Justia California Supreme Court Opinion Summaries

Defendant was convicted of violating Penal Code section 246 by standing outside his truck and shooting a passenger. Defendant argued that because the gun had crossed the threshold of the truck at the time of the shooting, the gun was not "discharged 'at' the vehicle" but was instead discharged "within" the vehicle. Although the court agreed that the statutory text alone was susceptible of more than one interpretation, reliable extrinsic evidence aids to statutory construction convinced the court that the Legislature intended section 246 to apply to a person standing outside an occupied motor vehicle and shooting into it, even if the gun had crossed the plane of the vehicle. Because the court could discern the Legislature's intent, there was no need to invoke the rule of lenity. Therefore, the court reversed the judgment. View "People v. Manzo" on Justia Law

C.A., a minor, sued his public high school guidance counselor and the school district for damages arising out of sexual harassment and abuse by the counselor. At issue was whether the district court could be found vicariously liable for the acts of its employees - not for the acts of the counselor, which were outside the scope of her employment, but for the negligence of supervisory or administrative personnel who allegedly knew, or should have known, of the counselor's propensities and nevertheless hired, retained, and inadequately supervised her. The court concluded that plaintiff's theory of vicarious liability for negligent hiring, retention, and supervision was a legally viable one. Ample case authority established that school personnel owed students under their supervision a protective duty of ordinary care, for breach of which the school district could be held vicariously liable. If a supervisory or administrative employee of the district was proven to have breached that duty by negligently exposing plaintiff to a foreseeable danger of molestation by his guidance counselor, resulting in his injuries, and assuming no immunity provision applied, liability fell on the school district. Accordingly, the court reversed the judgment. View "C.A. v. William S. Hart Union High School, et al. " on Justia Law

A jury convicted defendant of the first degree murder of the victim, also finding that he had personally used a firearm in the commission of the offense and finding true the circumstance that defendant had committed the murder during the course of a robbery. The jury imposed the death sentence. On appeal, the court addressed pretrial and guilt phase issues, as well as penalty phase issues. The court concluded that the outcome of the trial was unaffected by any errors that occurred and affirmed the judgment of the district. View "People v. Abel" on Justia Law

Plaintiffs brought an action against the Roman Catholic Bishop of Oakland, alleging that defendant bore responsibility for sexual abuse committed during the 1970's by a priest then assigned to the Oakland diocese. Plaintiffs alleged that they discovered for the first time that the cause of their adult psychological injuries was the sexual abuse inflicted by this priest when they were children. At issue was whether their claims were within the limitations period established by Code of Civil Procedure section 340.1. The court held that the revival of any lapsed claims against the subcategory of defendants identified in the 2002 amendments was governed by subdivision (c) of section 340.1. The court also established that as of 1998, plaintiffs' claims necessarily had lapsed and plaintiffs' claims were not revived by the 1999 amendments, but for one year only. Because they did not file their claims within that year, their claims were barred under the applicable statute of limitations. Accordingly, the court reversed and remanded for further proceedings. View "Quarry v. Doe I" on Justia Law

Defendant was convicted of second degree murder of one victim and two first degree murders of officers. The jury found true special circumstances allegations that the officers were killed while engaged in the performance of their duties and that defendant was convicted of more than one murder. On automatic appeal, the court modified the judgment to correct the sentence imposed on count 1 for second degree murder where the trial court made an error in imposing a sentence of death for count 1, an offense that was not punishable by death. The court affirmed defendant's convictions and death sentence in all other respects. View "People v. Thomas" on Justia Law

Defendant was convicted of the first degree murder of a Los Angeles County Deputy Sheriff and the premeditated attempted murder of the deputy sheriff's partner. The jury found true the special circumstance allegations that the murder of the deputy sheriff was committed for the purpose of avoiding and preventing a lawful arrest and that the deputy sheriff was a peace officer engaged in the performance of his duties when defendant knowingly and intentionally killed him. The jury also found true the allegations that defendant personally used a firearm in the murder and attempted murder, previously had been convicted of a serious felony, and had served two prior prison terms. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues related to the denial of a motion for discovery of law enforcement officers' personnel files; the denial of a motion to continue the trial; asserted errors during voir dire; guilt phase challenges; penalty phase challenges; assertedly improper denial of motion for new trial based upon insufficiency of the evidence; assertedly improper role of race in the proceedings; asserted denial of an impartial judge; challenges to the constitutionality of California's death penalty statutes; and cumulative prejudicial effects of asserted errors. View "People v. Fuiava" on Justia Law

Defendant was convicted of first degree murder of two victims, with a multiple-murder special circumstance finding. Defendant was also convicted of assault with a deadly weapon on another victim, with a a great bodily injury finding. Firearm use and criminal street gang findings were made as to all three counts. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues involving the admissibility of defendant's confession; the trial court's refusal to instruct on heat of passion; instructions on perfect and imperfect self-defense; defendant's waiver of his right to testify; victim impact evidence; asserted improper prosecutorial argument; lack of remorse; refusal to instruct on lingering doubt; and challenges to the death penalty law and instructions. View "People v. Enraca" on Justia Law

Defendant was convicted of murder in the first degree with the special circumstance of murder during the commission of a robbery and sentenced to death. Defendant was also convicted of robbery and assault with a deadly weapon, using a handgun to commit both the robbery and assault. On automatic appeal, the court addressed pretrial and jury selection issues; issues relating to guilt; issues relating to penalty; and the adequacy of the appellate record. The court ultimately affirmed the judgment. View "People v. Elliott" on Justia Law

Defendant was sentenced to death on a first degree murder conviction by trying to suffocate the victim, putting her in the trunk of a car and driving to a remote location, pouring gasoline on her and the outside of the trunk, and lighting the gasoline on fire. The victim burned to death trapped inside of the trunk. On automatic appeal, the court affirmed the convictions of first degree murder and the other charged felonies, but the court reversed as to the penalty of death and set aside the kidnapping special circumstances finding because the trial court erroneously instructed the jury. View "People v. Brents" on Justia Law

Defendant was convicted of various crimes against a number of victims. At issue was whether there was sufficient evidence to support defendant's conviction of second degree murder under a theory of implied malice when defendant cracked the victim's skull by punching him during a fight. The Court of Appeal reduced the conviction to voluntary manslaughter because of insufficient evidence of implied malice, focusing solely on the subjective component of implied malice. The court held, however, that the evidence was sufficient to satisfy both the physical and mental components of implied malice. Accordingly, the court held that the Court of Appeal erred in finding otherwise. View "People v. Cravens" on Justia Law