Justia California Supreme Court Opinion Summaries

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

The defendant, a high-ranking member of the Toonerville street gang, was convicted by a jury of three counts of first-degree murder and four counts of attempted murder. The jury found true the special circumstances of multiple murders and that two of the murders were committed for the benefit of a criminal street gang. The original jury deadlocked on the penalty phase, and a retrial resulted in a death sentence.The trial court received a note from two jurors during deliberations, alleging that Juror No. 5 was not deliberating fairly and was biased against the police and prosecution. The court conducted an inquiry, questioning all jurors individually. Several jurors expressed that Juror No. 5 was using speculation as facts, was not making sense, and had a bias against the police. Juror No. 5 denied these allegations, stating he was deliberating fairly and felt the other jurors were ganging up on him. The court ultimately removed Juror No. 5, citing a failure to deliberate and bias against the prosecution.The Supreme Court of California reviewed the case and found that the trial court erred in discharging Juror No. 5. The court concluded that the record did not manifestly support the trial court's findings that Juror No. 5 was refusing to deliberate or was biased against the police and prosecution. The Supreme Court emphasized that Juror No. 5's skepticism towards the prosecution's witnesses was based on evidence presented at trial, including issues of witness credibility and potential coaching by police. The court held that the removal of Juror No. 5 was an abuse of discretion and reversed the judgment, remanding the case for further proceedings. View "P. v. McGhee" on Justia Law

The defendant was convicted by a jury of first-degree murder for the killing of Carlos Cardona, with the special circumstance that the murder was committed during a robbery. The jury also found that the defendant personally used and discharged a firearm, causing great bodily injury or death. At the penalty phase, the jury returned a verdict of death, and the trial court sentenced the defendant to death, with additional terms for the firearm enhancements.The case was automatically appealed. The California Supreme Court reviewed several issues, including the admissibility of hearsay statements made by the defendant's accomplice, the admission of statements by another individual about the firearm used in the murder, and the prosecutor's leading questions to a witness who refused to testify. The court also considered whether the jury instructions on felony murder and accomplice liability were erroneous under current law, and whether the cumulative effect of any errors warranted reversal.The court found no reversible error in the admission of the accomplice's statements, concluding they were admissible as declarations against penal interest and were not testimonial. The court also found that any error in admitting the statements about the firearm was harmless. The prosecutor's leading questions to the uncooperative witness did not violate the defendant's confrontation rights, and the jury instructions, while potentially misleading, did not prejudice the defendant given the jury's findings.The court affirmed the death judgment but remanded the case to the trial court to consider whether to strike the firearm enhancements under the discretion conferred by Senate Bill No. 620, which became effective after the defendant's sentencing. View "P. v. Jasso" on Justia Law

Daniel Escamilla, a certified fugitive recovery agent, searched the home of Lan Ting Wu and Andy Yu Feng Yang in 2012, looking for Yang’s brother, who was wanted on felony drug trafficking charges. Yang, Wu, and their minor son sued Escamilla for assault, battery, trespass, false imprisonment, and emotional distress. Their lawyer, John Vannucci, represented them. Escamilla defended the search as supported by probable cause and cross-complained against Yang for abuse of process. In 2019, a jury found in favor of Escamilla on all claims and awarded him $20,000 in damages. On August 30, 2021, Escamilla filed a malicious prosecution action against Yang, Wu, and Vannucci.The Alameda County Superior Court granted Vannucci’s motion to strike Escamilla’s complaint as a strategic lawsuit against public participation (SLAPP), agreeing that the one-year statute of limitations for claims against attorneys under section 340.6 applied, making the suit time-barred. The Court of Appeal affirmed this decision.The Supreme Court of California reviewed the case to determine the appropriate statute of limitations for a malicious prosecution action against an attorney. The court held that section 340.6, which provides a one-year limitations period for certain suits against attorneys, does not apply to claims brought by parties who were never their clients or the intended beneficiaries of their clients. Instead, the two-year statute of limitations under section 335.1 applies to malicious prosecution claims brought by formerly adverse parties. The court reversed the judgment and remanded the case to the Court of Appeal to consider any unaddressed arguments in the anti-SLAPP motion. View "Escamilla v. Vannucci" on Justia Law

Oscar and Audrey Madrigal purchased a car from Hyundai Motor America in 2011 for $24,172.73. The car allegedly did not function as warranted, and repeated repair attempts failed. The Madrigals requested Hyundai to repurchase the car under the Song-Beverly Consumer Warranty Act, but Hyundai refused, leading the Madrigals to sue for violations of the Act. Hyundai made two settlement offers under California Code of Civil Procedure section 998, which the Madrigals did not accept. On the first day of trial, after the court tentatively ruled against the Madrigals on pretrial motions, the parties settled for $39,000, with the Madrigals retaining the right to seek costs and attorney fees by motion.The Placer County Superior Court ruled that section 998 did not apply because the case settled before trial, and awarded the Madrigals $84,742.50 in attorney fees and $17,681.05 in other costs. Hyundai appealed, arguing that the Madrigals should not recover any postoffer costs because they settled for less than the second 998 offer. The Court of Appeal reversed, holding that section 998’s cost-shifting provisions applied and remanded for further proceedings.The Supreme Court of California affirmed the Court of Appeal’s decision. The Court held that section 998’s cost-shifting provisions apply even when a case settles before trial but after a section 998 offer is rejected or deemed withdrawn. The Court reasoned that the statute’s language and purpose—to encourage the settlement of lawsuits before trial—support this interpretation. The Court clarified that parties are free to agree on their own allocation of costs and fees as part of a settlement agreement, but absent such an agreement, section 998’s default cost-shifting rules apply. View "Madrigal v. Hyundai Motor America" on Justia Law

In 2018, the California Legislature amended the law of homicide, eliminating several theories of liability based on imputed malice and offering relief to those convicted under certain now-invalid theories, such as the natural and probable consequences doctrine. Petitioners seeking relief must file a facially valid petition and make a prima facie showing before a court issues an order to show cause and holds an evidentiary hearing.Ramon Patton, who pleaded guilty to attempted murder and intentionally discharging a firearm, filed a petition for resentencing under the amended law. The People referenced the preliminary hearing transcript, which indicated Patton was the sole shooter, to argue against his prima facie showing. Patton offered no factual counterweight, relying solely on checkbox allegations.The Los Angeles County Superior Court found Patton failed to establish a prima facie case and denied the petition. The Court of Appeal affirmed, noting the preliminary hearing transcript showed Patton was the sole shooter, and his conviction did not implicate an invalid theory.The Supreme Court of California held that a petitioner who offers only conclusory allegations in response to a record of conviction demonstrating the conviction was under a still-valid theory has not made a prima facie showing. The court affirmed the judgment but remanded to allow Patton an opportunity to amend his petition. The court clarified that at the prima facie stage, courts may reference the record of conviction to refute conclusory allegations without engaging in impermissible factfinding. View "P. v. Patton" on Justia Law

Brian Ranger, a maintenance worker for Alamitos Bay Yacht Club, was injured while performing his duties, which included hoisting and mooring vessels. On August 28, 2018, he slipped and fell while boarding a vessel, resulting in serious injuries. Ranger applied for state workers' compensation and subsequently sued the Club under general maritime law, alleging negligence and unseaworthiness.The Los Angeles County Superior Court sustained the Club's demurrer without leave to amend, concluding that Ranger failed to allege facts implicating federal admiralty jurisdiction. Although the court acknowledged the tort occurred on navigable waters, it found that Ranger did not demonstrate his fall posed more than a fanciful risk to maritime commerce. The Court of Appeal affirmed the decision but on different grounds, holding that the Longshore and Harbor Workers’ Compensation Act (LHWCA) displaced general maritime law, making California’s workers’ compensation scheme Ranger’s exclusive remedy.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that the 1984 amendments to the LHWCA, which exclude certain workers from federal workers' compensation if they are covered by state laws, did not abrogate general maritime remedies for those outside the LHWCA’s scope. The court also determined that California’s workers’ compensation exclusive-remedy provision could not deprive Ranger of his substantive federal maritime rights under the supremacy clause of the federal Constitution. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings to address unresolved issues, including whether Ranger’s claims properly invoked admiralty jurisdiction. View "Ranger v. Alamitos Bay Yacht Club" on Justia Law

Michael Ayala, a correctional officer for California’s Department of Corrections and Rehabilitation (CDCR), was injured in a planned attack by inmates. He filed a workers’ compensation claim, asserting that his injuries were due to CDCR’s serious and willful misconduct in failing to address a credible threat of inmate violence. A workers’ compensation administrative law judge (WCJ) initially rejected this claim, but the Workers’ Compensation Appeals Board (Board) found in favor of Ayala, concluding that he was entitled to a 50 percent increase in compensation under Labor Code section 4553 due to CDCR’s serious and willful misconduct.The CDCR did not dispute the finding of serious and willful misconduct but argued that the 50 percent increase should be calculated based on the temporary disability (TD) benefits Ayala would have received under the workers’ compensation law, not the more generous industrial disability leave (IDL) and enhanced industrial disability leave (EIDL) benefits he received under the Government Code. The WCJ agreed with CDCR, but the Board reversed, including IDL and EIDL benefits in the calculation of the increased compensation.The California Supreme Court reviewed the case and agreed with the Court of Appeal, which had reversed the Board’s decision. The Supreme Court held that the term “compensation” under Labor Code section 4553, as defined in section 3207, is limited to benefits provided under the workers’ compensation law. Therefore, the 50 percent increase in compensation for serious and willful misconduct should be calculated based on the TD benefits Ayala was entitled to under the workers’ compensation law, not the IDL and EIDL benefits provided under the Government Code. The judgment of the Court of Appeal was affirmed. View "Dept. of Corrections & Rehabilitation v. Workers' Comp. Appeals Bd." on Justia Law