Justia California Supreme Court Opinion Summaries
Cervantes v. Bianco
A group of Riverside County residents, having voted in the November 2025 special election on Proposition 50, challenged the actions of the county sheriff’s department. The sheriff, responding to claims by a community group of a significant discrepancy between unofficial poll worker ballot intake logs and the Registrar of Voters’ final certified count, obtained search warrants and seized approximately 650,000 voted ballots. The Registrar of Voters maintained any discrepancy was minimal and within normal bounds, and no party disputed that the alleged discrepancy could not have changed the election outcome.After the sheriff’s department seized and began examining the ballots, the voters filed a petition for a writ of mandate directly in the Supreme Court of California. They argued the sheriff’s actions violated the Elections Code’s strict rules regarding the custody of ballots and requested the court order the immediate return of the ballots to the Registrar. The Registrar did not oppose this relief, and both the Secretary of State and Attorney General supported the petitioners’ position. The sheriff argued his actions were lawful as part of a criminal investigation supported by search warrants.The Supreme Court of California held that the seizure and removal of the ballots from the Registrar’s custody was unlawful under Elections Code section 15551, subdivision (d). The Court explained that the Elections Code specifically requires that voted ballots remain in the custody of the elections official at all times and that this rule applies even during criminal investigations. The Court issued a peremptory writ of mandate directing the sheriff to return all packages containing voted ballots to the Registrar and to refrain from further handling of the ballots, but denied the request for additional relief regarding non-ballot election materials and chain-of-custody reporting. The Court’s order superseded the previously issued superior court search warrants to the extent of any conflict. View "Cervantes v. Bianco" on Justia Law
Bonta v. Bianco
Following the passage of Proposition 50, which revised congressional district maps in California, a community group in Riverside County alleged a discrepancy in the number of ballots counted versus ballots cast during the 2025 special election. Acting on the group’s report, the county sheriff’s department obtained search warrants from the Riverside County Superior Court and seized large quantities of ballots and election materials. The county registrar defended the official tally and explained the discrepancy at a public meeting. Despite the Attorney General’s request for a pause to review the investigation, the sheriff’s department advanced their search and began counting ballots, only halting after direct communication from the Attorney General.The Attorney General issued formal directives to the sheriff, instructing him to pause the investigation, preserve all seized materials, and provide case records for review. The sheriff initially did not respond, began counting ballots, then paused the count and secured the materials. Subsequent communications from the Attorney General reiterated these directives and requested records. After further seizures by the sheriff’s department, the Attorney General initiated litigation, seeking a writ of mandate in the California Court of Appeal, which denied relief on procedural grounds. The Attorney General then sought review in the Supreme Court of California.The Supreme Court of California held that the Attorney General, under the state Constitution and Government Code section 12560, possesses the authority to give binding directions to sheriffs regarding specific investigations when necessary to ensure uniform and adequate enforcement of state laws. The court concluded the directives issued in this case were within the Attorney General’s lawful authority and sufficiently specific. It granted writ relief, ordering the sheriff and department to comply with the Attorney General’s instructions to pause investigative actions, retain seized records (with certain exceptions), and provide requested materials. Each party was directed to bear its own costs. View "Bonta v. Bianco" on Justia Law
P. v. Hazlett
In October 1978, a woman named Tana Woolley was found dead in her apartment in Rosamond, California. She had been strangled with a sock, and her body was partially undressed. Initial investigation yielded no arrests, although DNA and other forensic evidence were collected. Decades later, with advances in DNA technology, semen stains found on Woolley’s bedspread were tested and matched the defendant, who lived in the same apartment complex at the time. The defendant denied knowing Woolley or ever being in her apartment. Further investigation revealed he had previously committed multiple sexual assaults, and evidence of these prior offenses was admitted at trial.The case was first tried in the Kern County Superior Court. The jury convicted the defendant of first degree murder and found true two special circumstances: that the murder was committed during the commission or attempted commission of rape and burglary, both requiring a finding of willful, deliberate, and premeditated murder under the then-applicable 1977 death penalty law. At the penalty phase, the jury returned a verdict of death, and the trial court entered judgment accordingly. The defense raised several issues, including challenges to jury selection, the admission of prior sexual offenses, and various constitutional and evidentiary claims.The Supreme Court of California reviewed the case on automatic appeal. It addressed whether the defendant established a prima facie case of racial discrimination in jury selection, the admissibility and instructions regarding other sexual offenses, the sufficiency of the evidence for the murder and special circumstance findings, and challenges under the California Racial Justice Act. The court held that the defendant failed to establish a prima facie case of discrimination in jury selection, that the evidence and instructions regarding prior sexual offenses were properly admitted, and that sufficient evidence supported the convictions and special circumstance findings. It further determined that no prejudicial error occurred under the Racial Justice Act. The court affirmed the judgment of death. View "P. v. Hazlett" on Justia Law
Town of Apple Valley v. Apple Valley Ranchos Water
A town served by a privately owned water utility experienced significant rate increases after the utility was sold to an investment fund. Responding to community concerns, the town decided to pursue public ownership of the water system. In 2015, it adopted two resolutions of necessity to begin eminent domain proceedings, aiming to take over the utility’s assets both within and just outside its boundaries. The utility, now owned by a new company, did not challenge the procedural validity of the resolutions but argued that the requirements of public necessity and more necessary public use, as mandated by California’s Eminent Domain Law, were not satisfied.The San Bernardino County Superior Court, presiding over a bench trial, determined that special statutory rules for takings of privately owned public utilities applied. The court found that, in this context, the utility could rebut the presumption of necessity by a preponderance of the evidence, rather than being limited to showing gross abuse of discretion by the public entity. After trial, the court found in favor of the utility, concluding that the town had not established the requisite elements to justify the taking. The Fourth Appellate District, Division Two, reversed, holding that the trial court should have reviewed the town’s findings only for gross abuse of discretion and had failed to give proper deference to the town’s determinations.The Supreme Court of California reviewed the matter and held that, under the 1992 amendments to the Eminent Domain Law, a public entity’s resolution of necessity for taking privately owned utility property creates only a rebuttable presumption, not a conclusive one. Therefore, the trial court is to exercise independent judgment as the trier of fact, determining whether the utility owner has rebutted the presumption by a preponderance of the evidence. The Supreme Court reversed the Court of Appeal’s judgment and remanded for further proceedings. View "Town of Apple Valley v. Apple Valley Ranchos Water" on Justia Law
Mayor v. Workers’ Comp. App. Bd.
An employee suffered an industrial injury in December 2013 while working for a sanitation district. The employee filed a workers’ compensation claim, and a workers’ compensation judge awarded him total and permanent disability. The employer, Ross Valley Sanitation District, filed a timely petition for reconsideration of this award. However, for reasons not clear in the record, the workers’ compensation judge did not act on the petition, and the Workers’ Compensation Appeals Board did not act on the petition within the 60-day statutory deadline. The Appeals Board eventually granted the petition for reconsideration 144 days after it was filed, stating that it had not received notice of the petition within the 60-day period due to an administrative irregularity.The employee then sought a writ of mandate from the California Court of Appeal, arguing that the Appeals Board’s action was untimely and void under former Labor Code section 5909, which at the time provided that a petition for reconsideration is deemed denied unless acted upon within 60 days of filing. The Court of Appeal agreed, holding that the 60-day deadline in section 5909 is mandatory and that the Appeals Board exceeded its jurisdiction when it acted outside that period.The Supreme Court of California reviewed the case. It held that the deadline in former section 5909 is mandatory, but not jurisdictional in the fundamental sense, meaning the Appeals Board acts in excess of its authority, rather than lacking power, if it acts late. The Supreme Court further held that the Appeals Board may not equitably toll its own statutory deadline to act on a petition for reconsideration, rejecting the argument that tolling was appropriate when the Board itself did not receive notice of the petition in time. The Court affirmed the judgment of the Court of Appeal, granting the writ of mandate and directing the Appeals Board to rescind its untimely order. View "Mayor v. Workers' Comp. App. Bd." on Justia Law
Posted in:
Personal Injury
P. v. Pearson
In this case, the defendant was convicted by a jury in 2003 for the first degree murder of Penny Sigler, along with special circumstances, and several other violent crimes including robbery, torture, rape, sexual penetration by a foreign object, and kidnapping. The victim was brutally attacked and killed after leaving her home late at night, and significant physical and forensic evidence linked the defendant to the crime. The defendant initially denied involvement but later made multiple statements admitting varying degrees of participation. Family and acquaintances testified about the defendant’s background and character, and members of his social group were also implicated and tried separately.After the original trial in the Los Angeles County Superior Court, the California Supreme Court affirmed the convictions but reversed the death penalty due to the improper exclusion of a prospective juror based on her views about capital punishment (see People v. Pearson (2012) 53 Cal.4th 306). The case was remanded solely for a new penalty trial and resentencing. At the retrial, the jury again imposed a death sentence.On automatic appeal from the penalty retrial, the Supreme Court of California addressed numerous challenges, including claims regarding the reappointment of original trial counsel, alleged prosecutorial misconduct, ineffective assistance of counsel, and new arguments based on legal developments after the original trial. The court held that the reappointment of counsel did not violate the defendant’s rights and that there was no prejudicial error in the penalty retrial. Challenges to the underlying guilt and special circumstance findings based on People v. Banks and Senate Bill No. 1437 were rejected, as the evidence demonstrated the defendant was a major participant who acted with reckless indifference to human life. The court affirmed the judgment of death. View "P. v. Pearson" on Justia Law
Posted in:
Criminal Law
P. v. Lightsey
The defendant was charged with capital murder and other offenses in 1993. Throughout the proceedings, concerns arose regarding his mental competency and his ability to represent himself. On two occasions, the trial court declared a doubt as to the defendant’s competency and held hearings, concluding both times that he was competent. During the second such hearing in July 1994, the defendant represented himself, which meant no counsel was appointed despite statutory requirements. The medical experts at the hearing offered differing views: one expert found the defendant competent to stand trial but not to represent himself, while the other found him unable to cooperate rationally with counsel. The defendant was ultimately convicted and sentenced to death.After direct appeal, the Supreme Court of California found reversible error in the trial court’s failure to appoint counsel during the 1994 competency proceedings and remanded the case, instructing the trial court to determine if a retrospective competency hearing was feasible. If feasible, a hearing would be held; if not, the reversal would stand.On remand, the Kern County Superior Court found that a retrospective hearing was feasible, conducted the hearing, and a jury found the defendant competent at the relevant time, leading to reinstatement of the judgment. The defendant appealed again, arguing that feasibility was not established.The Supreme Court of California held that the trial court erred in finding a retrospective competency hearing feasible. The court emphasized that such hearings are generally disfavored and that the prosecution had not met its burden to show sufficient and reliable evidence existed to determine the defendant’s competence nearly two decades later, especially given the unavailability of key witnesses and the compromised development of evidence due to the lack of appointed counsel in 1994. As a result, the Supreme Court reversed the reinstated judgment, subject to retrial if the defendant is then found competent. View "P. v. Lightsey" on Justia Law
Posted in:
Constitutional Law, Criminal Law
P. v. Esquivias
The case concerns a man who, in 2013, committed a fatal shooting and two armed robberies. He was convicted in 2015 by a jury of first degree murder, two counts of robbery, and possession of a firearm by a felon, with multiple firearm and gang enhancements found true. He received a sentence totaling 37 years and 8 months, plus 75 years to life, with firearm enhancements accounting for a significant portion of his sentence. His conviction was affirmed by the Court of Appeal, and his petition for review was denied by the California Supreme Court in 2017. While his appeal was still technically pending due to the time allowed to seek further review, the Legislature enacted a new law (Senate Bill No. 620), giving trial courts discretion to strike firearm enhancements.Nearly four years later, the defendant filed a petition for writ of habeas corpus in Los Angeles County Superior Court, seeking retroactive application of Senate Bill No. 620, since his conviction was not yet final when the law took effect. The Superior Court agreed that he was eligible for relief under the new law and struck his firearm enhancements, reducing his sentence by over 38 years. However, the court expressly limited its review to the firearm enhancements and declined to reconsider the remainder of his sentence or apply other ameliorative laws enacted after his judgment became final.On appeal, the defendant argued that striking part of his sentence entitled him to a full resentencing, including the benefit of all ameliorative laws enacted since his original sentencing. The California Court of Appeal rejected this argument, holding that habeas corpus courts are not required to grant a full resentencing simply because they grant partial relief. The California Supreme Court affirmed this decision, holding that when a habeas court grants partial sentencing relief under Senate Bill No. 620, it is not required by statute or the Constitution to resentence the defendant in full or apply all intervening ameliorative laws. The court emphasized that habeas corpus remedies are to be tailored to the specific claim and circumstances presented. View "P. v. Esquivias" on Justia Law
Posted in:
Criminal Law
P. v. Shove
The defendant was convicted by a jury of the first degree murders of an elderly married couple who owned and operated an aerospace business. The prosecution’s evidence showed that the defendant masterminded a scheme to acquire the business for himself, which involved hiring an associate to kill the couple, burglarizing the company’s safe, and attempting to extort money from the victims’ children using stolen documents and threats under a false identity. The defendant’s efforts to obtain the business were persistent, and he was described as persuasive and intimidating, often referencing fictitious connections to organized crime. After the murders, forensic evidence connected the associate to the crime scene, and extensive phone records showed frequent communication between the defendant and the associate around the time of the killings. The defendant was also involved in the subsequent burglary of the business safe and in an extortion plot targeting the victims’ children.At trial in the Los Angeles County Superior Court, the jury found the defendant guilty of the murders, burglary, receiving stolen property, and extortion. They also found true the special circumstance allegations of multiple murder and murder for financial gain. The penalty phase concluded with a death sentence. The trial court denied the defendant’s motions for a new trial and to modify the verdict.On automatic appeal to the Supreme Court of California, the defendant challenged numerous aspects of the trial, including the denial of his motion to suppress evidence from a search of his home, the exclusion of third party culpability evidence, the admission of an audio recording and evidence of his use of an alias, several claims of prosecutorial misconduct, the exclusion of impeachment evidence, and issues related to the penalty phase, such as the admission and notice of victim impact testimony and the constitutionality of California’s death penalty scheme.The Supreme Court of California affirmed the judgment in its entirety. The court held that any errors in the admission or exclusion of evidence were either not prejudicial or were harmless beyond a reasonable doubt. The court also found no reversible error in the handling of jury selection, the exclusion of third party culpability evidence, or the penalty phase proceedings, and rejected the defendant’s constitutional challenges to the state’s death penalty law. View "P. v. Shove" on Justia Law
Posted in:
Constitutional Law, Criminal Law
P. v. Hernandez
A long-time lawful permanent resident of the United States was arrested in Kern County, California, and charged with two drug offenses after being recruited by a confidential informant to transport marijuana. She pled guilty to both charges. At the time, she had lived in the United States for 36 years, had extensive family ties, and no prior criminal record. Two years after her conviction, she traveled to Mexico and, upon her return to California, was detained by immigration authorities, which initiated removal proceedings against her due to her convictions.Following these events, the defendant filed a petition for habeas corpus in the Kern County Superior Court, arguing ineffective assistance of counsel because her attorney had not properly advised her of the immigration consequences of her plea. Before the court ruled, she completed probation and converted her petition to a motion under Penal Code section 1473.7, which allows convictions to be vacated if the defendant did not meaningfully understand the immigration consequences of the plea. The Superior Court denied relief, finding her attorney had properly advised her, based largely on her signed plea form and her attorney’s and interpreter’s signatures. The Court of Appeal affirmed, concluding that she had failed to show she did not meaningfully understand the immigration consequences.The Supreme Court of California reversed. It held that, when considering a motion under section 1473.7(a)(1), courts must focus on the defendant’s subjective understanding and consider all relevant circumstances, not just the advisements received or written forms. The Court found that the defendant established by a preponderance of the evidence that she did not meaningfully understand, defend against, or knowingly accept the adverse immigration consequences of her plea. The Court also determined there was a reasonable probability that, had she understood, she would have sought an alternative plea or gone to trial. The Supreme Court directed the trial court to grant her motion, vacate the convictions, and conduct further proceedings. View "P. v. Hernandez" on Justia Law
Posted in:
Criminal Law, Immigration Law