Justia California Supreme Court Opinion Summaries

The case concerns a mother whose two children were the subject of dependency proceedings after one child, Z.G., was found with methamphetamine in her system. The San Bernardino County Children and Family Services initiated proceedings based on allegations of parental substance abuse and domestic violence. Initially, both parents engaged in services, and the children were returned to their custody. However, after the birth of a second child, A.G., new dependency petitions were filed, and both children remained in the mother's care while the father lost custody due to ongoing concerns. Eventually, after the mother allegedly stopped cooperating with her case plan and drug testing, the children were removed from her custody. The department then moved to terminate reunification services and set a permanency planning hearing.At the disposition hearing, the juvenile court terminated reunification services for both children and set a permanency planning hearing, even though the mother had not yet received reunification services for A.G. The mother’s counsel failed to assert her statutory right to reunification services for A.G. and did not file a writ petition to challenge the termination of services or the setting of the hearing. The juvenile court subsequently terminated the mother's parental rights as to both children following a finding that they were likely to be adopted. The Court of Appeal affirmed the termination, reasoning that a finding of likely adoption was sufficient and that it lacked jurisdiction to consider challenges to the earlier order.The Supreme Court of California held that a juvenile court may not terminate parental rights based solely on a finding of likely adoption; it must also make an additional statutory finding, such as that reunification services were provided, bypassed, or properly terminated. The Court further held that the mother received ineffective assistance of counsel because her attorney failed to assert her right to reunification services and to challenge the relevant orders. The Court reversed the orders terminating parental rights and remanded for further proceedings. View "In re Z.G." on Justia Law

A property owner sought permission from San Luis Obispo County to construct single-family homes on several lots in Los Osos, an already developed coastal community. The County granted the permit, concluding the homes were an appropriate use under local zoning. However, the California Coastal Commission appealed the County’s decision to itself and denied the permit, asserting that it had appellate jurisdiction because the proposed development was situated in a sensitive coastal resource area (SCRA) under the County’s local coastal program (LCP), and because the site was designated for more than one principal permitted use.After the Commission's denial, the property owner filed a petition for a writ of administrative mandate in San Luis Obispo County Superior Court, contending the Commission lacked appellate jurisdiction on both grounds. The superior court sided with the Commission on the SCRA issue but rejected the Commission’s alternative jurisdictional basis. On appeal, the California Court of Appeal affirmed, holding the Commission properly exercised appellate jurisdiction based on the SCRA designation and did not address the alternative argument.The Supreme Court of California reviewed the case and clarified several important principles. It held that courts must exercise independent judgment—not deferential review—when determining the Commission’s appellate jurisdiction if the matter turns on legal interpretation of an LCP. The court further held that, where the Commission and a local government offer conflicting interpretations of an LCP, judicial deference to either is unwarranted when no interpretive advantage is clearly established. Examining the LCP, the court found that the proposed development was not in an SCRA as designated by the LCP. It also ruled the Commission does not have appellate jurisdiction solely because a site has multiple principal permitted uses; jurisdiction arises only if the proposed use is not among those principal permitted. The judgment of the Court of Appeal was reversed. View "Shear Development Co. v. Cal. Coastal Com." on Justia Law

Two defendants were implicated in the 1985 kidnapping, rape, and murder of a woman in California. Evidence showed that they were previously involved in a string of armed robberies and planned to escape law enforcement by stealing a vehicle from a shopping center parking lot. They kidnapped the victim, drove her hundreds of miles, sexually assaulted her, and killed her before disposing of her body in a canal. Forensic evidence, including eyewitness testimony and DNA analysis, linked both men to the crimes. Both were arrested years later after advances in DNA technology allowed for retesting of biological evidence.The Sacramento County Superior Court tried the defendants together with separate juries. Each was found guilty of murder, rape, and kidnapping, with special circumstances for kidnapping-murder, robbery-murder, and rape-murder. One defendant was also convicted of sodomy with a sodomy-murder special circumstance. Both were sentenced to death after separate penalty phase trials. The court also imposed various prison terms and restitution fines, staying the execution of the prison sentences.The Supreme Court of California reviewed the case on automatic appeal. It affirmed the convictions of both defendants and the death sentence for one. However, it reversed the death sentence for the second defendant, finding that subsequent changes in the law—specifically regarding the competency of defendants with mental illness to represent themselves—required reversal of his sentence, including the death judgment. The court also vacated any balance of restitution fines for both defendants, pursuant to recent statutory amendments. The case was remanded for further proceedings as to the sentencing of the second defendant. View "P. v. Bertsch" on Justia Law

The case arose from the killing of Rachel Deen and Calipatria Police Chief J. Leonard Speer by Omar Richard Deen on April 10, 1998. After an argument at his mother’s equipment yard, Deen shot both victims and fled to Mexico, where he was apprehended the same day and confessed. Evidence presented at trial included testimony about Deen’s strained relationship with his mother, prior threats, disputes over his father’s estate, and his mental health history, including diagnoses of severe thought disorder and schizophrenia, as well as methamphetamine abuse. The prosecution introduced evidence of premeditation and financial motive, while the defense focused on Deen’s mental state and substance-induced impairment.The Imperial County Superior Court conducted a four-phase trial—competency, guilt, sanity, and penalty. Deen was found competent by a separate jury and judge. The main trial jury convicted him of both murders, found true special circumstances (financial gain and killing a police officer in the line of duty), and returned a death verdict. Deen raised multiple issues on appeal, including the denial of several challenges for cause during jury selection, particularly regarding Juror No. 5, who had close associations with Chief Speer and law enforcement, had heard details of the case from police sources, and expressed difficulty in being impartial.The Supreme Court of California found that the trial court erred by denying the challenge for cause as to Juror No. 5. The trial court had misunderstood its authority, relying too heavily on the juror’s assurances of impartiality instead of independently determining whether actual bias existed under the applicable statutes. The Supreme Court held that the trial court must objectively consider the totality of circumstances regarding potential juror bias and remanded for a new trial, reversing the judgment in its entirety. View "P. v. Deen" on Justia Law

During an incident in Sonoma County, the defendant aimed an unloaded firearm at police officers, racked the slide, and pulled the trigger, but the weapon did not discharge. Officers later recovered the unloaded gun from the defendant’s vehicle. The defendant was charged and convicted of knowingly resisting an executive officer by the use of force or violence, in violation of California Penal Code section 69, subdivision (a). At trial, the defendant argued that assault is a lesser included offense of resisting an officer by force or violence, and that because his firearm was unloaded, he lacked the present ability to inflict injury, precluding a conviction for assault and thus for resisting under section 69(a).The Sonoma County Superior Court denied the defendant’s motion for acquittal and declined to instruct the jury on assault as a lesser included offense. The jury convicted the defendant on one count of resisting an officer but was unable to reach a verdict on two other counts. On appeal, the California Court of Appeal, First Appellate District, Division One, affirmed the conviction. The appellate court rejected the argument that assault is a lesser included offense of resisting an officer by force or violence, reasoning that section 69 does not include the “present ability” requirement found in assault, nor does its language require force or violence to be directed “upon the person” of an officer.The Supreme Court of California reviewed the case to resolve a conflict with an earlier decision, People v. Brown. The Supreme Court held that assault is not a lesser included offense of resisting an officer by force or violence under section 69(a), because this offense does not require a present ability to cause injury. The court affirmed the judgment of the Court of Appeal and expressly disapproved People v. Brown to the extent it was inconsistent with this holding. View "P. v. Morgan" on Justia Law

A prospective employee, Fuentes, applied for work at Empire Nissan and signed an “Applicant Statement and Agreement” that included a mandatory arbitration provision. The document was printed in an extremely small, blurry font that was nearly unreadable and contained a lengthy, complex paragraph filled with legal jargon and statutory references. Fuentes was given only five minutes to review the entire employment packet, was not offered an opportunity to ask questions, and did not receive a copy. Later, she signed two confidentiality agreements that appeared to allow Empire Nissan to seek judicial remedies, not mentioning arbitration. After working at Empire Nissan for over two years, Fuentes was terminated following a request for extended medical leave and subsequently sued the company for wrongful discharge and related claims.Empire Nissan moved to compel arbitration. The Los Angeles County Superior Court denied the motion, finding the arbitration agreement unconscionable due to its illegibility, complexity, and the lack of a meaningful opportunity for review or negotiation, establishing a high degree of procedural unconscionability and a low to moderate degree of substantive unconscionability. The court also found that the confidentiality agreements appeared to carve out certain claims from arbitration for Empire Nissan. The Second District Court of Appeal reversed, holding that “tiny and unreadable print” concerns procedural unconscionability only—not substantive—and, interpreting the agreements as requiring arbitration, found no substantive unconscionability and declined to address procedural unconscionability.The Supreme Court of California reviewed the case and held that a contract’s format, such as illegibility, is generally irrelevant to substantive unconscionability, which concerns the fairness of the contract’s terms. However, courts must more closely scrutinize the terms of contracts that are difficult to read for unfairness or one-sidedness when there is high procedural unconscionability. The Court reversed the Court of Appeal’s judgment and remanded the matter to the trial court for further proceedings consistent with its clarified standards. View "Fuentes v. Empire Nissan" on Justia Law

During a routine traffic stop for a minor violation, Sacramento Police officers pulled over a vehicle driven by Kayla Sepulveda, with Davonyae Sellers as a passenger. The officers observed a rolling tray on the backseat and what they described as “weed crumbs” scattered on the rear floorboard behind and under the passenger seat. The occupants were cooperative, and there was no suspicion of impaired driving. After having Sepulveda and Sellers exit the vehicle, the officers searched the car and Sepulveda’s purse, finding only 0.36 grams of loose marijuana on the floor and an unregistered firearm near the front passenger seat. Sellers was charged with unlawful firearm possession and moved to suppress the gun evidence, arguing the search was unlawful.A magistrate judge denied Sellers’s suppression motion, reasoning that the presence of loose marijuana constituted “contraband” under the open container law, thus providing probable cause for the search. The Sacramento County Superior Court affirmed this decision. The Court of Appeal for the Third Appellate District also upheld the search, holding that any marijuana not in a sealed container violated the open container statute and, alternatively, that the totality of circumstances supported probable cause for the search. One justice dissented, arguing the law required the presence of an actual container and that the facts did not support a violation or probable cause.The Supreme Court of California reversed the Court of Appeal’s decision. It held that a violation of Health and Safety Code section 11362.3, subdivision (a)(4) requires marijuana in a vehicle to be of a usable quantity, in imminently usable condition, and readily accessible to an occupant. The small amount of loose marijuana on the rear floor in this case was neither imminently usable nor readily accessible. The court further held that the circumstances did not provide probable cause for a warrantless vehicle search. The case was remanded for further proceedings. View "Sellers v. Super. Ct." on Justia Law

The case concerns a California statute that makes it a crime to knowingly file a false allegation of police misconduct and requires complainants to sign an advisory warning of potential criminal liability before their complaint is accepted. The Los Angeles Police Protective League sought an injunction compelling the City of Los Angeles to enforce this advisory requirement. The City had previously entered into a consent decree with the federal government prohibiting enforcement of the advisory, and even after the consent decree expired, continued not to require the advisory due to concerns about the statute’s constitutionality.The Superior Court of Los Angeles County, relying on the California Supreme Court’s earlier decision in People v. Stanistreet, granted the injunction and ordered the City to require the statutory advisory. The California Court of Appeal affirmed, adhering to Stanistreet’s reasoning that had upheld the statute’s constitutionality. The City then petitioned to the Supreme Court of California, arguing that subsequent federal decisions—especially Chaker v. Crogan by the Ninth Circuit—cast serious doubt on the continuing validity of Stanistreet and the constitutionality of the statute.Reviewing the case, the Supreme Court of California reconsidered its prior Stanistreet decision in light of more recent U.S. Supreme Court rulings, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that the statutory scheme—combining criminal penalties with a mandatory and prominently worded advisory—created a consequential risk of chilling truthful or well-intentioned complaints of police misconduct. The court concluded that this risk triggered heightened constitutional scrutiny under the First Amendment. The statute failed intermediate scrutiny because it was not narrowly tailored and burdened substantially more speech than necessary to serve the state’s legitimate interests. The court therefore reversed the judgment of the Court of Appeal. View "L.A. Police Protective League v. City of L.A." on Justia Law

The case concerns a dispute between a nonprofit legal services organization and a city over the city's handling of requests for public records related to law enforcement activities. The nonprofit submitted several requests seeking information and body-worn camera footage from police encounters with homeless individuals. The city released some records but withheld others, invoking statutory exemptions for law enforcement investigations. The nonprofit later learned that some older bodycam footage had been destroyed pursuant to the city's retention policy, which required footage to be kept for only one year. This prompted the nonprofit to file suit, alleging inadequate searches, improper withholding, untimely responses, and destruction of records while requests were pending.Reviewing the matter, the Santa Clara County Superior Court granted partial declaratory relief, finding the city violated the California Public Records Act (CPRA) in its response to certain requests, but declined to issue a writ of mandate or find a records retention requirement under the CPRA. The Sixth Appellate District Court of Appeal affirmed in part and reversed in part, holding the matter moot because all responsive, nonexempt records had been disclosed, and further concluding that the CPRA does not require agencies to preserve records withheld as exempt for three years after an exemption is claimed.The California Supreme Court reviewed two key issues. First, it held that declaratory relief under the CPRA is available even when all existing responsive, nonexempt records have been disclosed, at least where such relief would resolve ongoing disputes that could affect future records requests or conduct. Second, the court affirmed that the CPRA does not impose a duty on public agencies to preserve documents responsive to public records requests that have been withheld as exempt, rejecting the argument for a three-year retention period. The judgment was reversed in part and remanded for further proceedings consistent with these holdings. View "City of Gilroy v. Superior Court" on Justia Law

One defendant in this case was a high-ranking member of the Varrio Fallbrook Locos gang and the Mexican Mafia, while a codefendant acted as a secretary within the gang structure. In December 2013, the defendant participated in a meeting regarding methamphetamine sales, which resulted in the violent assault of another gang member, A.C., after accusations of unpaid debts. Following the assault, the defendant attempted to prevent A.C. from testifying and conspired to arrange the murder of another gang affiliate. The defendant was convicted by a jury of multiple offenses, including assault with a deadly weapon, conspiracy to commit murder, and conspiracy to dissuade a witness, among others. The trial court imposed a lengthy prison sentence and ordered the defendant to pay various fines and ancillary costs, despite defense counsel’s request to consider the defendant’s inability to pay.The Court of Appeal for the Fourth Appellate District, Division One, reviewed the monetary orders. It held that the trial court should have considered the defendant’s ability to pay before imposing ancillary costs but rejected the argument that an ability-to-pay finding was required for punitive fines. The appellate court clarified that fines could still be challenged under the excessive fines clauses of the federal and state constitutions and remanded the case for resentencing and further proceedings regarding the fines and costs.The Supreme Court of California reviewed the case to resolve inconsistent approaches among lower courts concerning court-ordered financial obligations. The Court held that challenges to the amount of criminal fines must be reviewed under the excessive fines clauses of the United States and California Constitutions. Separately, the Court held that, upon request, a sentencing court must consider a defendant’s inability to pay before imposing court operations and facilities assessments, as failing to do so violates equal protection. The judgment was reversed in part and remanded for further proceedings consistent with these holdings. View "P. v. Kopp" on Justia Law