Justia California Supreme Court Opinion Summaries

Defendant, driving while intoxicated, killed another driver instantly in a freeway collision. The accident left no surviving family, dependents, or heirs. Defendant was convicted and sentenced to prison. In addition, pursuant to the statute requiring that persons convicted of felonies pay restitution to the crimes' victims for their resulting economic loss, Defendant was also ordered to pay substantial restitutionary amounts to Decedent's estate. The award represented death-related loss in value of the decedent's business and property, and probate, estate administration, and funeral expenses. The court of appeal affirmed the award. The Supreme Court reversed, holding (1) mandatory restitution is not payable to the estate for economic loss the estate itself has sustained as a result of the death, but the decedent's personal representative is entitled to collect mandatory restitution on the decedent's behalf for economic loss the decedent personally incurred before death as an actual victim of the defendant's criminal conduct; (2) after the actual victim has died, he or she does not incur personal economic loss subject to mandatory restitution; and (3) there was no valid basis for any of the mandatory restitution amounts awarded to the estate in this case. View "People v. Runyan" on Justia Law

A jury found Defendant John Alexander Riccardi guilty of the first degree murders of Connie Navarro and Sue Jory by use of a firearm. The jury also found true the special circumstance allegations of multiple murder and that Defendant committed Connie's murder while engaged in the commission of a burglary. Subsequently, the jury fixed the penalty at death. The Supreme Court (1) reversed the judgment of death because of the erroneous excusal of a prospective juror during jury selection; (2) reversed the burglary special circumstance and one of the two multiple-murder special-circumstance findings; and (3) affirmed in all other respects. View "People v. Riccardi" on Justia Law

A jury found Defendant guilty of robbery, as an aider and abetter, and attempted murder, on the theory that the nontarget offenses of attempted murder were a natural and probable consequence of the target offenses of robbery, which Defendant had aided and abetted. The jury further found that the attempted murders were willful, deliberate, and premeditated under Cal. Penal Code 664(a), which increases the punishment for attempted murder beyond the maximum otherwise prescribed when those findings are found true by the trier of fact. At issue on appeal was whether, as to the premeditation allegation under section 664(a), the jury needs to be instructed that a premeditated attempt to murder, not just attempted murder, must have been a natural and probable consequence of the target crime of robbery. The Supreme Court affirmed the court of appeal, holding (1) under the natural and probable consequences doctrine, there is no requirement that an aider and abettor reasonably foresee an attempted murder as the natural and probable consequence of the target offense; and (2) it is sufficient that attempted murder is a reasonably foreseeable consequence of the crime aided and abetted, and the attempted murder itself was committed willfully, deliberately, and with premeditation. View "People v. Favor" on Justia Law

Defendant, a prison inmate, was charged with escape from custody. However, Defendant only broke out of his cell and breached interior security barriers. The jury found Defendant guilty of escape from prison without force or violence. The court of appeal reversed, finding insufficient evidence of escape and concluding that the term "escape" under the relevant statute required an actual escape beyond the outer boundary of the prison facility having custody of that prisoner. The court refused to modify the escape conviction to attempt to escape. The Supreme Court affirmed, holding that the court of appeal correctly determined it could not modify the escape conviction to an attempt to escape, as the record contained evidence that could lead a rational jury to find the element of specific intent lacking. View "People v. Bailey" on Justia Law

Defendant entered a plea of no contest to felony vandalism for vandalizing a pickup truck, extensively denting it and damaging the driver's side door. The trial court ordered restitution in the amount of $2,812, reflecting an automotive body shop's written estimate of repair cost. The court of appeal affirmed, rejecting Defendant's contention that the trial court should have limited restitution to the victim's $950 purchase price of the used truck. In reaching that conclusion, the court of appeal expressed its agreement with a decision by another court of appeal, In re Dina V., but its disagreement with the opposite holding in People v. Yanez. The Supreme Court affirmed after agreeing with the conclusion reached in Dina V., holding that a trial court's restitution award need not be limited to the lesser of the replacement cost of the victim's damaged property or the actual cost of repairing the property when repair is possible. View "People v. Stanley" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, burglary, and robbery. The trial court sentenced Defendant to death. The Supreme Court remanded the case, holding that the trial court committed reversible error by permitting Defendant to represent himself during proceedings to determine whether he was mentally competent to stand trial. To remedy the error, the Court remanded the case for further proceedings to allow the trial court to determine whether a retrospective evaluation of Defendant's competence to stand trial was feasible and, if it was, to hold such a hearing. If the trial court determined that such a hearing was not feasible or Defendant was incompetent, Defendant was entitled to a new trial. View "People v. Lightsey" on Justia Law

Defendant Perla Gonzalez (Perla) recruited her brother and her boyfriend to assault Roberto Canas-Fuentes (Canas). After Canas fended off a knife attack and gained the upper hand in the fight, Perla handed the boyfriend a loaded rifle. Canas wrested the rifle away and shot the boyfriend dead. The jury convicted Perla of the attempted premeditated and deliberate murder of Canas and, based on the provocative act doctrine, the first degree murder of her boyfriend. The Supreme Court affirmed, holding (1) substantial evidence supported Perla's conviction for the murder of her boyfriend; and (2) the trial court erred in instructing the jury on the requirements for premeditated and deliberate first degree murder, but the error was harmless beyond a reasonable doubt. View "People v. Gonzalez" on Justia Law

In this case Father's two young children were adjudged juvenile court dependents, in part because of findings under Cal. Code Welf. & Inst. 300(f), which allows an initial adjudication of dependency if a child's parent caused the death of another child through abuse or neglect. These findings were based on evidence that, in violation of law, Father transported his third child, an eighteen-month-old daughter, in an automobile without securing her in a child safety seat, and she was fatally injured when another vehicle collided with their car. The court of appeal affirmed the juvenile court's judgment. The Supreme Court affirmed, holding (1) section 300(f) does not limit is application to criminal negligence but allows the juvenile court to adjudge a child a dependent if the court finds that the want of ordinary care by the child's parent or guardian caused another child's death; (2) the juvenile court may adjudicate dependence under section 300(f) without any additional evidence or finding that the circumstances surrounding the parent's or guardian's fatal negligence indicate a present risk of harm to surviving children in the parent's or guardian's custody; and (3) the normal concepts of legal causation apply under section 300(f). View "Los Angeles Dep't of Children & Family Servs." on Justia Law

On February 10, Donald Smith and Christopher Sims were charged with felony first degree residential burglary. Smith did not waive his statutory right to be brought to trial within sixty days of his arraignment, but the trial date of Sims was continued beyond the sixty-day period for good cause. The trial was set for April 27, which meant that the last day for trial, pursuant to Cal. Penal Code 1382, was May 7. On May 1, Smith sought a writ of mandate in the court of appeal to stay further trial court proceedings against him. The court of appeal directed the superior court to enter an order dismissing the information pending against Smith. The Supreme Court reversed, holding (1) under section 1382, when one codefendant's trial is continued to a date within section 1382's ten-day grace period, the state's strong interests in joinder provide good cause to continue the trial for all properly joined codefendants to the same date within the ten-day period; and (2) therefore, the trial court did not abuse its discretion in continuing Smith's trial to a date within the ten-day period in order to permit Smith and Sims to be joined in a single trial. View "Smith v. Superior Court" on Justia Law

A charter city entered into certain contracts for the construction of public buildings. A federation of labor unions then petitioned the superior court for a peremptory writ of mandate, asserting that the city must comply with California's prevailing wage law notwithstanding local ordinances stating otherwise. The prevailing wage law requires that certain minimum wage levels be paid to contract workers constructing public works. At issue on appeal was whether, under the state constitution, the subject matter of the state's prevailing wage law was a "statewide concern" over which the state has primary legislative authority, or whether the matter was a municipal affair and therefore governed by the charter city's local ordinances. The Supreme Court affirmed the court of appeal, which in turn affirmed the trial court's judgment denying the union's petition for a writ of mandate, holding that there was no statewide concern at issue in this case, and therefore, the state's prevailing wage law did not apply to the charter city. View "State Bldg. & Constr. Trades Council v. City of Vista" on Justia Law