Justia California Supreme Court Opinion Summaries

In this case, the defendant was charged with multiple violent crimes arising from two separate incidents in Los Angeles County in 1991. The first incident involved the fatal shooting of Benson Jones, the attempted murder of Benjamin Jones, and an assault with a firearm on Linda Jones. The second incident involved the murder of Jesus Sanchez and the attempted murder of Ernest Johnson. The prosecution’s theory focused on gang affiliations as the motive for the shootings, supported by eyewitness identifications, gang expert testimony, and forensic evidence. Bankston was also charged with being a felon in possession of a firearm.At the initial trial in the Los Angeles County Superior Court, the jury convicted Bankston of murdering Benson Jones, the attempted murder of Benjamin Jones, and firearm possession, but could not reach verdicts on the charges related to Sanchez, Johnson, and Linda Jones, resulting in a mistrial for those counts. During the retrial, Bankston was acquitted of Johnson’s attempted murder but convicted of Sanchez’s murder and assaulting Linda Jones with a firearm. The jury found true the multiple-murder special-circumstance allegation, and after the penalty phase, returned a death verdict.On automatic appeal to the Supreme Court of California, the court reviewed numerous claims, including trial management, evidentiary rulings, jury selection, and self-representation. The court held that the guilt and special circumstance phases were free from prejudicial error, affirming the convictions and upholding most trial procedures. However, both parties agreed that the penalty phase closing argument by the prosecutor involved racially discriminatory language in violation of the California Racial Justice Act of 2020, Penal Code section 745. The Supreme Court held that this error was not harmless beyond a reasonable doubt under the Act and reversed the death sentence, remanding for further proceedings on penalty. The court affirmed the judgment in all other respects. View "P. v. Bankston" on Justia Law

The defendant was convicted by a jury of the first degree murders of his two young children, with special findings that the murders involved torture and multiple victims. The evidence at trial showed a prolonged pattern of severe physical abuse and neglect inflicted by the defendant on the children, including daily beatings, deliberate starvation, and ultimately fatal injuries. The abuse was corroborated by testimony from family members, expert medical evidence, and the circumstances of the children’s deaths. After a penalty phase hearing, the jury returned a death verdict, and the trial court imposed a sentence of death, staying punishment on the other counts.Prior to review by the Supreme Court of California, the case was tried in the Los Angeles County Superior Court. The jury found the defendant guilty of several crimes including first degree murder, child abuse homicide, child endangerment, and corporal injury to a child, and found true multiple special circumstance allegations. The defendant’s appeals centered on the sufficiency of the evidence for first degree murder and special circumstance findings, the admission of certain expert testimony, the adequacy of jury instructions, alleged prosecutorial misconduct, and claims under the California Racial Justice Act.The Supreme Court of California reviewed each of the defendant’s claims in detail. It held that the evidence was sufficient to support the first degree murder convictions and special circumstance findings under both theories of torture-murder and premeditated, deliberate murder. The court found any error in the admission of certain expert testimony or in the instructions to be harmless beyond a reasonable doubt. The court also assumed, without deciding, that certain prosecutorial comments may have violated the Racial Justice Act, but concluded that any such errors were harmless. The Supreme Court affirmed the judgment in its entirety, upholding the convictions and the death sentence. View "P. v. Barrera" on Justia Law

Two defendants were jointly tried before separate juries for a series of violent crimes committed in Sacramento and Pomona in 1995. These included the robbery and murders of members of the Le family, the attempted murder of Quyen Luu, a burglary, an attempted robbery, and the murder of Miguel Vargas Avina with the attempted murder of Rodolfo Huerta. Both were also implicated in an uncharged murder (Bun) and alleged to have acted for the benefit of a criminal street gang. The prosecution relied on eyewitnesses, accomplice testimony, forensic evidence, and admissions from the defendants. The defense challenged witness identifications, introduced expert testimony on eyewitness reliability, and presented extensive mitigating evidence about the defendants' traumatic backgrounds.The Los Angeles County Superior Court allowed the charges from different counties to be joined under Penal Code section 790(b), leading to a joint capital trial. Both men were convicted of all charges and special circumstance allegations, and each jury returned a verdict of death. The trial court entered death judgments for both, finding true additional special circumstances.The Supreme Court of California reviewed the case automatically. For one defendant, the court affirmed the judgment except for vacating the gang enhancement finding, due to legislative changes that barred the use of the charged offense to establish a pattern of criminal gang activity. For the other defendant, the court reversed the judgment in its entirety. It held that defense counsel's closing argument conceding guilt on the defendant’s behalf, over his express objection, violated the defendant’s constitutional right to decide the objective of his defense, as articulated in McCoy v. Louisiana (2018). This error was deemed structural, requiring automatic reversal of all convictions and enhancements for that defendant. The case was remanded for further proceedings as to both defendants as specified. View "P. v. Chhuon" on Justia Law

An 11-year-old girl disappeared while visiting her parents in Oakland in July 1999 and was found dead the next day. Investigators discovered she had been raped and strangled. Within weeks, the defendant, a nearby resident, confessed to the crime after matching DNA evidence was found. In his confession, the defendant described luring the victim into his apartment, assaulting and killing her, and disposing of her body. The prosecution further corroborated the confession with testimony from a neighbor and other witnesses, and confirmed the DNA link. The defense did not present evidence at the guilt phase but presented mitigating evidence at the penalty phase, including character witnesses and information about the defendant’s background.The Superior Court of Alameda County conducted the trial. Before trial, the court denied the defendant’s motion to suppress evidence related to the police’s collection of his blood sample and confession, finding the encounter to be consensual and not a detention under the Fourth Amendment. The defendant was convicted of first-degree murder with special circumstances and sentenced to death. His post-trial motions, including those to discharge a juror and for a mistrial based on alleged juror bias, were denied.The Supreme Court of California reviewed the case on automatic appeal. The court held that the defendant was not unlawfully detained before consenting to the blood draw, that evidence obtained was admissible, and that no juror bias or improper admission of evidence rose to the level of reversible error. The court also addressed and rejected challenges to victim impact evidence, admission of unadjudicated criminal acts, and claims of constitutional violations in the penalty phase, including a claim under California’s Racial Justice Act regarding the prosecutor’s language. The judgment, including the death sentence, was affirmed. View "P. v. Demolle" on Justia Law

A conservatee challenged the practice of the San Joaquin County Public Conservator, represented by County Counsel, of filing a large number of judicial disqualification motions under Code of Civil Procedure section 170.6 against a specific judge in conservatorship proceedings. The challenge came after the judge admonished County Counsel for improper conduct, and, according to the petitioner, County Counsel responded by disqualifying the judge in over 300 cases within a few months, effectively forcing her reassignment. The petitioner argued that this pattern of “blanket” challenges was being used to control judicial assignments and undermine judicial independence, rather than based on a good faith belief in prejudice.The San Joaquin County Superior Court denied the petitioner’s opposition, citing the California Supreme Court’s earlier decision in Solberg v. Superior Court, which held that such blanket challenges did not violate separation of powers. The Court of Appeal summarily denied writ relief without addressing the substance of the petitioner’s claims. The petitioner then sought review from the Supreme Court of California, asking it to reconsider the continued validity of Solberg given changed conditions in California’s courts.The Supreme Court of California granted review and held that while section 170.6 remains facially constitutional, Solberg is overruled to the extent it bars as-applied, separation of powers challenges to blanket abuses of section 170.6. The Court held that if a party timely objects to a section 170.6 motion and makes a prima facie showing of bad faith blanket challenges, the court may inquire into the legitimacy of the asserted prejudice. The Court remanded the matter to the Court of Appeal to determine if further proceedings are necessary in light of this new standard. View "J.O. v. Super. Ct." on Justia Law

The defendant was observed by a police officer driving recklessly in Ukiah, California, nearly hitting pedestrians and engaging in dangerous maneuvers while under the influence of alcohol. After a high-speed pursuit, she was arrested and charged with multiple felonies, including assault and reckless evasion, as well as misdemeanors related to driving under the influence. She had a prior robbery conviction, making her subject to enhanced sentencing under the Three Strikes law. Through a negotiated plea, she pled no contest to one felony and one misdemeanor, admitted her prior strike, and agreed to a stipulated upper-term sentence of three years (doubled to six years), with the remaining charges dismissed.After her conviction, but while her appeal was pending, California amended Penal Code section 1170 to require that aggravating facts justifying an upper-term sentence be either stipulated to by the defendant or found true beyond a reasonable doubt. The defendant argued on appeal that this amendment should apply retroactively to her nonfinal judgment, requiring reduction of her sentence since the new requirements were not met. The California Court of Appeal rejected her claim, holding that the amendment did not affect stipulated sentences from plea bargains, since no judicial discretion was exercised in those cases.The Supreme Court of California reversed the Court of Appeal. The Supreme Court held that defendants with nonfinal judgments who agreed to an upper-term sentence as part of a plea bargain are entitled to seek the retroactive benefit of amended section 1170(b). However, a stipulated upper-term sentence remains valid only if the defendant knowingly and voluntarily waives the new requirements. On remand, the defendant may either waive these requirements and reaffirm the plea (reinstating the original sentence), or invoke them, in which case the parties may renegotiate the plea or the defendant may withdraw her plea and proceed to trial. The Supreme Court of California thus vacated the lower court’s judgment and set forth these remedies. View "P. v. Mitchell" on Justia Law

A developer applied to San Luis Obispo County for a coastal development permit to construct single-family homes on several residential lots in an established neighborhood in Los Osos. The County granted the permit in 2019. The California Coastal Commission appealed the County’s approval and denied the permit, claiming appellate jurisdiction on two grounds: that the proposed development was located within a sensitive coastal resource area (SCRA) under the County’s local coastal program (LCP), and that the project was not the only principal permitted use for the site under the LCP.The developer petitioned for a writ of administrative mandate in the San Luis Obispo County Superior Court, arguing that the Commission lacked appellate jurisdiction. The trial court found for the Commission on the SCRA issue but rejected the Commission’s alternative jurisdictional ground. On appeal, the Second Appellate District, Division Six, affirmed, holding that the Commission had properly exercised appellate jurisdiction based on the project’s location in an SCRA and did not reach the alternative ground.The Supreme Court of California reviewed the case to clarify the standard of review for the Commission’s exercise of appellate jurisdiction and whether deference is owed to either the Commission’s or the County’s interpretation of the LCP. The Court held that: (1) courts should use independent judgment when the Commission’s appellate jurisdiction turns on LCP interpretation; (2) no deference is owed to either agency’s interpretation when both administer the LCP and their views are equally plausible; (3) the proposed development site is not within an SCRA under the LCP; and (4) the Commission lacks appellate jurisdiction merely because a site has multiple principal permitted uses. The Supreme Court reversed the judgment of the Court of Appeal and ordered the Commission’s denial of the permit to be vacated for lack of jurisdiction. View "Shear Development Co., LLC v. Cal. Coastal Com." on Justia Law

An educational technology company was contracted by a county office of education to provide software and technology services to school districts, which involved collecting and storing various types of student data, including medical information. In 2022, the company experienced a data breach that resulted in unauthorized access to student medical records, including those of a minor plaintiff. The minor, through a guardian, filed a class action lawsuit alleging violations of both the Confidentiality of Medical Information Act (CMIA) and the Customer Records Act (CRA), claiming the company was negligent in protecting confidential medical information and failed to provide timely disclosure of the breach.The Superior Court of Ventura County granted the company’s demurrer and dismissed the case, concluding that the plaintiff failed to state a claim under either statute, as the company was not a covered entity under the CMIA or CRA and the plaintiff was not a “customer” under the CRA. The California Court of Appeal, Second Appellate District, Division Six, reversed, finding that the company fell within the scope of both statutes and that the plaintiff had alleged sufficient facts to support both claims. The appellate court also determined that the trial court erred by denying leave to amend the complaint.The Supreme Court of California reversed the appellate decision. The Court held that the plaintiff did not sufficiently allege the company was a “provider of health care” under the CMIA, nor that he was the company’s “customer” under the CRA, so no claim was stated under either statute. However, the Court clarified that under the CMIA, a breach of confidentiality occurs when medical information is exposed to a significant risk of unauthorized access or use, and actual viewing by an unauthorized party is not required. The judgment was reversed and remanded for further proceedings. View "J.M. v. Illuminate Education, Inc." on Justia Law

Two men attacked a couple as they entered their condominium, robbing them and sexually assaulting the woman. During the incident, the male victim was fatally shot. Decades later, DNA evidence linked one of the assailants, Morris, to the crime. In 2013, Morris was convicted by a jury of first degree murder, with special circumstances for rape, robbery, and murder for financial gain. The jury found that Morris acted with intent to kill, and the trial court sentenced him to life without parole. The conviction was affirmed on appeal.After changes to California’s felony-murder rule under Senate Bill 1437, Morris filed a petition for resentencing under Penal Code section 1172.6, arguing he was ineligible for murder liability as a nonkiller under the amended law. The Superior Court summarily denied the petition at the prima facie stage, reasoning that the jury’s findings established Morris’s intent to kill, making him ineligible for relief. The California Court of Appeal, in a split decision, affirmed the denial. The majority held that, under the amended law, it was sufficient that Morris acted with intent to kill and aided the underlying felony, even if he was not the actual killer. The dissenting judge argued that the law requires a nonkiller to have aided the actual killer in the lethal act itself, not just in the underlying felony.The Supreme Court of California reviewed the case to resolve a conflict among appellate courts regarding the actus reus requirement for nonkiller aiders and abettors under section 189, subdivision (e)(2). The Supreme Court held that, for a nonkiller to be liable for felony murder under this provision, the prosecution must prove that the nonkiller, with intent to kill, aided or abetted the actual killer in the commission of the lethal act itself—not merely in the commission of the underlying felony. The Court reversed the Court of Appeal and remanded for further proceedings. View "P. v. Morris" on Justia Law

The defendant used a false pretense to enter the motel room of Carole Sund, her daughter Juli Sund, and family friend Silvina Pelosso. Once inside, he brandished a gun, used duct tape to bind the three, and murdered Carole and Silvina by strangulation and suffocation. Over several hours, he sexually assaulted Juli, then kidnapped her, assaulted her again, and ultimately killed her by slitting her throat. Months later, he also kidnapped, murdered, and decapitated Joie Armstrong. The defendant confessed to these crimes in detail. Physical evidence and testimony corroborated his confession. Evidence related to the Armstrong murder, prosecuted federally, was introduced during the penalty phase.A jury in the Santa Clara County Superior Court convicted the defendant of three counts of first-degree murder and one count of kidnapping. The jury found true multiple enhancement allegations, including use of a deadly weapon and firearm, and five special circumstances: multiple murders, kidnapping murder, attempted rape murder, forcible oral copulation murder, and burglary murder. The jury found not true the alleged robbery-murder special circumstance. In a separate sanity phase, the jury found the defendant sane at the time of the offenses, and in the penalty phase, recommended the death penalty. The trial court denied motions for a new trial and sentence modification, imposing death plus a consecutive prison term.On automatic appeal, the Supreme Court of California reviewed numerous claims, including challenges to the admission of the defendant’s confession, claims of evidentiary and procedural error, allegations of juror misconduct, and arguments regarding the constitutionality of California’s death penalty scheme. The Court held that the confession was properly admitted, the evidentiary and procedural rulings were within the trial court’s discretion, and that there was no prejudicial juror misconduct or judicial bias. The Court also rejected constitutional challenges to the death penalty statute. The Supreme Court of California affirmed the judgment in its entirety. View "People v. Stayner" on Justia Law