Justia California Supreme Court Opinion Summaries

Defendant was convicted of crimes arising out of two separate assaults. At issue was whether California courts could apply a higher standard of mental competence for self-representation than for competency to stand trial in light of the Supreme Court's holding under Indiana v. Edwards. Because California law has long been that criminal defendants have no right of self-representation, the court concluded that California courts could deny self-representation when the U.S. Constitution permitted such denial. The court also concluded that the trial court acted within its discretion in revoking defendant's self-representation status. View "People v. Johnson" on Justia Law

A proposed referendum in this case would require the electorate to decide at the November 2012 general election whether to accept or reject the California state Senate district map certified by the Citizens Redistricting Commission. If the referendum qualifies, the state Senate map certified by the Commission would automatically be stayed, presenting the question of what Senate districts should be used for the 2012 primary and general elections of the State. The Supreme Court held (1) if the proposed referendum qualifies for the November 2012 general election ballot and triggers a stay of the Commission's certified Senate district map, the Commission's state Senate map should be used on an interim basis for the June and November 2012 elections, pending the outcome of the referendum; and (2) if the proposed referendum does not qualify for the ballot, the Commission's state Senate map will continue to be used for the 2012 election and future elections until replaced pursuant to Cal. Const. art. XXI by new maps drawn by a future newly constituted Commission following the 2020 census. View "Vandermost v. Bowen" on Justia Law

Defendant was convicted of first degree murder and the jury made true findings as to the burglary-murder and robbery-murder special circumstances. The jury was fully instructed as to the elements of the felony-murder special circumstances for a defendant who was the actual killer. However, the jury was not fully instructed as to the elements of the special circumstances for a defendant who was not the actual killer, including the requirement that a nonkiller, in the absence of a showing of intent to kill, must have acted with reckless indifference to human life and as a major participant in the commission of the underlying felony. The Court of Appeal determined the omission in the instructions was harmless and affirmed the judgment. The court agreed that the instructional error was amenable to harmless-error review, but found that the error here was prejudicial. Therefore, the court reversed the jury's findings on the special circumstances of burglary murder and robbery murder, as well as defendant's sentence of life imprisonment without the possibility of parole, remanding the matter for further proceedings. View "People v. Mil" on Justia Law

In 2006, a jury awarded plaintiffs for breach of contract, and the trial court awarded plaintiffs costs and attorney and expert witness fees. Defendant appealed the judgment. At issue on appeal was whether Cal. Rules of Court, rule 8.278's reference to "the cost to obtain a letter of credit" extended to the interest expense incurred by an appellant to borrow funds to secure a letter of credit that was obtained to secure an appeal bond posted to stay enforcement of a money judgment during the pendency of the appeal. The court adopted a restrictive meaning of the reference and held that rule 8.278(d)(1)(F) did not authorize an award of costs for interest expenses and fees incurred to borrow funds to deposit as security for a letter of credit that was procured to secure an appeal bond. Accordingly, the court affirmed the judgment of the Court of Appeal. View "Rossa v. D.L. Falk Construction, Inc." on Justia Law

Defendants, makers of valves and pumps, were sued for a wrongful death allegedly caused by asbestos released from external insulation and internal gaskets and packing, all of which were made by third parties and added to the pumps and valves post sale. This case involved the limits of a manufacturer's duty to prevent foreseeable harm related to its product. At issue was when was a product manufacturer liable for injuries caused by adjacent products or replacement parts that were made by others and used in conjunction with defendant's product. The court held that a product manufacturer could not be held liable in strict liability or negligence for harm caused by another manufacturer's product unless defendant's own product contributed substantially to the harm, or defendant participated substantially in creating a harmful combined use of the products. Accordingly, the decision of the Court of Appeal was reversed and the case remanded for entry of judgment of nonsuit in favor of defendants. View "O'Neil, et al. v. Crane Co., et al." on Justia Law

Defendant, a 15-year-old, was tried as an adult and convicted of the murder of a 72-year-old and of five first degree burglaries relating to the residences of the victim and two other women. At issue was whether defendant made a postwaiver invocation of his Miranda rights by asking several times to speak to his mother or by making certain other statements while being questioned. The court held that juveniles claiming a postwaiver invocation of their Miranda rights were properly subject to the Davis v. United States standard. Applying that standard, the court concluded that the trial court did not err in finding that defendant's requests to speak to his mother and other statements were not sufficiently clear to require cessation of the interrogation. Accordingly, defendant's confessional statements were properly admitted at trial, and the contrary judgment of the Court of Appeal must be reversed. View "People v. Nelson" on Justia Law

Defendant was convicted, among other things, for first degree murder and sentenced to death. The jury found that the murder was committed during the course of robbery, kidnapping, rape, and sexual penetration by a foreign object, and that it involved the infliction of torture. On automatic appeal, the court affirmed the convictions of first degree murder and the other charged felonies. The court reversed as to the sentence of death, the jury's findings that defendant personally used a dangerous or deadly weapon, the jury's true finding on the special circumstance of murder with the infliction of torture, and the state prison sentence. The court remanded for a new penalty trial and for resentencing. View "People v. Pearson" on Justia Law

Defendant was convicted by a jury of a petty theft offense, but admitted a prior felony conviction. Defendant appealed only the admission of the prior conviction. At issue was whether Penal Code section 1237.5 applied under these circumstances. The court held that People v. Fulton erroneously determined that section 1237.5 applied to appeals where the defendant had not pleaded guilty or nolo contendere. The court also held that section 1237.5's underlying purpose of promoting economy would not be advanced by extending it to convictions after pleas of not guilty. Accordingly, the court reversed the Court of Appeal and remanded for further proceedings. View "People v. Maultsby" on Justia Law

The Association sought extraordinary writ relief from the court, arguing that two measures intended to stabilize school funding by reducing or eliminating the diversion of property tax revenues from school districts to the state's community redevelopment agencies, was unconstitutional. At issue was whether the state Constitution (1) redevelopment agencies, once created and engaged in redevelopment plans, have a protected right to exist that immunized them from statutory dissolution by the Legislature; and (2) redevelopment agencies and their sponsoring communities have a protected right not to make payments to various funds benefiting schools and special districts as a condition of continued operation. Answering the first question "no" and the second "yes," the court largely upheld Assembly Bill 1X 26 and invalidated Assembly Bill 1X27. The court held that Assembly Bill 1X 26, the dissolution measure, was a proper exercise of the legislative power vested in the Legislature by the state Constitution. The court held that Assembly Bill 1X 27, the measure conditioning further redevelopment agency operations on additional payments by an agency's community sponsors to state funds benefits schools and special districts, was invalid. View "Cal. Redevelopment Assoc., et al. v. Matosantos, et al." on Justia Law

Petitioner was convicted of second degree murder committed in 1987, and was sentenced to a term of 15 years to life in prison with a two-year enhancement for firearm use. At issue was whether a majority of Division One of the Fourth District Court of Appeal properly applied the "some evidence" standard to a decision denying parole for petitioner. The court concluded that the Court of Appeal majority had again invaded the province of the parole authority, in this case the Board of Parole Hearings. The court also offered general guidance to the Courts of Appeal on inmates' lack of insight as a parole unsuitability factor. View "In re Shaputis" on Justia Law