Justia California Supreme Court Opinion Summaries

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The Supreme Court responded to a question posed by the United States Court of Appeals for the Ninth Circuit by answering that the Court's decision in Dynamex Operations West, Inc. v. Superior Court, 4 Cal.5th 903 (2018), applies retroactively.In Dynamex, the Supreme Court held that the standard commonly known as the "ABC test" applies under California law in determining whether workers should be classified as employees or independent contractors for purposes of obligations imposed by California's wage orders. In concluding that the standard set forth in Dynamex applies retroactively the Supreme Court relied primarily on the fact that Dynamex addressed an issue of first impression and did not change a settled rule upon which the parties had relied. The Court further concluded that the retroactive application of the ABC test to cases pending at the time Dynamex became final was not improper or unfair. View "Vasquez v. Jan-Pro Franchising International, Inc." on Justia Law

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The Supreme Court held that Defendant could be convicted of an attempt to commit trafficking of a minor under Cal. Penal Code 236.1(c) for attempting to recruit as a prostitute "Bella," who was, in fact, an undercover detective.Bella had identified herself to Defendant as a seventeen-year-old girl but was actually an undercover detective. Defendant was convicted of human trafficking of a minor, attempted pimping of a minor, and pandering. The court of appeal reversed Defendant's human trafficking conviction, holding that Defendant could not be convicted under section 236.1(c) but only under the general law of attempt. The Supreme Court reversed and remanded the case, holding that, in light of the statutory language and the state's long-standing application of attempt law, Defendant could be convicted of an attempt under the trafficking statute. View "People v. Moses" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the court of appeal granting Petitioner's petition for habeas corpus relief on the grounds that the Department of Corrections and Rehabilitation did not have the authority to exclude from nonviolent offender parole consideration inmates with prior sex offense convictions requiring registration, holding that this categorial exclusion violates Cal. Const. art. I, 32.After the electorate approved Proposition 57, the Public Safety and Rehabilitation Act of 2016, Petitioner filed a petition for a writ of habeas corpus challenging the Department's determination that he did not qualify for nonviolent offender parole consideration. The trial court denied the petition. The court of appeal granted habeas relief, holding that the amended regulations improperly excluded Petitioner from nonviolent offender parole consideration based on his two prior sex offense convictions. The Supreme Court affirmed, holding (1) nonviolent offender parole eligibility must be based on an inmate's current conviction; and (2) an inmate may not be excluded from nonviolent offender parole consideration based on a current conviction for a registrable felony offense that the Department's regulations have defined as nonviolent. The Court directed the Department to treat as void and repeal California Code of Regulations, 3491(b)(3) and 3496(b). View "In re Gadlin" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the court of appeal ruling that a plaintiff seeking an accounting is not excused from the requirement set out in Cal. Code Civ. Proc. 580(a) to state a specific dollar amount to support a default judgment granting monetary relief, holding that the mere fact that plaintiffs have pleaded an accounting action does not insulate them from the obligation to notify defendants of the dollar amounts sought before such relief may be granted in default.At issue was the fact that in an accounting action a plaintiff does not know the sum certain owed by the defendant and, as such, the fact that a complaint seeking an accounting cannot state the exact amount of damages sought. The Supreme Court concluded that the most reasonable interpretation of section 580 is that the statute requires plaintiffs to have alleged their relief in terms of dollars if they are to receive monetary recovery. The Court expressed no view on the proper method for comparing the amount granted in default with the amount demanded in the complaint. View "Sass v. Cohen" on Justia Law

Posted in: Contracts
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The Supreme Court held that Senate Bill 1437 bars a conviction for second degree murder under the natural and probable consequences theory and that the procedure set forth in Cal. Penal Code 1170.95 is the exclusive mechanism for retroactive relief and that, therefore, the ameliorative provisions of Senate Bill 1437 do not apply to nonfinal judgments on direct appeal.Among other things, Senate Bill 1437 amended Cal. Penal Code 188 to provide that in order to be convicted of murder, a principal in a crime shall act with malice aforethought. At issue in this appeal was the affect of this amendment on the natural and probable consequences doctrine as it applies to second degree murder. The Supreme Court remanded this matter to the court of appeal to affirm Defendant's second degree murder conviction without prejudice to any petition for relief that Defendant may file under section 1170.95, holding (1) section 188(a)(3) bars conviction for second degree murder under a natural and probable consequences theory; and (2) the ameliorative provisions of Senate Bill 1437 do not automatically apply to nonfinal judgments on direct appeal. View "People v. Gentile" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court granting Defendant's petition for a writ of habeas corpus and reinstating Defendant's conviction, holding that trial counsel rendered objectively deficient performance that prejudiced Defendant's case.After a jury trial, Defendant was convicted of second degree murder and sentenced to a term of imprisonment of fifteen years to life. Defendant later filed a petition for a writ of habeas corpus on the grounds of ineffective assistance of counsel and actual innocence. The Supreme Court concluded that Defendant had stated a prima facie case for relief and issued an order to show cause. The trial court vacated Defendant's conviction, finding that Defendant's trial counsel rendered ineffective assistance. The court of appeal reversed, finding no deficient performance. The Supreme Court reversed, holding that counsel's failure to investigate the victim's time of death, in a case where the timeline was crucial, was an error sufficient to undermine confidence in the outcome. View "In re Long" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed Defendant's conviction of fetal murder and affirmed his convictions of ten counts of murder, holding that hearsay was improperly admitted on the question of fetal viability.Defendant was convicted of murdering ten women and one viable fetus and sentenced to death. The primary issues on appeal were whether the trial court erred in admitting statistical evidence about the significance of DNA matches and in admitting hearsay testimony about the fetus's viability. The Supreme Court reversed the fetal murder conviction and otherwise affirmed, holding (1) the challenged testimony admitted in this case was hearsay, and the error in admitting the testimony was prejudicial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Turner" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first degree murder, conspiracy to commit murder and grand theft, mingling a harmful substance with food or drink, and solicitation to commit murder, and sentence of death, holding that any error was not prejudicial.Specifically, the Supreme Court held (1) Defendant's judicial bias claim failed; (2) the erroneous admission of certain statements and the possibly erroneous admission of a certain letter were cumulatively harmless; (3) there was sufficient evidence for the lying-in-wait special circumstance finding and the lying-in-wait first degree murder conviction; (4) any asserted juror misconduct did not, singly or in combination, substantially prejudice the trial's fairness; (5) the trial court did not err in finding that Defendant was competent to stand trial; and (6) Defendant's challenges to the constitutionality of California's Death Penalty Law were unavailing. View "People v. Flinner" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and finding true the special circumstance allegations that the murder was committed while Defendant was engaged in the commission of rape and burglary and sentencing Defendant to death, holding that the errors committed during the trial proceedings were not prejudicial.Specifically, the Supreme Court held (1) assuming for the purposes of argument that a recording of the victim's last telephone call and testimony regarding DNA extraction should not have been admitted, any error was harmless; (2) assuming that portions of correspondence to Defendant were inadmissible hearsay, Defendant was not prejudiced by any error in the admission; (3) the prosecution committed misconduct by eliciting statements from a rebuttal witness during the penalty phase regarding the contents of one of those pieces of correspondence, but the trial court did not abuse its discretion in denying Defendant's related motion for a mistrial; and (4) the cumulative effect of those asserted errors was harmless. View "People v. Schultz" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeal concluding that the Governor acted lawfully when he concurred in the determination of the United States Secretary of the Interior (Interior Secretary) to allow casino-style gaming on tribal trust land in California, holding that California law empowers the Governor to concur.Under the Indian Gaming Regulatory Act, 25 U.S.C. 2701 et seq., the Interior Secretary may permit gaming on certain land taken into federal trust for an Indian tribe so long as the Governor of the state where the land is located concurs. At issue was whether the California Governor has the authority to concur in the Interior Secretary's determination to allow gaming on tribal trust land in California where the California Constitution has not granted explicit authority to concur in the cooperative-federalism scheme. The Supreme Court held that because the California Constitution, as amended in 2000, permits casino-style gaming under certain conditions on Indian and tribal lands and the Legislature imposed no restriction to the Governor's concurrence power, the Governor acted lawfully in concurring in the Interior Secretary's determination. View "United Auburn Indian Community of Auburn Rancheria v. Newsom" on Justia Law