Justia California Supreme Court Opinion Summaries

In 2016, the defendant was charged with multiple offenses, including possession of a firearm and controlled substances, with enhancements for prior prison terms. The jury found him guilty on most charges, and he later pled guilty to the remaining charge, admitting the prior-prison-term allegations. The trial court imposed but stayed the one-year enhancements for the prior prison terms. In 2022, the California Department of Corrections and Rehabilitation identified the defendant for resentencing under Penal Code section 1172.75, which invalidates certain prior-prison-term enhancements imposed before January 1, 2020.The trial court initially struck the prior-prison-term enhancements but denied a full resentencing hearing, reasoning that the enhancements were not "imposed" within the meaning of section 1172.75 because they were stayed. The Court of Appeal affirmed, interpreting "imposed" to mean "imposed and executed," thus excluding stayed enhancements from the statute's resentencing provisions.The Supreme Court of California reviewed the case and concluded that Penal Code section 1172.75 applies to enhancements that were imposed, regardless of whether they were executed or stayed. The Court held that the statute's language and legislative intent indicate that any enhancement imposed before January 1, 2020, is invalid, and defendants are entitled to resentencing. The Court reversed the Court of Appeal's judgment and remanded the case for further proceedings consistent with this interpretation. View "P. v. Rhodius" on Justia Law

Eric Wiley pled guilty to making a criminal threat in January 2020, for which the trial court imposed a three-year upper term prison sentence, suspended execution, and placed him on probation for three years. In March 2022, while on probation, Wiley pled guilty to being a felon in possession of a firearm. The trial court found he violated his probation terms, revoked probation, and sentenced him to the upper term of three years for the criminal threat and an additional eight months for the firearm possession.The Court of Appeal upheld Wiley’s sentence, rejecting his Sixth Amendment challenge. The court reasoned that the trial court’s findings regarding the increasing seriousness of Wiley’s prior convictions and his poor performance on probation were permissible under the Almendarez-Torres exception, which allows judges to consider recidivism-related facts without a jury.The Supreme Court of California reviewed the case and held that the trial court violated Wiley’s federal constitutional right to a jury trial by adjudicating underlying facts related to his prior convictions and relying on those conclusions to impose an upper term sentence. The court determined that under the recent U.S. Supreme Court decision in Erlinger v. United States, a judge may only determine the fact of a prior conviction and its elements, not make qualitative assessments about the seriousness of prior convictions or probation performance. The court overruled its previous decisions in People v. Towne and People v. Black, which had allowed broader judicial fact-finding related to recidivism.The Supreme Court of California found the error prejudicial and reversed the judgment of the Court of Appeal, remanding the case for further proceedings consistent with its opinion. View "P. v. Wiley" on Justia Law

The defendant was convicted of first-degree murder, aggravated assault by a life prisoner, and two counts of possession of a deadly weapon by a prisoner. The jury found true special circumstances for a prior murder and an intentional killing while lying in wait. The trial court imposed the death sentence for the murder and stayed the remaining terms. The defendant appealed.In the lower court, the defendant moved to dismiss the charges due to a 27-month pre-charging delay, arguing that it caused prejudice by the loss of two critical defense witnesses. The trial court denied the motion, finding no actual prejudice. The defendant also moved for acquittal under section 1118.1, arguing insufficient evidence of premeditation and lying in wait, which the trial court denied. Additionally, the defendant challenged the admission of evidence under Evidence Code section 1103, which the trial court allowed, and the court's instructions to the jury, which the defendant claimed were erroneous.In the Supreme Court of California, the court reviewed several claims, including the denial of the motion to dismiss for pre-charging delay, the sufficiency of evidence for first-degree murder and lying-in-wait special circumstance, and the admission of evidence under Evidence Code section 1103. The court found no abuse of discretion in the trial court's rulings. The court also addressed claims of prosecutorial misconduct, ineffective assistance of counsel, and instructional errors, finding no reversible error. The court upheld the trial court's decisions and affirmed the judgment, including the death sentence. View "P. v. Barrett" on Justia Law

The defendant was convicted by a jury of first-degree murder for the killing of Carlos Cardona during a robbery. The jury found true the special circumstance that the murder was committed in furtherance of a robbery and that the defendant personally used and discharged a firearm causing death. The jury returned a death verdict, and the trial court sentenced the defendant to death, with additional firearm enhancements.The defendant appealed, raising several issues. The California Supreme Court reviewed the case. The court found no reversible error in the admission of hearsay statements made by the defendant's accomplice, Fabian Perez, to Manuel Rivera, and subsequently relayed by Detective Carrillo. The court also found that the admission of statements by Benjamin Pinela to Jack Duke, although potentially erroneous, was harmless given the other evidence presented. The court rejected the defendant's claim that the prosecutor's leading questions to Pinela violated his confrontation rights, noting that the questions did not purport to be reading a confession and were not devastating to the defense.The court also addressed the defendant's claim that the jury was improperly instructed on felony murder under current law, concluding that any instructional error was harmless beyond a reasonable doubt because the jury's findings on the firearm enhancements necessarily implied that the defendant was the actual killer. The court found no merit in the defendant's argument that the jury was misled by the "equally guilty" language in the accomplice liability instruction, as the jury's verdicts established that the defendant was the actual killer.The court rejected the defendant's claims of ineffective assistance of counsel, prosecutorial misconduct, and challenges to California's death penalty law. The court affirmed the death judgment but remanded the case to allow the trial court to consider whether to strike the firearm enhancements under the discretion conferred by Senate Bill No. 620. View "P. v. Jasso" on Justia Law

Louis Sanchez Emanuel was convicted of first-degree murder under the felony-murder rule after his co-defendant, Jacob Craig Whitley, fatally shot John Cody Sonenberg during a robbery. Emanuel and Whitley had planned to rob Sonenberg of marijuana. During the robbery, Whitley unexpectedly pulled out a gun and shot Sonenberg, who resisted giving up the marijuana. Emanuel was convicted based on his participation in the robbery, which was considered an inherently dangerous felony.The Santa Clara County Superior Court denied Emanuel's petition for resentencing under Senate Bill No. 1437, which narrowed the felony-murder rule to require that a defendant be a major participant in the felony and act with reckless indifference to human life. The trial court found that Emanuel was a major participant and acted with reckless indifference. The Court of Appeal affirmed this decision, agreeing that Emanuel had the ability to prevent the robbery and could have done more to stop Whitley from shooting Sonenberg.The Supreme Court of California reviewed the case and found the evidence insufficient to support a finding that Emanuel acted with reckless indifference to human life. The court noted that Emanuel did not know Whitley was armed or likely to use lethal force, and the robbery was planned to occur in a public place during daylight hours, which could minimize the risk of violence. Emanuel attempted to leave the scene when the situation escalated and did not have a meaningful opportunity to restrain Whitley or aid Sonenberg. The court reversed the judgment of the Court of Appeal and remanded the case to the trial court to grant Emanuel's petition for resentencing, vacate his murder conviction, and resentence him. View "P. v. Emanuel" on Justia Law

A jury convicted the defendant of five counts of first-degree murder after five firefighters died while fighting a wildland fire that the defendant started. The jury also convicted the defendant of 20 counts of arson and 17 counts of possession of an incendiary device, with true findings on arson-murder and multiple-murder special-circumstance allegations. The jury returned a death verdict, and the trial court denied the defendant’s motion to reduce the death verdict, sentencing him to death and 28 years on the remaining convictions.The trial court denied the defendant’s motion for a change of venue, finding that the county’s population was large enough to provide a pool of jurors who were not familiar with the case. The court also excluded a juror who expressed uncertainty about considering both penalty options. The defendant’s challenges to the sufficiency of the evidence supporting his convictions and special-circumstance findings were rejected, as substantial evidence supported the jury’s findings.The court admitted evidence of two uncharged fires to show the defendant’s lack of remorse, finding it relevant to the circumstances of the crime. The court also admitted autopsy photos and victim impact testimony, which the defendant argued were unduly prejudicial. The court found the evidence relevant to the circumstances of the crime and not unduly prejudicial.The defendant’s challenges to California’s death penalty statute and the court’s interpretation thereof were rejected, as the court adhered to its precedent. The court concluded that any assumed instructional error regarding the arson-murder special circumstance was harmless beyond a reasonable doubt. The judgment was affirmed in its entirety. View "P. v. Oyler" on Justia Law

Ty Whitehead suffered a serious head injury during a bicycle training ride for a charity fundraiser due to a large pothole on Skyline Boulevard in Oakland. Whitehead alleged that the City of Oakland breached its statutory duty to maintain a safe roadway. Prior to the ride, Whitehead signed a release and waiver of liability, which included a provision discharging the City from any liability for negligence.The Alameda County Superior Court granted summary judgment in favor of the City, holding that the release was valid and enforceable, thus barring Whitehead’s claim. The court reasoned that the release did not affect the public interest, relying on the multifactor test from Tunkl v. Regents of University of California. The Court of Appeal affirmed the trial court’s decision, also relying on the Tunkl framework.The Supreme Court of California reviewed the case and concluded that the release was against public policy under Civil Code section 1668, which prohibits contracts that exempt a party from responsibility for their own fraud, willful injury, or violation of law. The court held that an agreement to exculpate a party for future violations of a statutory duty designed to protect public safety is unenforceable. The court reversed the judgment of the Court of Appeal and remanded the case for further proceedings, allowing the City to argue the doctrine of primary assumption of risk on remand. View "Whitehead v. City of Oakland" on Justia Law

The defendant was convicted of first-degree murder with special circumstances and sentenced to death for the murder of Alfonso Martinez during a robbery and kidnapping, and for the benefit of a criminal street gang. The jury also convicted him of the attempted murder of Deborah Pizano during the same incident, and for the second-degree robbery of both Martinez and Pizano. Additionally, the defendant was convicted of five counts of attempted murder related to a separate drive-by shooting, along with other related charges.The trial court denied the defendant's motion to suppress his custodial statements, finding that he was properly advised of his Miranda rights and that his waiver was voluntary. The court also denied the defendant's motion to sever the charges related to the American Legion Park incident from those related to the Bedlow Drive shooting, finding that the evidence was cross-admissible and that the charges were of the same class.The California Supreme Court reviewed the case and affirmed the first-degree murder conviction, finding that the jury's special circumstance findings indicated that the jury necessarily found the defendant guilty under a valid theory of felony murder. However, the court reversed the six counts of attempted murder, finding that the jury was instructed on an invalid natural and probable consequences theory, and the error was not harmless beyond a reasonable doubt. The court also vacated the gang-murder special circumstance finding due to insufficient evidence under the amended statute.The court held that the trial court abused its discretion in admitting a rap song found in the defendant's possession, but found the error harmless. The court also found no abuse of discretion in the trial court's denial of the defendant's motions for mistrial and a new trial based on alleged juror misconduct and emotional responses from court personnel during victim impact testimony.The case was remanded for any retrial on the reversed counts and for the trial court to strike the gang-murder special circumstance finding. The court affirmed the judgment in all other respects. View "People v. Hin" on Justia Law

In 1991, Timothy Patric Antonelli was convicted of first-degree murder under the provocative act doctrine for his role in a home invasion robbery where an accomplice was killed by a victim. In 2018, Senate Bill 1437 was enacted, and later amended by Senate Bill 775 in 2021, allowing for resentencing of individuals convicted of murder under theories imputing malice based solely on participation in a crime. Antonelli sought relief under this statute, arguing his conviction was based on such a theory.The trial court summarily denied Antonelli's petition. On appeal, the Court of Appeal affirmed, holding that Antonelli was ineligible for relief under section 1172.6 because the provocative act murder doctrine required personal malice, meaning he was not convicted under a theory imputing malice. The court deemed the jury instructions irrelevant to this determination.The California Supreme Court reviewed the case to resolve a conflict with another appellate decision, People v. Lee, which held that pre-2009 provocative act murder convictions did not necessarily require personal malice. The Supreme Court agreed with Lee, noting that prior to the 2009 decision in People v. Concha, the law allowed for malice to be imputed to a non-provocateur accomplice. Therefore, Antonelli was not categorically ineligible for relief under section 1172.6.The Supreme Court also held that the jury instructions were relevant to determining eligibility for resentencing. The case was remanded to the Court of Appeal to consider whether the trial court's previous denial of Antonelli's petition, based on findings that he was a major participant who acted with reckless indifference to human life, precluded him from seeking relief under the new law. View "P. v. Antonelli" on Justia Law

New England Country Foods, LLC (NECF) alleged that VanLaw Food Products, Inc. (VanLaw) intentionally undercut its business by promising to replicate NECF’s popular barbeque sauce and sell it directly to Trader Joe’s. NECF sued VanLaw in federal court, claiming tortious interference and other claims. The district court dismissed the case based on a clause in their manufacturing contract that limited damages. The United States Court of Appeals for the Ninth Circuit asked the California Supreme Court whether a contract clause that substantially limits damages for intentional wrongdoing is invalid under Civil Code section 1668.The district court dismissed NECF’s complaint, reasoning that the contract allowed only for direct damages and injunctive relief, while NECF sought lost profits, attorneys’ fees, and punitive damages. The court rejected NECF’s argument that section 1668 prevents limiting damages for future intentional conduct, stating it only prevents contracts that completely exempt parties from liability. NECF amended its complaint, but the district court dismissed it with prejudice, citing that parties may limit liability for breach of contract and that the contract did not bar all money damages but limited them to specific types NECF did not suffer. NECF appealed, and the Ninth Circuit sought guidance from the California Supreme Court.The California Supreme Court held that limitations on damages for willful injury to the person or property of another are invalid under section 1668. The court reasoned that the statute’s language and purpose, along with the policy against willful tortious conduct, support this interpretation. The court clarified that section 1668 does not preclude parties from limiting liability for pure breaches of contract absent a violation of an independent duty. The court’s decision ensures that parties cannot contractually limit their liability for intentional torts. View "New England Country Foods v. Vanlaw Food Products" on Justia Law