Justia California Supreme Court Opinion Summaries

A police union sought an injunction requiring the City of Los Angeles to comply with a state law mandating that anyone filing a complaint of police misconduct must first read and sign an advisory warning that knowingly filing a false complaint is a crime. The law, Penal Code section 148.6(a), singles out complaints against peace officers for this treatment, and its legislative history shows it was enacted to address concerns about reputational and professional harm to officers from false complaints, as well as the administrative burden of investigating such claims.Previously, the Los Angeles County Superior Court granted the injunction, finding itself bound by the California Supreme Court’s earlier decision in People v. Stanistreet, which had upheld the constitutionality of section 148.6(a). The California Court of Appeal affirmed, also relying on Stanistreet, despite several federal court decisions—including Chaker v. Crogan and Hamilton v. City of San Bernardino—holding that the statute violated the First Amendment.The Supreme Court of California reviewed the case and reconsidered its prior holding in light of subsequent U.S. Supreme Court decisions, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that section 148.6(a) is a content-based regulation within a proscribable category of speech (defamation) but, as drafted, it incidentally burdens protected speech by deterring truthful or well-intentioned complaints of police misconduct. Applying intermediate scrutiny, the court found the statute was not narrowly tailored to serve the government’s interests and burdened substantially more speech than necessary. The Supreme Court of California reversed the Court of Appeal’s judgment and remanded the case for further proceedings. View "L.A. Police Protective League v. City of L.A." on Justia Law

In 2017, the California Legislature enacted the LGBT Long-Term Care Facility Residents’ Bill of Rights, which included a provision prohibiting staff at long-term care facilities from willfully and repeatedly failing to use a resident’s preferred name or pronouns after being clearly informed of them, when such conduct is based on the resident’s sexual orientation, gender identity, gender expression, or HIV status. The law was designed to address documented discrimination and mistreatment of LGBT seniors in long-term care settings, where residents are particularly vulnerable and often lack alternative support networks.Before the pronouns provision took effect, Taking Offense, an association opposed to laws requiring recognition of transgender identities, filed a petition for writ of mandate in Sacramento County Superior Court, seeking to block enforcement of the provision as facially unconstitutional under the First Amendment. The trial court denied the petition, finding the law to be a permissible, narrowly tailored regulation serving a significant state interest in preventing discrimination. On appeal, the California Court of Appeal, Third Appellate District, reversed in part, holding that the pronouns provision was a content-based restriction on speech that failed strict scrutiny and was therefore facially unconstitutional.The Supreme Court of California reviewed the case. The State argued for the first time that Taking Offense lacked taxpayer standing under Code of Civil Procedure section 526a, as amended in 2018, which now limits such standing to suits against local, not state, entities. The Supreme Court agreed but exercised its discretion to address the merits due to the public importance of the constitutional question. The Court held that the pronouns provision regulates discriminatory conduct that only incidentally affects speech, is not subject to First Amendment scrutiny as an abridgment of free speech, and, even if intermediate scrutiny applied, the provision would satisfy that standard. The Court reversed the Court of Appeal’s judgment. View "Taking Offense v. State of Cal." on Justia Law

In 2009, a defendant was sentenced to an indeterminate term of 28 years to life under California’s original Three Strikes law after his third felony conviction, which was not classified as serious or violent. He also received three one-year enhancements for prior prison terms. In 2012, California voters passed the Three Strikes Reform Act (Proposition 36), which limited indeterminate life sentences to cases where the third strike was serious or violent, and allowed those serving indeterminate sentences for nonserious, nonviolent felonies to petition for resentencing, subject to a discretionary public safety determination by the court.After the Reform Act, the defendant petitioned for resentencing under section 1170.126, but the Santa Barbara County Superior Court denied the petition, finding his release would pose an unreasonable risk to public safety. The California Court of Appeal affirmed this decision. In 2021, the Legislature enacted Senate Bill No. 483, which retroactively invalidated certain prior prison term enhancements and required courts to recall and resentence affected defendants, applying any changes in law that reduce sentences. The defendant sought resentencing under this new law, and the trial court resentenced him to a determinate eight-year term. The Santa Barbara District Attorney challenged this, arguing that the new law unconstitutionally amended the voter-enacted Reform Act by bypassing its public safety requirement. The Court of Appeal agreed and reversed the trial court’s decision.The Supreme Court of California reviewed whether Penal Code section 1172.75, as applied, unconstitutionally amended the Reform Act. The Court held that section 1172.75 must be interpreted to incorporate the Reform Act’s discretionary public safety determination for nonserious, nonviolent third strike offenders seeking resentencing. This interpretation harmonizes the statutes and avoids constitutional conflict, allowing the revised penalty provisions to apply only if the court finds resentencing does not pose an unreasonable risk to public safety. The Court reversed the Court of Appeal and remanded for further proceedings consistent with this holding. View "P. v. Guevara" on Justia Law

This case involves a challenge to a tariff adopted by the California Public Utilities Commission (Commission) that significantly reduced the compensation utilities pay to customers who generate electricity through rooftop solar panels and export excess energy to the grid. Petitioners, including environmental organizations, argued that the Commission’s tariff was inconsistent with Public Utilities Code section 2827.1, which requires the Commission to ensure that compensation for customer-generators reflects the costs and benefits of renewable generation and supports sustainable growth, particularly among disadvantaged communities.The First Appellate District, Division Three, of the California Court of Appeal granted a writ of review and affirmed the Commission’s decision. In doing so, the Court of Appeal applied a highly deferential standard of review derived from the California Supreme Court’s decision in Greyhound Lines, Inc. v. Public Utilities Com., asking only whether the Commission’s interpretation of the statute bore a reasonable relation to statutory purposes and language. The court concluded that the Commission’s approach satisfied this standard and declined to engage in a more searching review of the statutory interpretation.The Supreme Court of California reviewed the case to determine whether the deferential Greyhound standard remains appropriate following legislative amendments to the Public Utilities Code. The Supreme Court held that, for Commission decisions not pertaining solely to water corporations, the deferential Greyhound standard no longer applies. Instead, courts must independently review the Commission’s statutory interpretations under the standards set forth in Public Utilities Code sections 1757 and 1757.1, which parallel the review of other administrative agencies. The Supreme Court reversed the judgment of the Court of Appeal and remanded the case for further proceedings consistent with this less deferential standard. View "Center for Biological Diversity, Inc. v. Public Utilities Com." on Justia Law

The case involved a defendant who was convicted by a jury of first-degree murder and two counts of attempted murder, all arising from a gang-related shooting in Visalia, California. The prosecution presented evidence that the defendant was a member of the North Side Visalia gang and that he shot individuals he believed to be rival gang members, resulting in one death and serious injury to another. The prosecution’s case relied heavily on expert testimony to establish the defendant’s gang membership and the gang-related nature of the crimes, as well as evidence of prior offenses by the defendant and other gang members. The defense argued that the shooting was not premeditated or gang-motivated, but rather stemmed from a personal dispute, and presented evidence that the defendant had renounced gang affiliation.The Tulare County Superior Court denied the defendant’s pretrial motion to recuse the entire District Attorney’s Office after his former defense attorney joined that office, finding that an effective ethical wall had been established. At trial, the jury found the defendant guilty on all counts, found true the gang enhancements and the gang-murder special circumstance, and returned a death verdict. The trial court entered judgment accordingly.On automatic appeal, the Supreme Court of California reviewed the case. The court held that, due to subsequent legal developments—specifically, its decision in People v. Sanchez and legislative amendments to Penal Code section 186.22 by Assembly Bill 333—the evidence was insufficient to support the gang enhancements and the gang-murder special circumstance. As a result, the court reversed the gang-related findings and the death judgment. The court also ordered a limited remand to allow the defendant to further develop his claim that his trial counsel violated his Sixth Amendment right of autonomy over the defense, as articulated in McCoy v. Louisiana. The convictions and death judgment were reversed and the case remanded for further proceedings. View "P. v. Cardenas" on Justia Law

A group of family members was attacked after being mistaken for rival gang members by individuals associated with the Dragon Family/Dragon Family Junior gang in Orange County. After being followed from a restaurant, their car was cornered in a cul-de-sac, and a shooter fired multiple shots into the vehicle, killing a 13-year-old and injuring two others. Several gang members were apprehended soon after, while the defendant was arrested months later in Arizona. At trial, accomplice testimony, forensic evidence, and writings attributed to the defendant were presented to establish his identity as the shooter and his gang affiliation.The Orange County Superior Court jury convicted the defendant of murder, two counts of attempted murder, and active participation in a criminal street gang, with various firearm and gang-related enhancements. The jury found true a special circumstance that the murder was committed to further gang activities and returned a death verdict. The trial court denied the defendant’s motion to modify the verdict. The defendant raised several claims on appeal, including challenges to jury selection under Batson and Wheeler, the sufficiency of accomplice corroboration, the handling of third-party culpability evidence, the admission of creative writings, the denial of a continuance, and alleged prosecutorial misconduct.The Supreme Court of California reviewed the case. It held that retroactive changes to the law under Assembly Bill 333, which heightened the requirements for proving a “pattern of criminal gang activity,” applied to the defendant’s case. The Court found that the jury had not been instructed under the new, stricter standard, and the Attorney General conceded this error was prejudicial. As a result, the conviction for active gang participation, all gang enhancements, and the gang-murder special circumstance were reversed, requiring reversal of the death judgment. The Court otherwise affirmed the judgment, finding no merit in the defendant’s other claims. The case was remanded for further proceedings. View "P. v. Aguirre" on Justia Law

A hotel property owner challenged the Los Angeles County Assessor’s valuation of its property for tax purposes, arguing that two specific revenue streams should have been excluded from the income-based assessment. The first was a 14 percent nightly occupancy tax assigned by the City of Los Angeles to the original developer as an incentive to construct the hotel, and the second was a one-time “key money” payment made by Marriott International to the owner for the right to manage and brand the hotel for 50 years. The owner claimed these revenues derived from nontaxable intangible assets—contractual rights—and thus should not be included in the property’s taxable value.The Los Angeles County Assessment Appeals Board ruled in favor of the County, finding both the occupancy tax and key money payments were properly included as income from the property itself. The Board also found insufficient evidence to isolate the value of certain enterprise assets (customer goodwill, food and beverage operations, and workforce) from the real estate value. The Los Angeles County Superior Court affirmed the Board’s decision on the occupancy tax and key money, but remanded for further proceedings on the valuation of the enterprise assets. The California Court of Appeal reversed the trial court on the first two issues, holding that the occupancy tax and key money should be excluded, but affirmed the remand for valuation of the enterprise assets.The Supreme Court of California reviewed the case and held that the Assessor was permitted to include both the occupancy tax and key money payments in the hotel’s assessed value, as these revenues represent income from the use of the property itself rather than from enterprise activity. The Court affirmed the lower courts’ decision to remand for further proceedings regarding the valuation and deduction of the three identified enterprise assets. The judgment was reversed in part and affirmed in part. View "Olympic and Ga. Partners, LLC v. County of L.A." on Justia Law

Two defendants, both members of a criminal street gang, were involved in a shooting incident outside a liquor store in Hemet, California, in December 2020. They were convicted by a jury of attempted murder, active participation in a criminal street gang, unlawful possession of a firearm, assault with a semiautomatic firearm, and willful discharge of a firearm at an occupied vehicle. The jury also found true several gang and firearm enhancements. In a subsequent bench trial, the court found that both defendants had prior 2015 convictions for unlawful possession of a firearm with a gang enhancement, and one defendant had an additional prior conviction for attempted burglary. These prior convictions were used to impose enhanced sentences under California’s Three Strikes law and the five-year prior serious felony enhancement.On appeal, after the passage of Assembly Bill 333, which narrowed the definitions and requirements for gang enhancements under Penal Code section 186.22, the Attorney General conceded that the new law applied retroactively to nonfinal judgments. The California Court of Appeal reversed the convictions and enhancements related to gang participation and remanded for possible retrial under the new standards. However, the Court of Appeal held that Assembly Bill 333 did not apply to the determination of whether the defendants’ 2015 convictions qualified as prior serious felonies or strikes, reasoning that such application would improperly amend voter-approved initiatives that set the list of serious felonies as of a specific date.The Supreme Court of California reviewed the case and held that Assembly Bill 333 does apply to the determination of whether a prior conviction qualifies as a serious felony under section 1192.7(c)(28) for purposes of the Three Strikes law and prior serious felony enhancements. The Court concluded that current law governs this determination, and that such application does not unconstitutionally amend any ballot initiative. The Court vacated the true findings on the prior serious felony convictions and remanded for retrial under the amended law. View "P. v. Fletcher" on Justia Law

A worker in Humboldt County performed maintenance and other services for several years on property managed by his employers, in exchange for free rent but without additional pay or benefits. After the arrangement ended, he filed claims with the Labor Commissioner, asserting he was an employee entitled to unpaid wages, liquidated damages, and penalties, including under California’s Paid Sick Leave law. The employers contended he was an independent contractor, but the Labor Commissioner found he was an employee and awarded him compensation.The employers appealed the Labor Commissioner’s decision to the Humboldt County Superior Court, which conducted a de novo bench trial. The court agreed that the worker was an employee and awarded unpaid wages, penalties, and interest. However, it denied liquidated damages, finding the employers acted in good faith based on their mutual understanding with the worker that he would work for rent and not as an employee. The court also rejected the worker’s claim for penalties under the Paid Sick Leave law, concluding such claims could not be raised in court during an employer’s appeal of a Labor Commissioner ruling. The worker appealed, and the California Court of Appeal affirmed the superior court’s rulings on both the liquidated damages and Paid Sick Leave issues.The Supreme Court of California reviewed the case. It held, first, that to establish a good faith defense to liquidated damages for minimum wage violations, an employer must show it made a reasonable attempt to determine the requirements of minimum wage law; mere ignorance of the law is insufficient. Second, the court held that an employee may raise a claim under the Paid Sick Leave law in the context of an employer’s appeal to the superior court of a Labor Commissioner ruling. The Supreme Court reversed the Court of Appeal’s judgment and remanded for further proceedings. View "Iloff v. LaPaille" on Justia Law

The case concerns a defendant who was convicted by a jury of the first degree murders of two young children, Tyler and Dylan, as well as assaulting Dylan, a child under eight, with force likely to produce great bodily injury resulting in death. The defendant was in romantic relationships with each child’s mother and lived with them at the time of the children’s deaths. Both children suffered extensive physical abuse and fatal injuries while in the defendant’s care. Medical and forensic evidence indicated repeated, severe trauma consistent with child abuse. The defendant denied responsibility, suggesting others may have caused the injuries, and presented evidence attempting to cast doubt on the mothers’ fitness as parents.After the initial trial in the Kern County Superior Court, the defendant was convicted and sentenced to death, but the trial court granted a new trial due to juror misconduct. At retrial, the jury again convicted the defendant on all counts and returned a death verdict, which the trial court entered as judgment. The defendant was also sentenced to 25 years to life for the assault charge, with that term stayed.The Supreme Court of California automatically reviewed the case. The defendant raised numerous claims, including challenges to the sufficiency of the evidence, denial of motions for change of venue and to sever charges, alleged juror misconduct, evidentiary rulings, and constitutional challenges to California’s death penalty statute. The court found the evidence sufficient to support the convictions for first degree murder, both as deliberate and premeditated and as murder by torture. The court also found no reversible error in the trial court’s evidentiary and procedural rulings, and rejected the constitutional challenges to the death penalty scheme.The Supreme Court of California’s main holding was to strike a $200 parole revocation fine imposed under Penal Code section 1202.45, as the defendant’s sentence did not include a period of parole. In all other respects, the court affirmed the judgment, including the convictions and the death sentence. View "P. v. Alvarez" on Justia Law