Justia California Supreme Court Opinion Summaries

The defendant was convicted and sentenced to death for the murder of Alfonso Martinez during a robbery and kidnapping, and for the attempted murder of Deborah Pizano. The jury also found him guilty of several other crimes, including second-degree robbery and multiple counts of attempted murder related to a separate drive-by shooting. The jury found true the allegations that a principal discharged a firearm causing death or great bodily injury but did not find that the crimes were committed for the benefit of a criminal street gang.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 two incidents, finding that the evidence was cross-admissible and that the charges were of the same class. The jury was instructed on multiple theories of liability, including direct aiding and abetting, natural and probable consequences, and felony murder.The California Supreme Court reviewed the case and reversed the six counts of attempted premeditated murder and the one count of being an active participant in a criminal street gang. The court also vacated the gang-murder special-circumstance true finding. The court affirmed the judgment in all other respects, including the first-degree murder conviction and the death sentence. The court found that the instructional errors related to the natural and probable consequences doctrine and felony murder were harmless beyond a reasonable doubt for the murder conviction but not for the attempted murder convictions. The court also held that the evidence was insufficient to support the gang allegations under the amended statute. View "P. v. Hin" on Justia Law

A landowner sought to confirm that a conveyance occurring before March 4, 1972, created separate parcels under the Subdivision Map Act. The property in question was described in a 1944 deed as Lot 18, Lot 17, and a portion of Lot 16 on an antiquated subdivision map. The landowner argued that this conveyance created three separate parcels, including Lot 18, and sought a certificate of compliance to confirm Lot 18 as a separate legal parcel.The Alameda County Superior Court denied the landowner's petition for a writ of mandate to compel the City of Oakland to issue the certificate. The landowner appealed, and the First Appellate District, Division One, reversed the trial court's decision, concluding that Lot 18 was a separate parcel entitled to the conclusive presumption of legality under section 66412.6(a) of the Subdivision Map Act.The Supreme Court of California reviewed the case and reversed the Court of Appeal's judgment. The court held that the phrase "division of land" in section 66412.6(a) should be interpreted in light of the Act’s general definition of "subdivision" in section 66424. The court concluded that a conveyance does not create multiple parcels merely by referring separately to lots of the contiguous property being conveyed. Since Lot 18 was always conveyed together with contiguous land and never separately, it was not created as a separate parcel under the Act. Therefore, the landowner was not entitled to a certificate of compliance for Lot 18 as a separate legal parcel. View "Cox v. City of Oakland" on Justia Law

In October 2014, Oscar Lopez and Sergio Vidrio stopped their car next to Nestor M. and Noel A.'s car. After a brief exchange, Lopez and Vidrio fired multiple shots, killing Nestor and injuring Noel. Lopez was convicted of first-degree murder, attempted premeditated murder, shooting at an occupied vehicle, and possession of a firearm by a felon. The jury found that Lopez committed the crimes for the benefit of a criminal street gang and used a firearm. Lopez was sentenced to 141 years to life in prison.Lopez appealed, and the Court of Appeal modified his sentence and conditionally reversed the judgment, remanding the case to the trial court for resentencing under Senate Bill Nos. 620 and 1393. While awaiting resentencing, Assembly Bill 333, which amended the gang enhancement statute, was enacted. The trial court declined to apply Assembly Bill 333 retroactively, resentencing Lopez to 101 years to life. Lopez appealed again, and the Court of Appeal held that the judgment was nonfinal for Estrada purposes but that the superior court lacked jurisdiction to apply Assembly Bill 333.The Supreme Court of California reviewed the case and held that Lopez was entitled to the retroactive application of Assembly Bill 333 because his judgment was not final for Estrada purposes. The court clarified that a criminal case is not final until the entire prosecution, including sentencing, is complete. The court reversed the judgment below and remanded for further proceedings consistent with its opinion, allowing Lopez to renew his arguments for resentencing under Senate Bill Nos. 567 and 81. View "P. v. Lopez" on Justia Law

Brittney Collins was convicted of second-degree murder for the death of her two-month-old son, Abel James Norwood, who was killed by his father, Matthew Norwood. Norwood committed the fatal act while Abel was under his care, and Collins was in another room. Collins and Norwood had a history of drug use, and Norwood had previously expressed not wanting the baby and had been abusive towards Collins during her pregnancy. On the day of the incident, Collins was recovering from childbirth complications and was in the front room while Norwood was caring for Abel in the back bedroom. Collins heard a bang but did not check on Abel immediately. Later, she found Abel in a state of medical emergency, and he was taken to the hospital, where he later died from blunt force trauma.The Kern County Superior Court convicted Collins of second-degree murder and assault with force likely to cause great bodily injury. The Court of Appeal affirmed the murder conviction, reasoning that Collins knew of Norwood’s abuse and intentionally failed to protect Abel, including on the day of the fatal act.The Supreme Court of California reviewed the case and held that the evidence was insufficient to convict Collins of second-degree murder. The court clarified that for implied malice murder based on a failure-to-protect theory, the evidence must show that the parent knew to a substantial degree of certainty that a life-endangering act was occurring or about to occur and failed to act in conscious disregard for life. The court found that Collins did not have the requisite mens rea to support a conviction under either a direct aider and abettor theory or a direct perpetrator theory. The court reversed the judgment of the Court of Appeal and remanded with instructions to vacate Collins’s conviction for second-degree murder and resentence her accordingly. View "People v. Collins" on Justia Law

The case involves Taylor Capito, who filed a class action lawsuit against San Jose Healthcare System, LP, also known as Regional Medical Center San Jose, challenging the assessment of Evaluation and Management Services (EMS) fees for two emergency room visits. Capito argued that Regional had a duty to notify emergency room patients about EMS fees beyond listing them in the chargemaster, such as through posted signage or during the patient registration process. She claimed that Regional's failure to do so constituted an unlawful, unfair, or fraudulent business practice under the Unfair Competition Law (UCL) and violated the Consumers Legal Remedies Act (CLRA).The trial court sustained Regional's demurrer without leave to amend, and the Court of Appeal affirmed. The appellate court reasoned that hospitals do not have a duty to disclose EMS fees beyond what is required by the relevant statutory and regulatory framework, following the reasoning in similar cases like Gray v. Dignity Health and Saini v. Sutter Health. The Court of Appeal also affirmed the trial court's order striking the class allegations in Capito's first amended complaint.The Supreme Court of California reviewed the case and affirmed the Court of Appeal's judgment. The court held that hospitals do not have a duty under the UCL or CLRA, beyond their obligations under the relevant statutory and regulatory scheme, to disclose EMS fees prior to treating emergency room patients. The court emphasized that requiring such disclosure would alter the balance of competing interests, including price transparency and the provision of emergency care without regard to cost, as reflected in the multifaceted scheme developed by state and federal authorities. The court also dismissed Capito's appeal from the trial court's order striking her class allegations as moot. View "Capito v. San Jose Healthcare System, LP" on Justia Law

A landlord, JJD-HOV Elk Grove, LLC (JJD), owns a shopping center in Elk Grove, California, and leased space to Jo-Ann Stores, LLC (Jo-Ann). The lease included a cotenancy provision allowing Jo-Ann to pay reduced rent if the number of anchor tenants or overall occupancy fell below a specified threshold. When two anchor tenants closed, Jo-Ann invoked this provision and paid reduced rent for about 20 months until the occupancy threshold was met again.The Sacramento County Superior Court ruled in favor of Jo-Ann, finding the cotenancy provision to be an alternative performance rather than a penalty. The Court of Appeal for the Third Appellate District affirmed this decision, distinguishing the case from a previous ruling in Grand Prospect Partners, L.P. v. Ross Dress For Less, Inc., which found a similar provision to be an unenforceable penalty.The Supreme Court of California reviewed the case to determine the validity of the cotenancy provision. The court held that the provision was a valid form of alternative performance, allowing JJD a realistic choice between accepting lower rent or taking steps to increase occupancy. The court found that the provision did not constitute an unreasonable penalty under California Civil Code section 1671, nor did it result in a forfeiture under section 3275. The court emphasized that contracts should be enforced as written, especially when negotiated by sophisticated parties.The Supreme Court of California affirmed the judgment of the Court of Appeal, upholding the cotenancy provision as a valid and enforceable part of the lease agreement. View "JJD-HOV Elk Grove, LLC v. Jo-Ann Stores, LLC" on Justia Law

In 2018, Richard Allen Mitchell was charged with one felony count of resisting an executive officer and one misdemeanor count of possessing a controlled substance. The prosecution also alleged that Mitchell had a prior "strike" conviction. Five years later, just before the trial was to begin, the trial court reduced the felony charge to a misdemeanor and referred Mitchell to a veterans court program.The Ventura County District Attorney sought review of the trial court's order by filing both an appeal and a petition for writ of mandate in the Court of Appeal. The district attorney argued that the trial court lacked statutory authority to reduce the felony charge to a misdemeanor before sentencing. The Court of Appeal stayed the trial court proceedings and issued an order to show cause. After briefing, the Court of Appeal held that the trial court's order was unauthorized and granted the requested relief, determining that the order was appealable under certain statutory provisions.The Supreme Court of California reviewed the case and disagreed with the Court of Appeal's finding on appealability. The Supreme Court held that the trial court's order was not appealable under the cited statutory provisions because it did not set aside or terminate any portion of the action but merely modified the charges. However, the Supreme Court concluded that the trial court's order was unauthorized and in excess of its jurisdiction, making it subject to writ review. The Supreme Court affirmed the judgment of the Court of Appeal but noted that the trial court's subsequent actions, taken while a temporary stay was in effect, were void. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "People v. Superior Court (Mitchell)" on Justia Law

In this case, a fire destroyed the building where Cory Michael Hoehn and his roommate lived. The building’s insurer, California Capital Insurance Company, determined that careless smoking caused the fire and sued Hoehn and his roommate for negligence, seeking damages. The company attempted to serve Hoehn with the complaint and summons, but the service was allegedly improper. A default judgment was entered against Hoehn in April 2011. In January 2020, Hoehn learned of the default judgment when his wages were garnished and promptly moved to set aside the judgment, claiming he was never properly served.The Placer County Superior Court denied Hoehn’s motion, ruling it was time-barred because it was filed more than two years after the default judgment. The court also found no extrinsic fraud or mistake. The Court of Appeal affirmed, relying on precedent that a motion to vacate a judgment for improper service must be made within two years if the judgment is not void on its face.The Supreme Court of California reviewed the case to determine the validity of the two-year time limit for such motions. The court held that the judicially created rule imposing a two-year limit on motions to vacate void judgments for improper service is not supported by the statute’s text, legislative intent, or sound justification. The court concluded that a motion to vacate a judgment void for lack of proper service under section 473(d) is not subject to a two-year limitation. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Cal. Capital Ins. Co. v. Hoehn" on Justia Law

Plaintiffs Everardo Rodriguez and Judith Arellano purchased a two-year-old car with over 55,000 miles on it, which still had an unexpired manufacturer’s powertrain warranty. Despite numerous repair attempts by the defendant, FCA US, LLC (FCA), the car continued to experience engine problems. Plaintiffs sued FCA under the Song-Beverly Consumer Warranty Act, seeking to enforce the refund-or-replace provision, arguing that their car qualified as a “new motor vehicle” because it was sold with a manufacturer’s new car warranty.The Riverside County Superior Court granted FCA’s motion for summary judgment, concluding that the plaintiffs’ car did not qualify as a “new motor vehicle” under the Act. The Fourth Appellate District, Division Two, affirmed the trial court’s decision, holding that the phrase “other motor vehicle sold with a manufacturer’s new car warranty” does not include previously owned vehicles with some balance remaining on the manufacturer’s express warranty.The Supreme Court of California reviewed the case and affirmed the judgment of the Court of Appeal. The Court held that a motor vehicle purchased with an unexpired manufacturer’s new car warranty does not qualify as a “motor vehicle sold with a manufacturer’s new car warranty” under section 1793.22, subdivision (e)(2) of the Song-Beverly Act unless the new car warranty was issued with the sale. The Court emphasized that the statutory language and the broader context of the Song-Beverly Act support this interpretation, maintaining the distinction between new and used vehicles and their respective warranty protections. View "Rodriguez v. FCA US, LLC" on Justia Law

In this case, the petitioners sought to disqualify a trial court judge based on alleged bias and prejudice. The key facts revolve around a wage-and-hour class action lawsuit initiated by the real parties in interest against the petitioners, their employer. During the litigation, the trial judge made comments suggesting the petitioners were attempting to evade liability through corporate restructuring. These comments were cited by the petitioners as evidence of bias.The Fresno County Superior Court judge struck the petitioners' statement of disqualification as untimely. The petitioners then sought writ review in the Court of Appeal, which held that the nonwaiver provision of section 170.3(b)(2) precluded the application of the timeliness requirement in section 170.3(c)(1) when a party alleges judicial bias or prejudice. The Court of Appeal reasoned that the nonwaiver provision should be interpreted to prohibit all forms of waiver, including implied waiver due to untimeliness.The Supreme Court of California reviewed the case and disagreed with the Court of Appeal's interpretation. The Supreme Court held that the nonwaiver provision of section 170.3(b)(2) applies only to judicial self-disqualification and does not affect the timeliness requirement for party-initiated disqualification attempts under section 170.3(c)(1). The Court emphasized that the statutory text, structure, legislative history, and case law support this interpretation. Consequently, the Supreme Court reversed the Court of Appeal's judgment and remanded the case for the lower court to determine whether the petitioners' statement of disqualification was filed in a timely manner. View "North Am. Title Co. v. Superior Court" on Justia Law