Justia California Supreme Court Opinion Summaries

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The Supreme Court granted review in this criminal case to determine the continued viability of Cal. Penal Code 632(d) in light of the limits placed on the exclusion of evidence by the "Right to Truth in Evidence" provision of the California Constitution, holding that nothing in the amendments to section 632 evidenced an intent on the part of the Legislature to render surreptitious recordings once again inadmissible in criminal proceedings. Defendant was convicted of two counts of committing a lewd and lascivious act upon a child. The conviction was largely based on a secretly recorded conversation that violated section 632. The court of appeal, however, found that section 632(d), which prohibits the admission of "evidence obtained...in violation of this section...in any judicial, administrative, legislative, or other proceeding," had been abrogated by the Right to Truth in Evidence constitutional provision, which instructs that "except as provided by statute hereafter enacted...relevant evidence shall not be excluded in any criminal proceeding." The Supreme Court affirmed, holding (1) to the extent section 632(d) demanded suppression of relevant evidence in a criminal proceeding, it was abrogated by the voters' approval of Proposition 8; and (2) none of the Legislature's subsequent amendments to section 632 revived the exclusionary remedy of section 632(d). View "People v. Guzman" on Justia Law

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The Supreme Court affirmed, as modified in this opinion, the judgments of the trial court convicting James David Beck and Gerald Dean Cruz of four counts of first degree murder and entering judgments of death based on the murders, holding that certain true findings as to Defendants' convictions of conspiracy to commit murder were unauthorized. Defendants were convicted of four counts of first degree murder and of conspiracy to commit murder. The jury also found true a multiple murder special circumstance allegation and allegations of personal use of a deadly weapon. The trial court entered judgments of death. The Supreme Court vacated the multiple murder special circumstances true findings as to conspiracy to commit murder, as well as the death sentences imposed for that count, and otherwise affirmed, holding (1) the trial court erred in imposing a death sentence based upon Defendants' conspiracy convictions because conspiracy to commit murder alone cannot make a defendant death eligible; and (2) there was error but no prejudice in some of the trial court's instructions, the prosecutor's argument during the penalty phase, the imposition of the death penalty for the convictions of conspiracy to commit murder, and in the admission of certain testimony, but these errors were not prejudicial when considered individually or cumulatively. View "People v. Beck" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death, holding that there were four possible errors during the penalty phase of trial, but none of those errors was prejudicial. Defendant was convicted of first degree murder, and the jury found true the special circumstance allegation that Defendant committed the murder while engaged in a home invasion robbery. The prosecution retried the penalty phase, and, after a second penalty phase, the trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's sentence, holding that the trial court's errors regarding the admission of certain testimony regarding Defendant's remorselessness, the admission of hearsay testimony, an erroneous instruction, and the failure to transfer a certain exhibit to the jury were not prejudicial. The dissent would have reversed on the grounds that the prosecution disproportionately excused black prospective jurors during the jury selection process. View "People v. Johnson" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant was not entitled to relief on his allegations of error. Defendant was convicted of first degree murder with special circumstances of murder in the commission of forcible sodomy, murder in the commission of a lewd act on a child, and murder by torture. The trial court sentenced Defendant to death. On appeal, Defendant asserted multiple claims of error. The Supreme Court affirmed, holding (1) there was no prejudicial error during the guilt phase of trial; and (2) the only errors committed during the penalty phase were two instances of prosecutorial misconduct in argument to the jury, and these errors were not prejudicial either individually or cumulatively. View "People v. Rhoades" on Justia Law

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The Supreme Court reversed the opinion of the court of appeal reversing the judgment of the trial court ruling that the search of Defendant's car was invalid on the basis that the search was authorized under In re Arturo D., 27 Cal.4th 60 (Cal. 2002), holding that the desire to obtain a driver's identification following a traffic stop does not constitute an independent, categorical exception to the Fourth Amendment's warrant requirement, and to the extent Arturo D. held otherwise it should no longer be followed. Acting on a tip about Defendant's erratic driving, a police officer approached Defendant after she parked and exited her car. The police detained Defendant for unlicensed driving and, without asking her name, searched the car for Defendant's personal identification. The trial court held that the search was invalid under Arizona v. Gant, 556 U.S. 332 (2009). The Court of Appeals reversed, holding that the search was authorized under the Supreme Court's pre-Gant decision in Arturo D. The Supreme Court reversed, holding that the warrantless search of Defendant's vehicle in this case violated the Fourth Amendment. View "People v. Lopez" on Justia Law

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The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of two counts of first-degree murder and related crimes and sentencing Defendant to death for each of the murder convictions, holding that there was no reversible error in the proceedings below. Specifically, the Supreme Court held (1) there was substantial evidence to support the trial court's denial of Defendant's Batson/Wheeler challenge; (2) as to the admission of Defendant's confession, the investigator should have stopped the interrogation on April 21, 1999 sooner than he did, but the error did not compel the exclusion of the confession obtained on April 22, 1999 or thereafter; (3) Defendant's arguments involving testimony of Defendant's volitional impairment did not require reversal of the death sentence; (4) the trial court did not err in admitting testimony by Defendant's former girlfriend, a photograph of Defendant, and evidence that Defendant lied about shooting a person; and (5) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Krebs" on Justia Law

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The Supreme Court vacated the judgment of the court of appeal affirming in part and reversing in part the trial court's denial of Defendant's Proposition 47 petition, holding that the court of appeals did not properly apply this Court's decision in People v. Romanowski, 2 Cal.5th 903 (2017). At issue in this case was how to assess the value of stolen access card information. Defendant was convicted of five counts theft of access card information. Defendant petitioned for Proposition 47 relief seeking resentencing on her convictions on the basis that the value of the property she obtained was not more than $950. The trial court denied relief. The court of appeal reversed as to two convictions and affirmed as to the other three. The court did not engage in the Romanowski inquiry but instead assumed that the value of what Defendant obtained using the stolen information set a floor on the fair market value of the information she unlawfully used. The Supreme Court vacated the judgment and remanded with instructions to send the case back to the trial court for further fact-finding as to the reasonable and fair market value of the access card information at issue, holding that the court of appeal's reasoning fell short of what Romanowski required. View "People v. Liu" on Justia Law

Posted in: Criminal Law
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The Supreme Court exercised its original jurisdiction to entertain an emergency petition for a writ of mandate that would forbid the Secretary of State from enforcing portions of the recently enabled Presidential Tax Transparency and Accountability Act, Cal. Elec. Code 6880 et seq. The Supreme Court granted that writ, holding that portions of the Act conflict with Cal. Const. art. II, 5(c) and are therefore invalid. Specifically, the Court held that Elections Code sections 6883 and 6884 are invalid under article II, section 5(c) insofar as they require someone who is recognized as a candidate for the office of President of the United States to file with the Secretary of State federal income tax returns for the five most recent taxable years as a necessary condition for appearing on the primary election ballot of a qualified political party. The Court held that this additional prerequisite conflicts with the California Constitution's specification of an inclusive open presidential primary ballot and therefore cannot lawfully be enforced. View "Patterson v. Padilla" on Justia Law

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The Supreme Court answered a question requested by the United States Court of Appeals for the Ninth Circuit by holding that the provision in Cal. Civ. Code 1916-2 prohibiting lenders from assessing compound interest "unless an agreement to that effect is clearly expressed in writing and signed by the party to be charged therewith" does not apply to lenders exempt under article XV of the California Constitution. Article XV sets the maximum interest rates lenders may charge but exempts specified classes of lenders from those rate restrictions and authorizes the Legislature to regulate the compensation these exempt lenders may receive. At issue was whether exempt lenders are required to obtain a borrower's signed agreement in order to charge compound interest on a loan. The Supreme Court held that exempt lenders are not required to obtain a borrower's signed agreement in order to charge compound interest on a loan. View "Wishnev v. Northwestern Mutual Life Insurance Co." on Justia Law

Posted in: Banking
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In this Private Attorneys General Act (PAGA), Cal. Lab. Code 2698 et seq., action seeking civil penalties under Cal. Labor Code 558 the Supreme Court held that the civil penalties a plaintiff may seek under section 558 through the PAGA do not include the "amount sufficient to recover underpaid wages." Real party in interest Kalethia Lawson brought this action naming as Defendants her employer and its parent company (collectively, ZB). Lawson had agreed to arbitrate all employment claims and forego class arbitration with her employer. The court of appeals ordered the trial court to deny ZB's motion to arbitrate that portion of Lawson's claim for unpaid wages, concluding that section 558's civil penalty encompassed the amount for unpaid wages and that Lawson's unpaid wages claim could not be compelled to arbitration under Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal.4th 348 (2014). The Supreme Court affirmed, holding (1) the amount for unpaid wages is not recoverable under the PAGA, and section 558 does not otherwise permit a private right of action; and (2) therefore, the trial court should have denied ZB's motion. View "ZB, N.A. v. Superior Court" on Justia Law