Justia California Supreme Court Opinion Summaries

A husband and wife brought a lawsuit against a physician and his employer after the husband, working as a surgical technologist, was exposed to HIV-positive blood during a cardiac procedure. The exposure occurred when the physician discharged blood onto a sterile drape rather than into a splash bin, causing blood to splash into the husband’s eye. Following this incident, the husband underwent antiviral treatment with significant side effects and endured months of anxiety and medical testing, which also affected his marriage.The plaintiffs filed five claims, including negligence, assault, battery, unfair business practices, and loss of consortium (the latter on behalf of the wife only), in the Riverside County Superior Court. The defendants demurred to four of the claims and moved to strike several forms of relief. The trial court overruled the demurrer as to negligence but sustained it with leave to amend for the other challenged claims, and struck certain relief such as punitive damages. Before the amendment period expired, the plaintiffs voluntarily dismissed all their claims with prejudice, expressly to expedite an appeal of the trial court’s orders. After the clerk entered the dismissal, plaintiffs filed a notice of appeal. The Fourth Appellate District, Division One, dismissed the appeal for lack of jurisdiction, concluding that a voluntary dismissal is not an appealable judgment.The Supreme Court of California reviewed the matter and held that when a plaintiff voluntarily dismisses an action before the court has issued a final resolution as to any pleaded claim, the dismissal terminates the action and forfeits the right to appeal. The Court clarified that such a dismissal is a ministerial act, not a judgment that confers appellate jurisdiction. The Supreme Court affirmed the Court of Appeal’s dismissal of the appeal for lack of jurisdiction. View "Maniago v. Desert Cardiology Consultants' Medical Group" on Justia Law

The defendant was charged with several robberies and related offenses, and the prosecution alleged that he had previously served a prison term under former Penal Code section 667.5(b). The defendant pleaded no contest, admitting the prior prison term allegation. At sentencing in 2017, the Santa Clara County Superior Court found the prior prison term allegation true but exercised its discretion to strike the punishment for the enhancement in the interest of justice, without striking the allegation itself. The abstract of judgment reflected the true finding. After the Legislature enacted Penal Code section 1172.75, which retroactively invalidated most prior prison term enhancements imposed before January 1, 2020, the defendant petitioned for resentencing.The Santa Clara County Superior Court denied the petition, concluding that section 1172.75 applied only to persons for whom a section 667.5(b) enhancement was imposed and executed, not to those for whom the enhancement was stayed, stricken, or dismissed. On appeal, the Sixth District Court of Appeal reversed the superior court’s decision, holding that section 1172.75 applies whenever a prior prison term enhancement was imposed, regardless of whether the punishment was executed, stayed, or struck. A dissenting opinion argued that a punishment-stricken enhancement is not “imposed” under section 1172.75(a) because it does not lengthen a defendant’s sentence.The Supreme Court of California granted review and addressed whether section 1172.75(a) invalidates a prior prison term enhancement for which punishment was stricken. The Court held that an enhancement is “imposed” when it is made part of a legally effective sentencing order, even if the punishment is stricken. Consequently, the defendant is entitled to resentencing under section 1172.75. The Supreme Court of California affirmed the judgment of the Court of Appeal. View "People v. Espino" on Justia Law

Several individuals who were former students at an elementary school within a California school district alleged that a school counselor sexually assaulted them between 1993 and 2001. These plaintiffs initially filed lawsuits regarding the alleged abuse in California state court, then voluntarily dismissed those actions without prejudice. On the same day as those state court dismissals, they filed a similar action in the United States District Court for the Eastern District of California, alleging both state and federal claims. Before the federal court ruled on the defendant school district’s motion to dismiss, the plaintiffs again voluntarily dismissed the case, this time under Federal Rule of Civil Procedure 41(a)(1)(A)(i), designating the dismissal as without prejudice.Subsequently, the plaintiffs filed a new action in California state court based on the same underlying facts. The school district demurred, arguing that the so-called two-dismissal rule in Federal Rule 41(a)(1)(B)—which states that a plaintiff who twice voluntarily dismisses claims is subject to an adjudication on the merits—operated as a bar to the new state court action. The Yuba County Superior Court agreed, sustaining the district’s demurrer without leave to amend, and entered a judgment of dismissal. The California Court of Appeal, Third Appellate District, affirmed in a split decision, holding that the federal procedural rule precluded the state court claims.The Supreme Court of California reversed. The court held that Federal Rule 41(a)(1)(B) is a procedural rule that limits a plaintiff’s ability to refile the same claim in federal court but does not itself create a rule of claim preclusion applicable in state courts. Therefore, a second voluntary dismissal under Rule 41(a)(1)(B) does not bar a subsequent suit on the same state law claims in California state court. The matter was remanded for further proceedings. View "Doe v. Marysville Joint Unified School Dist." on Justia Law

A defendant faced five separate criminal cases, each involving different charges of burglary, theft, and related offenses. The defendant was arrested and held in custody for varying periods in each case, sometimes being out on bail or released on his own recognizance in one or more cases while remaining in custody for others. Ultimately, all five cases were resolved together through a plea agreement, and the defendant was sentenced at a single hearing, receiving concurrent sentences in each matter.After sentencing, the defendant requested that the trial court award presentence custody credits in each case for all time served in custody on any of the cases, not just the time specifically attributable to each individual case. The Monterey County Superior Court declined, awarding presentence credits in each case only for custody time attributable to that particular case. The defendant appealed, and the California Court of Appeal, Sixth Appellate District, reversed. The appellate court concluded that, because all five cases were resolved and sentenced at one hearing, the defendant should receive custody credits in each case for all time spent in custody on any of the cases, except for time that preceded the arrest in a specific case.The Supreme Court of California reviewed the case. It held that, under Penal Code section 2900.5, subdivision (b), the term “proceedings” refers to a single criminal case, not all cases resolved at one sentencing hearing. Therefore, custody credits must be awarded in each case only for the time the defendant was actually in custody in that case, not time served in other cases, even if the cases were resolved and sentenced together. The Supreme Court of California reversed the judgment of the Court of Appeal. View "P. v. Cofer" on Justia Law

A company with a lease in the Brentwood Oil Field, Contra Costa County, proposed to convert an inactive oil and gas extraction well into a water injection well for disposing of treated wastewater, a byproduct of oil and gas drilling. The well in question had been built in 1963, used for extraction until 1984, and then plugged. The company currently disposed of wastewater by trucking it offsite but sought to inject it underground instead. Regulatory agencies, including CalGEM, the State Water Board, and the Regional Water Board, expressed concerns about potential contamination of local clean water sources due to possible migration of wastewater. After additional technical analysis and the imposition of specific project conditions, these concerns were resolved, and CalGEM approved the project, issuing a notice of exemption (NOE) under the California Environmental Quality Act (CEQA), relying on the “class 1” categorical exemption for minor alterations of existing facilities with negligible expansion of use.The Contra Costa County Superior Court found substantial evidence did not support CalGEM’s determination that the project fell within the class 1 exemption, concluding that converting an oil and gas well into a water injection well did not constitute negligible or no expansion of former use. CalGEM agreed to comply with the writ. On appeal, the First Appellate District, Division Five, reversed, holding that the exemption applied because the environmental risks of the new use were negligible.The Supreme Court of California reviewed the case and reversed the Court of Appeal’s judgment. The Supreme Court held that the phrase “negligible or no expansion of existing or former use” in the class 1 exemption refers to the nature or degree of a structure or facility’s use, not to the risk of environmental harm caused by such a change. The court remanded the case for reconsideration under this proper framework and did not reach the additional question regarding project conditions as mitigation. View "Sunflower Alliance v. Dept. of Conservation" on Justia Law

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