by
In this original habeas corpus action the Supreme Court granted Petitioner habeas corpus relief insofar as the petition sought relief from the judgment of death after accepting the finding of the referee that a prosecution witness had falsely identified Petitioner as the man who sexually assaulted her, holding that the false testimony was material. Petitioner was convicted of first degree murder and second degree murder and sentenced to death. Petitioner later filed a habeas corpus petition alleging, among other things, that a penalty phase witness had misidentified him as the man who assaulted and raped her. The Supreme Court appointed a referee who conducted an evidentiary hearing, after which the referee found that, during the penalty phase, the witness had testified falsely when she identified Petitioner as her assailant. Noting that the Court generally accepts the referee's findings, the Supreme Court granted Petitioner relief on the basis of false evidence by overturning his sentence of death, holding that the false testimony undermined this Court's confidence in the outcome of the trial and that Petitioner was entitled to relief on this claim as to the penalty verdict. View "In re Rogers" on Justia Law

Posted in: Criminal Law

by
In this negligence case, the Supreme Court held that the immunity provision of the Government Claims Act (GCA) that bars any statutory liability that might otherwise exist for injuries resulting from the condition of firefighting equipment or facilities, Cal. Gov't Code 850.4, does not deprive a court of fundamental jurisdiction but, rather, operates as an affirmative defense to liability. Plaintiff sued the Chester Fire Protection District and the Garden Valley Fire Protection District alleging that Defendants created a "dangerous condition" of public property for which public entities may be held liable under Cal. Gov't Code 835. Defendants did not allege the immunity conferred by section 850.4. After trial began, defense counsel presented a written motion for nonsuit in which Defendants for the first time invoked section 850.4. Plaintiff objected on the ground that Defendants waived section 850.4 immunity by failing to invoke the immunity in their answer. The trial court overruled the objection, concluding that governmental immunity is jurisdictional and can't be waived. The court of appeal affirmed. The Supreme Court reversed, holding that section 850.4 immunity operates as an affirmative defense and not a jurisdictional bar. The Court remanded the case so the court of appeal may address the parties' remaining arguments in the first instance. View "Quigley v. Garden Valley Fire Protection District" on Justia Law

Posted in: Personal Injury

by
The Supreme Court reversed the decision of the court of appeal reversing the ruling of the trial court denying Defendants' motion for dismiss this breach of contract suit under the anti-SLAPP statutes, holding that Plaintiff met its burden of showing its breach of contract claim had "minimal merit" sufficient to defeat an anti-SLAPP motion. The parties to a tort action agreed to settle their lawsuit. The agreement, which was reduced to writing, included provisions purporting to impose confidentiality obligations on the parties and their counsel. All parties signed the agreement, and the parties' lawyers signed under a notation that they approved the agreement. Plaintiff brought this suit against Defendants, counsel in the tort action, alleging that Defendants violated the agreement by making public statements about the settlement. Defendants moved to dismiss the suit under the anti-SLAPP statutes. The trial court denied the motion. The court of appeal reversed, concluding that the notation meant only that counsel recommended their clients sign the document. The Supreme Court reversed, holding that it would be reasonable to argue that Defendants' signature on the agreement evinced a willingness to be bound by its terms. View "Monster Energy Co. v. Schechter" on Justia Law

Posted in: Contracts

by
The Supreme Court held that the determination of the California Department of Social Services (the Department) that a household member's income that is used to pay child support for a child living in another household counts as income "reasonably anticipated" to be "received" by the paying household within the meaning of Cal. Welf. & Inst. Code 11265.2 for the purposes of determining eligibility for state welfare benefits was reasonable and therefore valid. Plaintiff applied for California Work Opportunity and Responsibility to Kids (CalWORKs) aid to support herself and her family. The Director of the Department denied the claim, concluding that child support payments garnished from Plaintiff's husband's earned income and unemployment insurance benefits was correctly included as nonexempt available income in determining eligibility for CalWORKs benefits. The superior court declared the department's policy of counting court-ordered child support payments as available income of CalWORKs applicants invalid. The court of appeal reversed. The Supreme Court affirmed, holding that the Department’s determination that funds garnished to pay child support for the benefit of a child living in another household are not exempt from the paying household’s income for purposes of determining its eligibility for or amount of CalWORKs aid was a reasonable exercise of its lawmaking authority and was therefore valid. View "Christensen v. Lightbourne" on Justia Law

Posted in: Public Benefits

by
The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and his sentence of death, holding that none of Defendant's challenges to his convictions and death sentence warranted reversal. Defendant was one of three members of a gang who were charged with the murders of Michael Faria and Jessica Salazar. This automatic appeal concerned only Defendant. The Supreme Court affirmed Defendant's conviction of two counts of first degree murder and death sentence, holding (1) any error in allowing a gang expert to testify was harmless; (2) the trial court did not err in declining to exclude two portions of a jailhouse conversation Defendant had with a friend; (3) there was sufficient evidence to support a finding that Defendant shot Faria; (4) the trial court did not abuse its discretion in limiting the cross-examination of a certain witness; (5) the trial court did not abuse its discretion in admitting a photograph depicting Faria's body; (6) the victim impact evidence admitting in this case was within the bounds of what precedents permit; and (7) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Mendez" on Justia Law

by
In this case concerning whether a certified class of state correctional employees is entitled to additional compensation for time spent on pre- and postwork activities, the Supreme Court held that the represented plaintiffs' claims failed insofar as they sought additional compensation for either "duty-integrated walk time" or "entry-exit walk time" and that, as to the subclass of unrepresented plaintiffs, they may be entitled to additional compensation for duty-integrated walk time. The Supreme Court referred to the time the employees spent traveling from the outermost gate of the prison facility to their work posts within the facility as "entry-exit walk time" and the time the employees spent after beginning the first activity they were assigned to but before arriving at their assigned work post the "duty-integrated walk time." The trial court divided the plaintiff class into two subclasses: one for supervisory employees who were not represented by a union and the other for represented employees. The Court concluded (1) the subclass of represented plaintiffs expressly agreed to a specific amount of compensation for duty-integrated walk time; and (2) the collective bargaining agreements precluded other forms of compensation, and therefore, the represented plaintiffs' claims failed insofar as they sought additional compensation for either duty-integrated walk time or entry-exit walk time. View "Stoetzl v. Department of Human Resources" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of first degree murder, with the special circumstance that the murder was committed during a rape, and Defendant's sentence of death holding that there was no prejudicial error in the proceedings below. Specifically, the Court held (1) the victim's brother testified at the penalty phase in contravention of a court order, but any prejudice was cured by the trial court's admonition and by other evidence undermining the significance of Defendant's assertions; (2) any assumed error in failing to instruct at the guilt phase on a good faith but unreasonable belief in consent to intercourse was not prejudicial; and (3) Defendant offered no compelling reasons for the Court to reconsider its precedent rejecting Defendant's constitutional challenges to California's death penalty scheme. View "People v. Molano" on Justia Law

by
The Supreme Court affirmed Defendant's convictions for three counts of first degree murder and three counts of first degree attempted murder arising from two shootings committed by Defendant on the same day and Defendant's sentence of death, holding that only one error occurred during the proceeding, and the error was harmless beyond a reasonable doubt. Specifically, the Court held (1) none of Defendant's claims of error at the guilt phase had merit, and therefore, there was no cumulative error requiring reversal of his convictions; and (2) during the penalty phase, the trial court erred in failing to instruct the jury that a witness's prior conviction of a felony bore on his credibility, but the error was harmless, and therefore, there was no cumulative error requiring reversal of Defendant's penalty of death. View "People v. Mitchell" on Justia Law

by
The Supreme Court reversed the judgment of the trial court upholding Defendants' convictions of two counts of attempted murder, holding that the evidence was insufficient to support an instruction on the kill zone theory in connection with one of the two alleged attempted murder victims. Defendants were jointly charged and tried on counts including first degree murder and two attempted murders. The trial court gave a kill zone instruction in connection with one of the two alleged attempted murder victims. Under the kill zone theory, a defendant may be convicted of the attempted murder of an individual who was not the defendant's primary target. The court of appeals upheld the attempted murder convictions. The Supreme Court reversed, holding (1) a jury may convict a defendant under the kill zone theory only when the evidence supports a finding that the defendant harbored the requisite specific intent to kill both the primary target and everyone within the zone of fatal harm; and (2) there was insufficient evidence in the record to support an instruction on the kill zone theory. View "People v. Canizales" on Justia Law

Posted in: Criminal Law

by
The Supreme Court held that the City and County of San Francisco (San Francisco) can lawfully apply a tax collection requirement, which requires parking lot operators to collect a tax from drivers who park their cars in paid parking lots and remit the proceeds to the city, to state universities that operate paid parking lots in the city, holding that the collection requirement is not unconstitutional. San Francisco, a consolidated city and county that has adopted a charter for its own governance, requires that state universities collect the parking tax at issue with whatever parking fees they charge and remit the proceeds to the city. The trial court concluded that the universities were exempt from compliance with the parking tax ordinance. The court of appeal affirmed, concluding that the constitutional principles articulated and applied in In re Means, 14 Cal.2d 254 (1939), and Hall v. City of Taft, 47 Cal.2d 177 (1956), exempts state agencies from collecting and remitting the parking tax. The Supreme Court reversed, holding that charter cities may require state agencies to assist in the collection and remittance of municipal taxes and that San Francisco's collection requirement is a valid exercise of its power from which state universities are not immune. View "City & County of San Francisco v. Regents of the University of California" on Justia Law