Justia California Supreme Court Opinion Summaries

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The Supreme Court affirmed the decision of the appellate court dismissing a minor's appeal challenging the juvenile court's neglect of its mandatory duty under Cal. Welf. & Inst. Code 702 to declare a wobbler offense to be a misdemeanor or a felony, holding that the minor may not bring such a challenge in an appeal from a later dispositional order after the time to appeal the original disposition expired. Two wardship petitions were filed against G.C. alleging that G.C. committed three wobbler offenses. G.C. admitted all three allegations. The court, however, did not declare on the record whether the offenses were felonies or misdemeanors. Thereafter, G.C. was adjudged a ward and placed on probation. G.C. did not appeal the disposition. After G.C. violated the terms of her probation the juvenile court maintained G.C. in her mother's custody under the supervision of the probation department with various conditions. G.C. appealed, arguing that the court failed expressly to declare whether the offenses were misdemeanors or felonies. The appellate court determined that the issue was not timely raised. The Supreme Court affirmed, holding that although section 702 is mandatory, noncompliance did not make the original dispositional order an unauthorized sentence that could be corrected at any time. View "In re G.C." on Justia Law

Posted in: Juvenile Law
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The Supreme Court affirmed the decision of the court of appeal affirming the trial court's grant of Defendant's demurrer and dismissing Plaintiff's complaint alleging that Defendant negligently allowed a fire to spread from Defendant's property to Plaintiff's property, harming some of Plaintiff's trees, holding that Plaintiff could not rely on Cal. Civ. Code 3346's extended statute of limitations and that his complaint was otherwise untimely. Section 3346 provides enhanced damages to plaintiffs suffering wrongful injuries to timber, trees, or underwood. The relevant statute of limitations where a plaintiff seeks such damages is five years. In this case, Plaintiff alleged that section 3346's enhanced damages and five-year statute of limitations applied to property damage from a fire negligently allowed to escape from Defendant's property. Defendant filed a demurrer, arguing that Plaintiff's claims were time-barred. The trial court granted the demurrer. The court of appeal affirmed, concluding that the three-year statute of limitations in Cal. Code Civ. Proc. 338(b) applied to this action for trespass upon or injury to real property. The court of appeal agreed. The Supreme Court affirmed, holding that section 3346 is inapplicable to damages to timber, trees, or underwood from negligently escaping fires and that Plaintiff's complaint was otherwise untimely. View "Scholes v. Lambirth Trucking Co." on Justia Law

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The Supreme Court granted the request of the United States Court of Appeals for the Ninth Circuit to decide a question of California law regarding Industrial Welfare Commission wage order No. 7-2001 (Wage Order 7), which requires employers to pay their employees a minimum wage for all "hours worked," concluding that time spent on the employer's premises waiting for, and undergoing, mandatory exit searches of bags, packages, or personal technology devices voluntarily brought to work purely for personal convenience by employees is compensable as "hours worked" within the meaning of Wage Order 7. Employees filed a class action complaint against Employer, Apple Inc., alleging that Employer failed to pay them minimum and overtime wages for time spent waiting for and undergoing Employer's exit searches in violation of California law. A federal district court granted summary judgment for Employer. On appeal, the Ninth Circuit asked the Supreme Court to address the state law issue. The Supreme Court concluded that, in the instant case, Employees' time spent on Employer's premises waiting for, and undergoing, required exit searches of packages, bags, or personal technology devices, such as iPhones, brought to work purely for personal convenience, is compensable as "hours worked" within the meaning of Wage Order 7. View "Frlekin v. Apple Inc." on Justia Law

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The Supreme Court granted Petitioner habeas corpus relief, holding that Petitioner was denied his constitutional right to the assistance of competent counsel at the guilt phase of his criminal trial, and trial counsel's deficient performance undermined the reliability of the jury's guilty verdict. Petitioner was convicted of the first degree murder of a police officer and sentenced to death. While his appeal was pending, Petitioner filed his first petition for a writ of habeas corpus, arguing that the judgment should be vacated because he had received constitutionally ineffective assistance of counsel. During the habeas proceedings, the Supreme Court found that Petitioner's trial counsel had defrauded Petitioner in order to induce Petitioner to retain him instead of the public defender. Counsel went on to commit serious errors during the penalty phase undermining the reliability of the death verdict. The Supreme Court granted the petition and ordered a new penalty phase trial. Petitioner later filed this petition for a writ of habeas corpus challenging his convictions. The Supreme Court granted the writ and vacated Defendant's conviction for first degree murder, holding that Petitioner was denied the effective assistance of counsel at the guilt phase of his trial. View "In re Gay" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree murder, finding Defendant was sane at the time of the crimes, and sentencing Defendant to death, but struck an improperly imposed restitution fine, holding that the restitution fine should be stricken from the abstract of judgment and that any other error was not prejudicial. The trial court imposed a $10,000 restitution fine but did not impose the fine at the sentencing hearing. Rather, the fine was later added to the abstract of judgment. The Supreme Court ordered the restitution fine stricken from the record and the minutes because the trial court never imposed the fine in open court in Defendant's presence. The Court assumed other errors during the trial proceedings but found no prejudice. Further, the Court held that the error regarding the restitution fine and any assumed error were not cumulatively prejudicial. View "People v. Frederickson" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and kidnapping and sentence of death, holding that Defendant was not entitled to relief. Specifically, the Court held (1) the superior court did not err in exercising its jurisdiction in this matter; (2) the trial court did not err in the voir dire proceedings; (3) Defendant's argument that there was a material variance between the kidnap alleged in the indictment and the prosecutor's argument regarding his actual offense was unavailing; (4) the trial court did not err in admitting Defendant's custodial confession; (5) the trial court did not err by compelling Defendant to testify as a foundation for testimony by Defendant's expert that his confession was false; (6) the trial court did not err by limiting expert witness testimony; (7) the trial court did not err by compelling Defendant to undergo a prosecution-conducted psychiatric examination; (8) the prosecutor did not commit misconduct during the guilt phase closing argument; (9) there was no instructional error; (10) there was sufficient evidence to support the kidnap-murder special circumstance; (11) Defendant's claims of prosecutorial misconduct during the penalty phase closing argument lacked merit; and (12) Defendant's remaining penalty phase claims were unavailing. View "People v. Hoyt" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the decision of the court of appeal dismissing an appeal of an order directing an attorney to pay sanctions because the notice of appeal identified the attorney's client as the appealing party but other indicia made it clear that the attorney was the party seeking review, holding that, under the circumstances of this case, the notice of appeal should be construed to include the omitted attorney. Attorney represented K.J. in a negligence action against the Los Angeles Unified School District (collectively, LAUSD). During the litigation, LAUSD filed an application seeking sanctions from Attorney. The trial court awarded sanctions based on its finding that Attorney had violated discovery statutes. A notice of appeal was filed by K.J.'s attorney. The court of appeal dismissed the appeal for lack of jurisdiction, holding that when a sanctions order is entered against an attorney, the right of appeal is vested in the attorney and not the attorney's client. The Supreme Court reversed, holding that when it is clear from the record that the omitted attorney intended to participate in the appeal and the respondent was not misled or prejudiced by the omission, the rule of liberal construction requires that the notice be construed to include the omitted attorney. View "K.J. v. Los Angeles Unified School District" on Justia Law

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The Supreme Court affirmed Defendant's conviction of two counts of murder and one count of attempted murder and sentence of death for one murder and life imprisonment without the possibility of parole for the other murder, holding that there was no prejudicial error in the proceedings below. Specifically, the Court held (1) the trial court did not err in admitting Defendant's convictions because there was no basis to conclude Defendant's Miranda waiver was anything other than knowing, intelligent, and voluntary; (2) any error in instructing the jury was harmless; (3) Defendant's challenges to the constitutionality of California's death penalty scheme were unavailing; and (4) the potential errors in the instructions were harmless, and even considered together, the errors did not warrant reversal. View "People v. Leon" on Justia Law

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The Supreme Court held that the Probate Code grants standing in probate court to individuals who claim that trust amendments eliminating their beneficiary status arose from incompetence, undue influence, or fraud, thus reversing the decision of the court of appeal concluding that only a currently named beneficiary can petition the court concerning the internal affairs of a trust or to determine the existence of the trust under Cal. Prob. Code 17200, subdivision (a). Plaintiff, one of the daughters of Joan Lee Maynord, was a beneficiary under the Maynord Family Trust. Maynord subsequently executed a series of amendments to the trust. In these amendments Plaintiff's share of the trust was eliminated and Plaintiff was expressly disinherited. Plaintiff then filed a petition alleging the amendments disinheriting her were invalid on three grounds. The trial court dismissed the petition, concluding that Plaintiff lacked standing because she was neither a beneficiary nor a trustee under the trust. The court of appeals affirmed. The Supreme Court reversed, holding that claims that trust provisions or amendments are the product of incompetence, undue influence, or fraud should be decided by the probate court if the invalidity of those provisions or amendments would render the challenger a beneficiary of the trust. View "Barefoot v. Jennings" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court reversed the judgment of the court of appeal affirming Defendant's conviction of four felony counts of accessory after the fact to murder and one misdemeanor count of contempt of court, holding that a witness's refusal to testify in the face of a valid subpoena, while punishable as contempt, does not by itself amount to harboring, concealing, or aiding a principal within the meaning of Cal. Penal Code 32. On appeal, Defendant argued that her failure to testify did not support the accessory conviction because her silence did not fulfill the "overt or affirmative assistance" requirement of the crime of accessory. The Supreme Court agreed and reversed, holding that Defendant's silence did not constitute overt or affirmative assistance and did not transform her misdemeanor offense of contempt into four felony offenses of accessory after the fact to murder. View "People v. Partee" on Justia Law

Posted in: Criminal Law