Justia California Supreme Court Opinion Summaries

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

The case centers on the City of San José’s attempt to address a substantial unfunded liability in its employee retirement plans. The City, obligated by its charter and state law to maintain actuarially sound pension systems for its employees, decided to refinance this unfunded liability by issuing pension obligation bonds. The proposed bonds would allow the City to pay down the liability at a potentially lower interest rate, thereby aiming to relieve future budgetary pressures. The Howard Jarvis Taxpayers Association and others challenged the plan, arguing that issuing these bonds would create new municipal debt exceeding current annual revenues and, under the California Constitution’s local debt limitation, would require approval by two-thirds of the City’s voters.The Santa Clara County Superior Court found in favor of the City, ruling that the unfunded pension liability was an obligation imposed by law and thus fell within an exception to the local debt limitation. The California Court of Appeal affirmed, though it reasoned that the bonds would not create new debt because the obligation already existed in the form of the unfunded liability.The Supreme Court of California reviewed the case and affirmed the judgment of the Court of Appeal. The Court held that, even if the bonds were considered to create new debt, the City’s obligation to address its unfunded actuarial liability is an obligation imposed by law, not a voluntary undertaking. Therefore, the exception to the local debt limitation applies, and voter approval is not required for the issuance of the pension obligation bonds. The Court clarified that the local debt limitation does not restrict the City’s discretion in choosing how to fulfill its legally imposed pension funding obligations. View "City of San Jose v. Howard Jarvis Taxpayers Assn." on Justia Law

In December 2020, Troy Lee Shaw was found unconscious in his car by police officers and subsequently charged with felony driving under the influence of a drug, possession of a controlled substance, possession of drug paraphernalia, and possession of more than 28.5 grams of marijuana. Shaw admitted to having two prior convictions for gross vehicular manslaughter while intoxicated, stemming from a 2002 incident in which his impaired driving resulted in the deaths of a mother and her young son. These two prior convictions made him eligible for a third-strike sentence under California’s Three Strikes law.Shaw requested that the Placer County Superior Court dismiss one of his prior strikes, arguing that both convictions arose from a single criminal act and citing People v. Vargas (2014) 59 Cal.4th 635. The trial court denied his motion and imposed a third-strike sentence of 25 years to life for the driving under the influence charge, with concurrent six-month sentences for the other possession offenses. On appeal, the California Court of Appeal, Third Appellate District, affirmed the sentence, relying on People v. Rusconi (2015) 236 Cal.App.4th 273, and reasoned that because Shaw’s prior act harmed two victims, it was distinguishable from Vargas, which involved a single victim.The Supreme Court of California reviewed the case and reversed the Court of Appeal’s decision. It held that under the Three Strikes law, when two prior convictions arise from a single criminal act—even if that act harmed multiple victims—a trial court must dismiss one of the strikes for sentencing purposes. The court disapproved the contrary holding in Rusconi and directed the lower court to resentence Shaw consistent with this ruling. View "P. v. Shaw" on Justia Law

A group of homeowners, all over the age of 65, entered into contracts for energy efficiency improvements to their homes under California's Property Assessed Clean Energy (PACE) program. This program allows local governments to offer financing for such improvements, with repayment made through voluntary special assessments added to the homeowners’ property tax bills. Most local governments contracted private companies to administer these PACE loans. The homeowners alleged that these private administrators failed to comply with consumer protection and lending laws applicable to consumer lenders, such as providing required warnings and avoiding prohibited security interests. They filed suit under the Unfair Competition Law, seeking injunctive relief and restitution, including the return of assessment monies paid and prohibitions on future collection of delinquent assessments unless the assessments were removed from their properties.The San Diego County Superior Court sustained the defendants’ demurrers, concluding that the plaintiffs were required to exhaust administrative tax remedies before pursuing their claims in court. The California Court of Appeal affirmed, reasoning that because PACE assessments are collected as part of property taxes and the relief sought would invalidate those assessments, plaintiffs first needed to pay the assessments and seek administrative relief through the established tax refund procedures.The Supreme Court of California reviewed the case to determine whether plaintiffs were required to follow statutory procedures for challenging taxes. The court held that when plaintiffs’ claims effectively seek to invalidate PACE assessments or prevent their future collection, they must first pay the assessments and pursue administrative tax remedies. However, the court also held that plaintiffs are not required to use tax challenge procedures for claims that do not directly or indirectly challenge a tax, such as those solely addressing the administration of the PACE program. The judgment was affirmed in part, reversed in part, and the case remanded to consider whether plaintiffs should be allowed to amend their complaints to state only non-tax-related claims. View "Morgan v. Ygrene Energy Fund, Inc." on Justia Law

The case concerns a mother whose conduct toward her children led to a juvenile court’s jurisdictional finding of child abuse. The events arose after a series of family disputes, culminating in a physical confrontation at the mother's home involving her two older daughters. During the incident, the mother struck her middle daughter with a shovel and brandished a knife, claiming self-defense. As a result, the Los Angeles County Department of Children and Family Services removed the middle and youngest daughters from her care and initiated dependency proceedings.The Los Angeles County Superior Court sustained the petition, finding that the mother’s response was unreasonable and escalated the situation, thus supporting jurisdiction under Welfare and Institutions Code section 300. The court ordered removal of the children, counseling for the mother, and monitored visitation. After subsequent review hearings, the daughters were returned and jurisdiction was terminated. The mother appealed the jurisdictional finding. The California Court of Appeal, Second Appellate District, Division Eight, determined the appeal was moot after termination of jurisdiction and dismissed it, reasoning that the findings were limited and lacked lasting stigma.The Supreme Court of California reviewed whether the mother’s appeal survives mootness when the underlying allegation is reportable to the California Child Abuse Central Index (CACI). The Court held that a parent’s appeal is not moot if the challenged finding is reportable for CACI inclusion, as reversal could remove the parent from the CACI or preserve the right to a grievance hearing. The Court reversed the dismissal of the mother’s appeal and remanded for further proceedings, confirming that demonstration of a legal consequence—such as CACI listing—requires merits review of the appeal. View "In re S.R." on Justia Law

The case arises from the enactment of the 2017 Lesbian, Gay, Bisexual, and Transgender Long-Term Care Facility Residents’ Bill of Rights in California, which, among other things, prohibits 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 plaintiff, an association claiming taxpayer status, challenged this provision before it took effect, arguing that it was facially unconstitutional under the First Amendment.The Sacramento County Superior Court denied the petition for a writ of mandate, finding the pronouns provision to be a permissible, content-neutral restriction narrowly tailored to serve the state’s interest in preventing discrimination and harassment in long-term care facilities. The trial court rejected arguments that the law compelled speech or censored viewpoints, and found no First Amendment violation. On appeal, the California Court of Appeal, Third Appellate District, reversed in part. It held that the provision was content-based, subject to strict scrutiny, and was overinclusive, restricting more speech than necessary to achieve the government’s compelling interest in eliminating discrimination. The appellate court did not address standing.Upon review, the Supreme Court of California first concluded that the plaintiff lacked standing under the current version of Code of Civil Procedure section 526a, as amended in 2018, which limits taxpayer standing to suits against local, not state, entities. Nevertheless, due to the procedural posture and public importance, the court exercised its discretion to decide the merits. The Supreme Court of California held that the pronouns provision is a regulation of discriminatory conduct, not subject to First Amendment scrutiny as speech. Even if intermediate scrutiny applied, the law would be upheld. The court reversed the judgment of the Court of Appeal. View "Taking Offense v. State" on Justia Law

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