Justia California Supreme Court Opinion Summaries

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

A man was arrested after attempting to purchase food at a restaurant using several credit cards, three of which were lost cards belonging to other individuals. When the first five cards were declined, he discarded them; the sixth card worked, but after a dispute with the manager over a refund, he left without the food and was later taken into custody. He was charged with multiple counts, including felony vandalism, identity theft, and petty theft. At arraignment, the trial court denied his motion for release on his own recognizance and set bail at $75,000, citing his extensive criminal history and past failures to appear. After further hearings, the trial court ultimately denied bail altogether.The defendant filed a petition for writ of habeas corpus in the California Court of Appeal, First Appellate District, Division Three, challenging the denial of bail. While the petition was pending, he entered a plea agreement, resulting in his release. The appellate court dismissed the petition as moot, but the Supreme Court of California directed the Court of Appeal to address unresolved constitutional questions regarding bail. The Court of Appeal issued a published opinion addressing the relationship between two California constitutional provisions on bail and whether a trial court may set bail above a defendant’s ability to pay. The appellate court's reasoning conflicted with another appellate decision, In re Brown.The Supreme Court of California reviewed the case to resolve these issues. It held that Article I, section 12, subdivisions (b) and (c), defines the exclusive circumstances under which bail may be denied in noncapital cases, and Article I, section 28(f)(3), can be harmonized with, but does not expand, these exceptions. The court further held that, except where pretrial detention is authorized, bail must be set in an amount reasonably attainable given the defendant’s circumstances; courts may not set bail at an amount that is objectively unattainable based solely on indigency. The Supreme Court affirmed the judgment of the Court of Appeal. View "In re Kowalczyk" on Justia Law

A 16-year-old defendant and several adult associates, all affiliated with a street gang, confronted perceived rivals outside a taco truck in Modesto. During the confrontation, one of the group’s members fatally shot a rival gang member. The defendant was convicted by a jury of murder, assault with a deadly weapon, and participation in a criminal street gang. Jury enhancements were applied for crimes committed for the benefit of a gang and for personal firearm use causing death. The prosecution’s theory at trial shifted, with arguments that either the defendant was the shooter or he aided and abetted the shooting. The jury was instructed on both perpetrator and accomplice liability, using standard instructions that later case law found potentially ambiguous as to whether malice could be imputed to an accomplice.Following the passage of Senate Bill 1437 and related legislation, which restricted murder liability and created a resentencing process for those convicted under prior, broader legal theories, the defendant petitioned for resentencing under Penal Code section 1172.6. The Stanislaus County Superior Court acknowledged a prima facie case for relief, but, after an evidentiary hearing, denied the petition, finding the defendant could be convicted as either the actual killer or a direct aider and abettor. The defendant appealed, arguing the instructions allowed conviction on an impermissible imputed malice theory. The California Court of Appeal affirmed the denial, holding the defendant’s claim was not cognizable in a section 1172.6 petition because he could have raised it on direct appeal and had therefore forfeited it.The Supreme Court of California reversed. It held that Penal Code section 1172.6, subdivision (a)(3), does not categorically bar resentencing relief for petitioners who could have raised instructional challenges to imputed malice on direct appeal but did not. The court remanded the case to the Court of Appeal for consideration of the merits of the defendant’s claims. View "People v. Lopez" on Justia Law

The case concerns a mother whose two children were the subject of dependency proceedings after one child, Z.G., was found with methamphetamine in her system. The San Bernardino County Children and Family Services initiated proceedings based on allegations of parental substance abuse and domestic violence. Initially, both parents engaged in services, and the children were returned to their custody. However, after the birth of a second child, A.G., new dependency petitions were filed, and both children remained in the mother's care while the father lost custody due to ongoing concerns. Eventually, after the mother allegedly stopped cooperating with her case plan and drug testing, the children were removed from her custody. The department then moved to terminate reunification services and set a permanency planning hearing.At the disposition hearing, the juvenile court terminated reunification services for both children and set a permanency planning hearing, even though the mother had not yet received reunification services for A.G. The mother’s counsel failed to assert her statutory right to reunification services for A.G. and did not file a writ petition to challenge the termination of services or the setting of the hearing. The juvenile court subsequently terminated the mother's parental rights as to both children following a finding that they were likely to be adopted. The Court of Appeal affirmed the termination, reasoning that a finding of likely adoption was sufficient and that it lacked jurisdiction to consider challenges to the earlier order.The Supreme Court of California held that a juvenile court may not terminate parental rights based solely on a finding of likely adoption; it must also make an additional statutory finding, such as that reunification services were provided, bypassed, or properly terminated. The Court further held that the mother received ineffective assistance of counsel because her attorney failed to assert her right to reunification services and to challenge the relevant orders. The Court reversed the orders terminating parental rights and remanded for further proceedings. View "In re Z.G." on Justia Law

A property owner sought permission from San Luis Obispo County to construct single-family homes on several lots in Los Osos, an already developed coastal community. The County granted the permit, concluding the homes were an appropriate use under local zoning. However, the California Coastal Commission appealed the County’s decision to itself and denied the permit, asserting that it had appellate jurisdiction because the proposed development was situated in a sensitive coastal resource area (SCRA) under the County’s local coastal program (LCP), and because the site was designated for more than one principal permitted use.After the Commission's denial, the property owner filed a petition for a writ of administrative mandate in San Luis Obispo County Superior Court, contending the Commission lacked appellate jurisdiction on both grounds. The superior court sided with the Commission on the SCRA issue but rejected the Commission’s alternative jurisdictional basis. On appeal, the California Court of Appeal affirmed, holding the Commission properly exercised appellate jurisdiction based on the SCRA designation and did not address the alternative argument.The Supreme Court of California reviewed the case and clarified several important principles. It held that courts must exercise independent judgment—not deferential review—when determining the Commission’s appellate jurisdiction if the matter turns on legal interpretation of an LCP. The court further held that, where the Commission and a local government offer conflicting interpretations of an LCP, judicial deference to either is unwarranted when no interpretive advantage is clearly established. Examining the LCP, the court found that the proposed development was not in an SCRA as designated by the LCP. It also ruled the Commission does not have appellate jurisdiction solely because a site has multiple principal permitted uses; jurisdiction arises only if the proposed use is not among those principal permitted. The judgment of the Court of Appeal was reversed. View "Shear Development Co. v. Cal. Coastal Com." on Justia Law

Two defendants were implicated in the 1985 kidnapping, rape, and murder of a woman in California. Evidence showed that they were previously involved in a string of armed robberies and planned to escape law enforcement by stealing a vehicle from a shopping center parking lot. They kidnapped the victim, drove her hundreds of miles, sexually assaulted her, and killed her before disposing of her body in a canal. Forensic evidence, including eyewitness testimony and DNA analysis, linked both men to the crimes. Both were arrested years later after advances in DNA technology allowed for retesting of biological evidence.The Sacramento County Superior Court tried the defendants together with separate juries. Each was found guilty of murder, rape, and kidnapping, with special circumstances for kidnapping-murder, robbery-murder, and rape-murder. One defendant was also convicted of sodomy with a sodomy-murder special circumstance. Both were sentenced to death after separate penalty phase trials. The court also imposed various prison terms and restitution fines, staying the execution of the prison sentences.The Supreme Court of California reviewed the case on automatic appeal. It affirmed the convictions of both defendants and the death sentence for one. However, it reversed the death sentence for the second defendant, finding that subsequent changes in the law—specifically regarding the competency of defendants with mental illness to represent themselves—required reversal of his sentence, including the death judgment. The court also vacated any balance of restitution fines for both defendants, pursuant to recent statutory amendments. The case was remanded for further proceedings as to the sentencing of the second defendant. View "P. v. Bertsch" on Justia Law