Justia California Supreme Court Opinion Summaries

After a school district (District) approved the conversion of an existing public school into a charter school, a union (UTLA) claimed that the District failed to comply with collective bargaining agreement provisions (CBPs) concerning charter school conversion. UTLA petitioned to compel arbitration pursuant to the collective bargaining agreement. The trial court denied the petition, finding that the collective bargaining provisions (CBPs) regulating charter school conversion were unlawful because they conflicted with the Education Code, and therefore, arbitration of those unlawful provisions should not be compelled. The court of appeals reversed, holding that the court's function in adjudicating a petition to compel arbitration was limited to determining whether there was a valid arbitration agreement that had not been waived. The Supreme Court reversed, holding (1) a court faced with a petition to compel arbitration to enforce CBPs between a union and a school district should deny the petition if the CBPs at issue directly conflict with provisions of the Education Code; and (2) because UTLA had not identified with sufficient specificity which CBPs the District allegedly violated, the case was remanded for identification of those specific provisions and to address whether the provisions conflicted with the Education Code. View "United Teachers of L.A. v. L.A. Unified Sch. Dist." on Justia Law

A high school security officer arrested minor M.M. for vandalism. The county district attorney's office filed an amended petition alleging that the minor had resisted or delayed a public officer in violation of Cal. Penal Code 148(a)(1) and had committed misdemeanor vandalism. The juvenile court found a school security officer was a public officer within the meaning of section 148(a)(1), and found true the allegations that the minor had resisted or delayed a public officer and of misdemeanor vandalism. The court of appeal reversed, concluding that a school security officer is not a public officer within the meaning of section 148(a)(1). The Supreme Court reversed, holding that school security officers, like sworn peace officers, fall within the protection of section 148(a)(1). Remanded. View "In re M.M." on Justia Law

In 1984 a jury convicted Defendant of first degree murder, attempted murder, attempted rape, and burglary. After a penalty trial, the jury set the penalty at death. The Supreme Court affirmed. In 1997, the Ninth Circuit Court of Appeals, while affirming the federal district court's denial of Defendant's petition for writ of habeas corpus as to the guilt phase, reversed its denial of the writ as to the death sentence. After the first retrial of the penalty phase resulted in a mistrial, a second penalty retrial was held, in which the jury returned a verdict of death. The Supreme Court affirmed, holding (1) the second penalty retrial was constitutional; (2) the trial court did not err by excusing prospective jurors; (3) the court did not erroneously admit victim impact evidence and giving related instructions; (4) the court did not err in excluding proffered defense expert opinion testimony or mitigating evidence; (5) there was no prejudicial prosecutorial misconduct; and (6) California's death penalty law and related standard jury instructions were constitutional and lawful. View "People v. McDowell" on Justia Law

At issue in this case was what attorney work product production, if any, should be accorded (1) recordings of witness interviews conducted by investigators employed by defendant's counsel, and (2) information concerning the identity of witnesses from whom defendant's counsel was obtained statements. Defendant objected to Plaintiff's request for discovery of these items, invoking the work product privilege. The trial court sustained the objection, concluding as a matter of law that the recorded witness interviews were entitled to absolute work product protection and that the other information sought was work product entitled to qualified protection. A court of appeals reversed, concluding that work product protection did not apply to any of the disputed items. The Supreme Court reversed, holding (1) the recorded witness statements were entitled as a matter of law to at least qualified work product protection; and (2) information concerning the identity of witnesses from whom Defendant's counsel has obtained statements is entitled to protection if (a) Defendant can persuade the trial court that disclosure would reveal the attorney's tactics, impressions, or evaluation of the case (absolute privilege); or (b) disclosure would result in opposing counsel taking undue advantage of the attorney's industry or efforts (qualified privilege). View "Coito v. Superior Court" on Justia Law

The South Coast Air Quality Management District is charged with regulating nonvehicular air pollution emissions in regions that have some of the worst air pollution in the country. This case concerned the District's 2002 amendments to its Rule 1113, which limits certain pollution-causing substances in paints and coatings. The American Coatings Association challenged the amendments on the ground they exceeded the District's regulatory authority under statutes requiring the use of "best available retrofit control technology." At issue was whether the technology was "available" under the statute. The superior court held that the rule was within the District's authority. The court of appeal reversed in part, concluding that the statutory phrase "best available retrofit control technology" meant technology that was available or capable of being readily assembly when the amendments were promulgated. The Supreme Court reversed in part, holding (1) the relevant statutes give the District the authority to promulgate pollution standards based on technologies that do not currently exist but are reasonably anticipated to exist by the compliance deadline; and (2) the District sufficiently demonstrated that its challenged emissions limits were achievable in each paint and coating category in Rule 1113 and that the categories were reasonably drawn. View "Am. Coatings Ass'n v. S. Coast Air Quality Dist." on Justia Law

Defendant, a convicted felon, carried a loaded and concealed firearm. A jury convicted Defendant of possession of a firearm by a felon, carrying a readily accessible concealed and unregistered firearm, and carrying an unregistered loaded firearm in public. Defendant appealed, arguing that Cal. Penal Code 654, which prohibits multiple punishment for an act that is punishable in different ways by different provisions of law, prohibited multiple punishment for his convictions. The court of appeal modified the judgment to stay execution of the sentence on count three and affirmed the judgment as modified. The Supreme Court reversed, holding that because different provisions of law punish in different ways Defendant's single act, section 654's plain language prohibits punishment for more than one of those crimes. Remanded. View "People v. Jones" on Justia Law

After police found Defendant Victor Correa hiding in a closet with a cache of guns, Defendant was convicted of seven counts of being a felon in possession of a firearm. The court of appeal affirmed. The Supreme Court initially limited review to the question of whether imposing sentence on more than one of these counts violated Cal. Penal Code 654's prohibition against multiple punishment for the same criminal act. The Court then requested supplemental briefing on the question of whether section 654 applies to multiple violations of the same criminal statute. The Supreme Court affirmed, holding (1) by its plain language, section 654 does not bar multiple punishment for multiple violations of the same criminal statute, but this interpretation was not applied to Defendant because the new rule may be applied prospectively only; and (2) even so, Defendant's sentence did not violate section 654 because specific statutory authority makes possession of each weapon a separate offense. View "People v. Correa" on Justia Law

Defendant MBNA America Bank issued a credit card to Plaintiff Allan Parks. As part of its service to cardholders, MBNA extended credit to Plaintiff by sending him convenience checks that did not include disclosures required by Cal. Civ. Code 1748.9. Plaintiff later sued MBNA on behalf of himself and similarly situated MBNA customers, alleging that the bank engaged in unfair competition by failing to make the disclosures mandated by section 1748.9. MBNA argued that the National Bank Act of 1864 (NBA) preempted the state disclosure law. The trial court granted judgment on the pleadings on MBNA's motion, concluding that the bank's failure to attach the statutorily mandated disclosures to its convenience checks was not unlawful. The court of appeal reversed. The Supreme Court reversed the court of appeal, holding that NBA preempts section 1748.9 because the state law standards act as an obstacle to the broad grant of power given by the NBA to national banks to conduct the business of banking. Remanded. View "Parks v. MBNA Am. Bank, N.A." on Justia Law

Penal Code section 4019 has offered prisoners in local custody the opportunity to earn conduct credit against their sentences for good behavior. For eight months during 2010, a now-superseded version of section 4019 that was enacted during a state fiscal emergency temporarily increased the rate at which local prisoners could earn conduct credits. At issue was whether this former statute retroactively benefited prisoners who served time in local custody before January 25, 2010, the date on which it became operative. The court held that former section 4019 applied prospectively, meaning that qualified persons in local custody first became eligible to earn credit for good behavior at the increased rate beginning on the statute's operative date. The court also held that the equal protection clauses of the federal and state constitutions did not require retroactive application. View "People v. Brown" on Justia Law

This case arose when petitioner filed a petition for writ of mandate in the Lassen Superior Court, seeking to require the prison to process four administrative appeals of grievances that he had filed. At issue was whether a court commissioner had the authority to summarily deny a petition for writ of mandamus or habeas corpus under Code of Civil Procedure section 259, subdivision (a), which authorized commissioners to hear and determine ex parte motions for orders and alternative writs and writs of habeas corpus. The court concluded that section 259(a) did grant this authority to commissioners and that, at least when the petition sought to enforce a prisoner's rights while in confinement - but did not seek to collaterally attack the criminal conviction that provided the basis for that confinement - the summary denial of a writ petition constituted a subordinate judicial duty properly undertaken by a commissioner within the meaning of article VI, section 22 of the California Constitution. View "Gomez v. Super. Ct." on Justia Law