Justia California Supreme Court Opinion Summaries

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Petitioner committed murder when he was sixteen years old and was sentenced to life without the possibility of parole. The sentencing court did not give due consideration to the factors in Miller v. Alabama in imposing this sentence. Petitioner did not pursue an appeal. Here, Petitioner filed a petition for a writ of habeas corpus seeking a resentencing hearing at which the court would properly integrate the Miller factors into its sentencing calculus. The superior court granted habeas corpus relief. The Court of Appeal reversed, concluding that Petitioner could seek recall of his sentence and resentencing to a term of life with the opportunity for parole pursuant to Cal. Penal Code 1170(d)(2), which remedied any constitutional defect in Petitioner’s sentence and therefore precluded habeas corpus relief. The Supreme Court reversed, holding that section 1170(d)(2) does not provide an adequate remedy at law for Miller error, and Petitioner may obtain a Miller resentencing as a form of habeas corpus relief. Remanded for a resentencing hearing. View "In re Kristopher Kirchner" on Justia Law

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Section 391.7’s prefiling process applies to self-represented plaintiffs who have been declared vexatious litigants. Plaintiff initiated an unlawful detainer action against Defendant. Defendant largely represented herself in the case. The trial court issued a writ of possession. Defendant appealed. In a separately filed action in which Defendant was the plaintiff and appellant, the Court of Appeal declared Defendant a vexatious litigant plaintiff. The court also entered a prefiling order under Cal. Code Civ. Proc. 391.7(c) that prohibited Defendant from filing any new litigation in California courts. In the instant case, the trial court’s appellate division dismissed Defendant’s consolidated appeals. Defendant petitioned the Court of Appeal for a writ of mandate directing the appellate division in the consolidated appeals to decide the appeals on their merits. The Court of Appeal ordered the appellate division to vacate its order dismissing Defendant’s appeals, concluding that a defendant’s status as a vexatious litigant plaintiff in one matter cannot limit that same defendant’s ability to pursue her appeal in an action she did not initiate as a plaintiff. The Supreme Court affirmed, holding that 391.7’s prefiling requirements do not apply to declared vexatious litigants who are self-represented defendants appealing from an adverse judgment in litigation they did not initiate. View "John v. Superior Court of Los Angeles County" on Justia Law
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After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a witness, murder, in the commission of kidnapping, and lying in weight. The jury also found Defendant guilty of kidnapping, rape, and dissuading a witness. After a penalty trial, the jury returned a verdict of death for the murder conviction. The trial court imposed a judgment of death. The Supreme Court reversed the lying-in-wait special-circumstance finding for insufficient evidence but otherwise affirmed the judgment, holding (1) the evidence did not support the lying-in-wait special-circumstance finding, but no other prejudicial error occurred during the guilt phase of trial; and (2) there was no prejudicial error during the penalty phase of trial. View "Poeple v. Becerrada" on Justia Law

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Plaintiff filed suit against Defendants, alleging that she was unlawfully terminated from employment. The complaint set forth two causes of action, one based on Cal. Health & Safety Code 1278.5(g) and one based on wrongful termination in violation of public policy. At issue in these proceedings was whether there was a right to a jury trial as to Plaintiff’s cause of action authorized by section 1278.5(g). The trial court denied a jury trial on the section 1278.5(g) cause of action. Plaintiff then filed a petition for writ of mandate in the Court of Appeal. The Court of Appeal ruled in Plaintiff’s favor, holding, inter alia, that the trial court erred in determining that there was no right to a jury trial in an action based on section 1278.5(g). The Supreme Court affirmed in part and reversed in part, holding (1) a trial court ruling denying a requested jury trial may be challenged prior to trial by a petition for an extraordinary writ; but (2) there is no right to a jury trial in a cause of action for retaliatory termination under section 1278.5(g) when a plaintiff seeks damages in such an action. Remanded. View "Shaw v. Superior Court" on Justia Law

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Plaintiff and Defendants entered into a business relationship embodied in a series of oral and written agreements. Two of the written agreements contained clauses subjecting disputes arising out of the agreements to the sole jurisdiction of Florida courts. Plaintiff later brought this action for breach of contract, fraud, and related causes of action. Citing the two Florida forum selection clauses, Defendants moved to dismiss the action on grounds of forum non conveniens. The trial court granted the motion. Defendants then moved to recover $84,640 in attorney fees incurred in connection with the motion to dismiss, relying on an attorney fee clause in the agreements. The trial court denied the motion, ruling that Defendants were not the prevailing party for purposes of Cal. Civ. Code 1717 because the merits of the contract issues were still under litigation. The Court of Appeal affirmed. The Supreme Court affirmed, holding that the trial court acted within its discretion in denying Defendants’ motion for attorney fees because Defendants’ success in moving the litigation to Florida did not make them the prevailing party as a matter of law under section 1717. View "DisputeSuite.com, LLC v. Scoreinc.com" on Justia Law

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Plaintiff opened a credit card account with Defendant Citibank, N.A. and purchased a credit protector plan. Defendant later amended the original agreement by adding an arbitration provision. The provision waived the right to seek public injunctive relief in any forum. The arbitration provision became effective in 2001. In 2011, Plaintiff filed this class action based on Defendant’s marketing of the Plan and the handling of a claim she made under it when she lost her job, alleging claims under the Consumers Legal Remedies Act (CLRA), the unfair competition law (UCL), and the false advertising law. Defendant petitioned to compel Plaintiff to arbitrate her claims on an individual basis pursuant to the arbitration provision. Based on the Broughton-Cruz rule, the trial court ordered Plaintiff to arbitrate all claims other than those for injunctive relief under the UCL, the CLRA, and the false advertising law. The Court of Appeal reversed and remanded for the trial court to order all of Plaintiff’s claims to arbitration, concluding that the Federal Arbitration Act preempts the Broughton-Cruz rule. The Supreme Court reversed, holding that the arbitration provision was invalid and unenforceable because it waived Plaintiff’s right to seek public injunctive relief in any forum. Remanded. View "McGill v. Citibank, N.A." on Justia Law

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This California Environmental Quality Act (CEQA) dispute centered on whether an environmental impact report (EIR) must identify areas that might qualify as environmentally sensitive habitat areas (ESHA) under the California Coastal Act and account for those areas in its analysis of mitigation measures and project alternatives. The City of Newport Beach approved a project for the development of a parcel known as Banning Beach. Banning Ranch Conservancy (BRC) sought a writ of mandate to set aside the approval, alleging (1) the EIR was inadequate, and (2) the City violated a general plan provision by failing to work with the California Coastal Commission to identify wetlands and habitats. The trial court found the EIR sufficient but concluded that the general plan required the City to cooperate with the Coastal Commission before approving the project. The Court of Appeal (1) agreed that the EIR complied with CEQA requirements; but (2) reversed on the general plan issue. The Supreme Court reversed and granted BRC relief on its CEQA claim, holding (1) CEQA requires an EIR to identify areas that might qualify as ESHA under the Coastal Act; and (2) the City’s failure to discuss ESHA requirements and impacts was neither insubstantial nor merely technical. View "Banning Ranch Conservancy v. City of Newport Beach" on Justia Law

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Defendant, a Canadian citizen, pleaded guilty to a drug possession charge. Defendant filed a motion to withdraw the plea on grounds of mistake or ignorance. The trial court denied the motion, concluding that it was insufficient because Defendant had received the standard statutory advisement that a criminal conviction may have the consequences of deportation. The Court of Appeal affirmed. The Supreme Court reversed, holding that receipt of the standard statutory advisement that a criminal conviction “may” have adverse immigration consequences does not bar a noncitizen defendant from seeking to withdraw a guilty plea on that basis. Remanded to permit the trial court to determine whether Defendant has shown good cause for withdrawing his plea. View "People v. Patterson" on Justia Law

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At issue in this case was whether theft of access card account information is one of the crimes eligible for reduced punishment under Proposition 47. In 2014, Defendant pleaded no contest to a felony. Voters subsequently approved Proposition 47, which reduced the punishment for several crimes previously punished as felonies. In 2015, Petitioner filed a resentencing petition. The superior court denied the petition, concluding that Proposition 47 does not apply to theft of access card information. The Court of Appeal reversed. The Supreme Court affirmed, holding that theft of access card account information is one of the crimes eligible for reduced punishment under Proposition 47. View "People v. Romanowski" on Justia Law
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Under the terms of a spendthrift trust established by his parents, Defendant was entitled to receive over one million dollars, all to be paid out of trust principal. Before the trust’s first payment, Defendant filed for bankruptcy. The bankruptcy trustee sought a declaratory judgment on the extent of the bankruptcy trustee’s interest in the trust. The bankruptcy court concluded that the bankruptcy trustee, standing as a hypothetical lien creditor, could reach twenty-five percent of Defendant’s interest in the trust. The bankruptcy appellate panel affirmed. On appeal, the Court of Appeals for the Ninth Circuit asked the Supreme Court to clarify the relevant provisions of the California Probate Code. The Supreme Court held (1) where a spendthrift trust pays the beneficiary entirely out of principal, the California Probate Code does not limit a bankruptcy estate’s access to the trust to twenty-five percent of the beneficiary’s interest; and (2) with limited exceptions, a general creditor may reach a sum up to the full amount of any distributions that are currently due and payable to the beneficiary even though they are still in the trustee’s hands and separately may reach a sum up to twenty-five percent of any payments that are anticipated to be made to the beneficiary. View "Carmack v. Reynolds" on Justia Law