Justia California Supreme Court Opinion Summaries

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

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

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

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

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

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

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

In this case, organizations that represent indigent and low-income litigants challenged the widespread unavailability of official court reporters in California’s superior courts for civil, family, and probate proceedings. These organizations documented that, despite prior assurances, many indigent litigants appear in court and find that no court reporter is present, even when properly requested. As a result, such litigants are often forced either to accept repeated continuances—delaying urgent matters like domestic violence restraining orders and child custody—or to proceed without a verbatim record, which severely impairs their ability to seek appellate review.Previously, the Supreme Court of California had ruled in *Jameson v. Desta* that when a superior court does not routinely provide court reporters in civil cases but allows parties who can afford it to hire private reporters, the court must ensure that indigent litigants receive access to an official verbatim record. Despite this, the petitioners alleged and the courts largely conceded that a chronic shortage of court reporters had rendered this guarantee largely ineffective. Some superior courts responded by issuing general orders allowing electronic recording in certain cases involving fundamental rights, but these policies were limited in scope and not uniformly adopted.The Supreme Court of California reviewed this original proceeding and held that, under the in forma pauperis doctrine articulated in *Jameson v. Desta*, superior courts have a ministerial duty to provide indigent litigants, upon request, with meaningful access to an official verbatim record of proceedings in all civil matters. This duty includes using electronic recording if neither an official nor a private court reporter is available, notwithstanding statutory restrictions. The court issued a writ of mandate directing the respondent superior courts to comply with this obligation. Each party was ordered to bear its own costs. View "Family Violence Appellate Project v. Super. Ct." on Justia Law

Tesoro, a company operating an oil refinery in the City of Carson, was assessed for underpayment of the City’s oil industry business license tax following an audit. Tesoro paid the assessed deficiency under protest and filed a claim for a tax refund with the City clerk, using the form prescribed under the California Government Claims Act (GCA). The City denied this claim. Tesoro then filed a lawsuit seeking a refund, arguing that the City was barred from seeking the payment due to expiration of the limitations period and because the City’s method for calculating the tax was unlawful.In the Los Angeles County Superior Court, the City demurred, contending that Tesoro failed to exhaust the City’s local administrative remedies—specifically, the procedures in the Carson Municipal Code requiring a taxpayer to seek a refund first from the finance director and then, if necessary, to appeal to the city manager—before filing a claim under the GCA. The trial court sustained the demurrer. The California Court of Appeal, Second Appellate District, Division Four, affirmed, holding that Tesoro had not demonstrated that the GCA preempted the City’s local administrative review process.The Supreme Court of California granted review to determine whether a local government may require a taxpayer seeking a refund to comply with local administrative procedures before submitting a claim under the GCA, or whether the GCA preempts such requirements. The Supreme Court held that the GCA occupies the entire field of presentation requirements for claims for money or damages against local public entities, including claims for local tax refunds. The Court concluded that the sections of the Carson Municipal Code imposing additional administrative prerequisites are preempted by state law and may not be enforced. The judgment of the Court of Appeal was reversed. View "Tesoro Refining & Marketing Co. LLC v. City of Carson" on Justia Law

The plaintiff leased a new vehicle from the defendant, but soon experienced persistent defects that could not be repaired despite multiple attempts. After the defendant failed to promptly replace the vehicle or provide restitution under the Song-Beverly Consumer Warranty Act, the plaintiff filed suit for breach of warranty, seeking damages and attorney fees. During litigation, the defendant made a statutory settlement offer pursuant to Code of Civil Procedure section 998, presenting two alternative sets of terms: a lump-sum payment or a reimbursement option requiring proof of damages, both accompanied by provisions for attorney fees and costs.In the Los Angeles County Superior Court, the jury awarded the plaintiff damages totaling $76,155.27, less than the lump-sum alternative in the defendant’s 998 offer. The trial court found the offer valid, imposed section 998’s cost-shifting penalty, limited plaintiff’s postoffer costs and attorney fees, and awarded defendant its postoffer costs. The plaintiff appealed, contesting the validity of the alternative-choice offer. The California Court of Appeal upheld the trial court’s awards, finding the lump-sum alternative sufficiently certain but deemed alternative-choice offers categorically invalid for cost-shifting purposes.The Supreme Court of California reviewed whether an offer under section 998 that presents two independent, alternative sets of terms for acceptance is categorically invalid due to uncertainty. The Court held that such an alternative-choice offer can be valid if it clearly presents the alternatives and at least one alternative is sufficiently certain to permit accurate valuation at the time the offer is made. If the judgment or award does not exceed the highest valued, valid alternative, cost-shifting under section 998 is permitted. The Court affirmed the trial court’s award, but rejected the Court of Appeal’s categorical prohibition of alternative-choice offers under section 998. View "Gorobets v. Jaguar Land Rover North America, LLC" on Justia Law