, and the Porterville doctrine does not apply, to situations when it is probable at the time a dedication requirement is put in place that the property designated for public use will be included in the project for which the condemnation is sought. Remanded. View "City of Perris v. Stamper" on Justia Law

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A class action employment lawsuit filed against a staffing firm and related companies settled for $19 million. Under the settlement agreement it was agreed that class counsel would request attorney fees of not more than one-third of the gross settlement amount. In seeking the trial court’s approval of the settlement, class counsel sought the maximum fee amount. One class member objected to the proposed settlement, arguing that the projected attorney fee was excessive and class counsel had not provided enough information to evaluate it. The trial court approved the settlement and awarded counsel the requested fee. The Court of Appeal affirmed. The Supreme Court affirmed, holding (1) a trial court is permitted to calculate an attorney fee award from a class action common fund as a percentage of the fund, and the trial court did not abuse its discretion using the percentage of fund method to approve the fee request in this class action; and (2) trial courts have discretion to conduct a lodestar cross-check on a percentage fee, as the court did in this case. View "Laffitte v. Robert Half Int’l, Inc." on Justia Law
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In 1981, Appellant was convicted of murder and sentenced to death. The Supreme Court reversed the penalty verdict. At the penalty retrial, the jury again sentenced Appellant to death, but the trial court modified the sentence to life imprisonment without the possibility of parole. The case was again remanded. On remand, the judge denied the motion to modify the verdict. On appeal, the Supreme Court vacated the death judgment and remanded for another hearing on Appellant’s application to modify the verdict. On remand, the trial court granted Appellant’s request to represent himself but denied his application to modify the verdict. The court then reinstated the death judgment. The Supreme Court vacated the judgment and remanded for another hearing on the application for modification of the death penalty verdict. On remand, the judge denied Appellant’s application to modify the verdict. On appeal, the Supreme Court affirmed the death judgment, holding (1) the trial court did not err in granting Appellant’s request to represent himself; and (2) Appellant forfeited his second claim on appeal. View "People v. Burgener" on Justia Law
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After a jury trial, Defendant was convicted of three counts of first degree murder, two counts of premeditated attempted murder, and other crimes. The jury returned death verdicts as to all three murders, and the trial court sentenced Defendant to death. During guilt phase deliberations, the trial court discharged a juror for refusing to deliberate. On appeal, Defendant argued that the court erred in dismissing the juror. The Supreme Court reversed the judgment in its entirety, holding (1) because there was not a “demonstrable reality” that there was good cause to discharge the juror, the court abused its discretion in removing the juror; and (2) the error was prejudicial and required reversal of the judgment. View "People v. Armstrong" on Justia Law
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