Justia California Supreme Court Opinion Summaries

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In this case addressing whether the limitation under Cal. Unemp. Ins. Code 1253.3 that public school employees are not eligible to collect unemployment benefits under certain circumstances applies to substitute teachers and other public school employees during the summer months the Supreme Court held that a summer session does not fall within the period of unemployment benefits ineligibility mandated by 1253.3 if the summer session constitutes an "academic term." Under section 1253.3, public school employees are ineligible to collect unemployment benefits during "the period between two successive academic years or terms" if the employees worked during "the first of the academic years or terms" and received "reasonable assurance" of work during "the second of the academic years or terms." Each claimant in this case filed for unemployment benefits for the period between May 27, 2011 and August 15, 2011. The court of appeals concluded that summer sessions are not "academic terms" under section 1253.3, and therefore, the claimants were not eligible for benefits. The Supreme Court reversed, holding that a summer session is an "academic term" within the meaning of the statute if the session resembles the institution's other academic terms based on objective criteria such as enrollment, staffing, budget, instructional program or other objective characteristics. View "United Educators of San Francisco, AFT/CFT v. California Unemployment Insurance Appeals Board" on Justia Law

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The Supreme Court reversed the judgment of the court of appeal affirming the judgment of the trial court dismissing this complaint filed by Plaintiffs, two therapists and one counselor, alleging that the basic norm of confidentiality protected by the psychotherapist-patient privilege applies to admissions by certain patients of downloading or electronically viewing child pornography, holding that Plaintiffs asserted a cognizable privacy interest under the California Constitution and that their complaint survived demurrer. Specifically, Plaintiffs claimed that the 2014 amendment to Cal. Pen. Code 11165.1(c)(3), which requires Plaintiffs to report to law enforcement and child welfare authorities patients who have admitted to downloading or electronically viewing child pornography, violated their patents' right to privacy under the Fourteenth Amendment to the United States Constitution and Cal. Const. art. I, 1. Defendants filed demurrers, arguing that Plaintiffs failed to establish a valid constitutional privacy claim. The trial court dismissed the complaint, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiffs' allegations satisfied the threshold inquiry for a cognizable privacy claim. View "Mathews v. Becerra" on Justia Law

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The Supreme Court remanded this matter questioning whether Cal. Govt. Code 1092 gave Plaintiff, a citizens' taxpayer organization, statutory standing to invalidate certain contracts allegedly made in violation of Cal. Govt. Code 1090, holding that section 1092 did not provide Plaintiff a private right of action because it was not a party to the contracts. Plaintiff sued the City of San Diego and its Public Facilities Financing Authority (collectively, Defendants), asserting that aspects of a refinancing transaction in which the City sought to refinance the remaining debt on its bonds to finance the construction of Petco Park, violated section 1090. The complaint asserted that the issuance of new bonds to accomplish the refinancing violated section 1090. The trial court ruled in favor of Defendants, concluding that section 1092 confers standing only on the parties to a challenged contract. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiff cannot sue under section 1092. View "San Diegans for Open Government v. Public Facilities Financing Authority of the City of San Diego" on Justia Law

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In deciding whether the Legislature's enactment of two statutes requiring a portion of state funding provided annually to local education agencies to be used prospectively as "offsetting revenues" under Cal. Gov't Code 17557(d)(2)(B) was constitutional the Supreme Court held that the method chosen by the Legislature to pay for two existing state reimbursement mandates did not on its face violate the state Constitution. In 2010, during a period of economic recession, the Legislature enacted the two statutes at issue in this case to satisfy the two mandates. The statutes designated previously non-mandate education funding as restricted funding at the beginning of the next fiscal year to satisfy the state's obligation to reimburse school districts for the two mandates. Petitioner filed a petition for writ of mandate and complaint for injunctive and declaratory relief alleging that the two statutes violate the Constitution. The superior court denied the petition, and the court of appeal affirmed. The Supreme Court affirmed, holding that mandate reimbursement as provided by the statutes does not violate the Constitution. View "California School Boards Ass'n v. State" on Justia Law

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The Supreme Court reversed Defendant's convictions involving one of the witnesses that testified during Defendant's trial, holding that the trial court violated Defendant's right of confrontation under the Sixth Amendment by positioning a computer monitor so that the witness could not see Defendant while the witness testified and Defendant could not see the witness. Defendant was convicted of multiple sex offenses involving several minor victims. Three of the victims testified with the repositioned monitor. The court of appeal affirmed Defendant's convictions. The Supreme Court reversed in part, holding (1) as to one of the witnesses, Defendant's constitutional right of confrontation was violated when he could not see the witness and the witness testified because the trial court repositioned a computer monitor on the witness stand to allow the witness to testify without seeing Defendant; (2) as to the other two witnesses, Defendant forfeited his claim by failing to object to the trial court's action; and (3) Defendant failed to establish that he received ineffective assistance of counsel. View "People v. Arredondo" on Justia Law

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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