Justia California Supreme Court Opinion Summaries

This case stemmed from the City of Manhattan Beach's adoption of an ordinance banning the use of "point-of-sale plastic carry-out bags" in the city. Plaintiff, a coalition of plastic bag manufacturers and distributors, claimed standing to maintain a citizen suit to vindicate the public interest in environmental quality. At issue was what were the standing requirements for a corporate entity to challenge a determination on the preparation of an environmental impact report (EIR) and whether the city was required to prepare an EIR on the effects of the ordinance. The court held that plaintiff would qualify for public interest standing here and disapproved Waste Management of Alameda County, Inc. v. County of Alameda's holding that corporations were subject to heightened scrutiny when they filed citizen suits. The court also held that plaintiff, which represented businesses directly affected by the ordinance, had standing in its own right to challenge the city's analysis of environmental impacts. On the merits, the court held that substantial evidence and common sense support the city's determination that its ordinance would have no significant environmental effect. Therefore, a negative declaration was sufficient to comply with the requirements of the California Environmental Quality Act (CEQA), Pub. Resources Code, section 21000 et seq. Accordingly, the judgment was reversed. View "Save the Plastic Bag Coalition v. City of Manhattan Beach" on Justia Law

Petitioner was convicted of one count of murder and one count of grand theft where the jury found true a special circumstance allegation that the murder was for financial gain. Petitioner was sentenced to death for the murder and on automatic appeal, the court affirmed the judgment. Petitioner timely filed a petition for a writ of habeas corpus seeking relief from the judgment and alleging, among other things, ineffective representation by his trial counsel at the penalty phase of his capital trial for failing to adequately investigate and present mitigating evidence. The court held that petitioner had not established that he was entitled to habeas corpus relief on his claim that his trial counsel was ineffective. The court also held that because the order to show cause and the court's reference order were limited to this claim, the court would not address any other claim set forth in the petition, which would be resolved by separate order. Accordingly, the order to show cause was discharged. View "In re Crew" on Justia Law

Defendant was convicted of first degree murder of a prison inmate where the jury found that defendant used a deadly weapon in the commission of the murder and found true the special circumstance of allegations of prior convictions of first degree murder and lying in wait. The jury further convicted defendant of assault with a deadly weapon by a life prisoner and found he had been convicted in 1988 of three counts of first degree murder. Defendant was sentenced to death and this appeal was automatic. The court addressed claims regarding the denial of defendant's motion for separate juries for the guilty phase and the special circumstance and penalty phase; excusal for cause of prospective Juror No. 3; refusal to excuse for cause of Prospective Juror No. 8; introduction of evidence that defendant was a white supremacist; instructional error; whether defendant's death sentence was cruel and unusual punishment because it was based primarily on prior murders committed when he was a juvenile; and California's death penalty statute. The court subsequently affirmed the judgment of the superior court. View "People v. Bivert" on Justia Law

Defendant was convicted of first degree murder under the special circumstance that the murder was committed while defendant was engaged in kidnapping and in the commission or attempted commission of sodomy and defendant was sentenced to death. On automatic appeal, defendant raised issues related to motions for change of venue; failure to conduct individual sequestered jury selection; the claim of instructional error concerning concealment of evidence; the claim of instructional errors related to the standard of proof; the claim of improper instructions on first degree premeditated murder; admission of victim impact evidence; the trial court's refusal to admit allegedly mitigating evidence; instruction on the credibility of a single witness; admission of unadjudicated conduct; instruction on aggravating and mitigating factors; instruction on scope of sentencing discretion; miscellaneous issues concerning California's death penalty law; and cumulative error. The court discussed each issue and held that the judgment was affirmed. View "People v. Famalaro" on Justia Law

Defendant was convicted of first degree murder under the special circumstance of a murder engaged in the commission of a lewd and lascivious act on a child under the age of 14 and sentenced to death. On automatic appeal, defendant raised issues related to comments to prospective jurors during jury selection; admission of other crimes evidence; admission of the victim's statement; admission of expert testimony; instructions regarding the other crimes evidence; cumulative prejudice; validity of the lewd-and-lascivious-act special circumstance; and challenges to California's death penalty law and instructions. The court discussed each issue and held that the judgment was affirmed. View "People v. Loy" on Justia Law

Defendant submitted a false report to a deputy sheriff, stating that her vehicle had been stolen. At issue was whether defendant's felony conviction under a general statute governing the offering of a false instrument for filing in a public office was precluded by special statutes in the Vehicle Code that made it a misdemeanor to make or file a false report of vehicle theft or to file a false statement with the Department of Motor Vehicles. The court held that the Legislature intended that defendant's conduct be prosecuted as a misdemeanor under Vehicle Code section 10501 and not under the more general statute. Thus, the court reversed the district court's judgment. View "People v. Murphy" on Justia Law

Defendant was convicted of murdering a 22-year-old Soy Sun Lao during a doughnut shop robbery and convicted of two other robberies, both committed with a knife and one accompanied by an assault with force likely to produce great bodily injury. Defendant was sentenced to death and the court subsequently reviewed defendant's case on automatic appeal. The court reviewed guilt phase issues, penalty phase issues, and defendant's other claims of error. The court concluded that defendant's claim that the cumulative effect of guilt and penalty phase errors required reversal of his sentence failed because defendant had not established that any prejudicial error had occurred at either phase of his trial. Accordingly, the court affirmed the judgment. View "People v. Virgil" on Justia Law

Defendant was convicted of crimes related to the murder of Colleen Mary Kennedy and sentenced to death. On automatic appeal, defendant argued, among other things, that the trial court provided an erroneous instruction concerning the element of asportation for the offense of kidnapping and thereby violated his rights to due process and a fair trial under the Fifth, Sixth, Eighth, and Fourteenth Amendments of the U.S. Constitution and article I, sections 7 and 17 of the California Constitution. The court held, and the Attorney General conceded, that the totality of the circumstances standards set forth in People v. Martinez could not be applied to defendant's actions where defendant moved the victim from one room to another room. The court also held, and the Attorney General conceded, that "it is reasonably probable that a result more favorable to [defendant] would have been reached in the absence of the error." Therefore, the court reversed the judgment of conviction for kidnapping, vacated the findings related to kidnapping, and otherwise affirmed the judgment.View "People v. Castaneda" on Justia Law

Plaintiffs, former workers for defendant, a large software company headquartered in California, sued defendant claiming overtime compensation under the Labor Code for days longer than eight hours, and weeks longer than 40 hours, worked entirely in California; claiming that defendant's failure to pay overtime for work performed in California was an "unlawful [or] unfair... business act or practice" for purposes of California's unfair competition law (UCL), Bus. & Prof. Code, 17200 et seq.; and claiming restitution under the UCL in the amount of overtime compensation due under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 207(a), for weeks longer than 40 hours worked entirely in states other than California. The court held that the Labor Code's overtime provision did apply to plaintiffs' claims for compensation for work performed in California and that the same claims could serve as predicates for claims under the UCL. The court also held that plaintiffs' claims for overtime compensation under the FLSA for work performed in other states could not serve as predicates for the UCL. View "Sullivan, et al. v. Oracle Corp., et al." on Justia Law

Defendant was convicted of residential burglary and receiving stolen property. The trial court held a trial to determine whether defendant had suffered a prior Alabama felony conviction that qualified as a serious felony conviction under the Three Strikes Law, Pen. Code, 667. At issue was whether faxed copies of certified court records were admissible to establish that a prior conviction qualified as a serious or violent felony under the Three Strikes law. The court affirmed the Court of Appeal judgment upholding the trial court's admission of the faxed copy of the certified court record because there was sufficient evidence to sustain a finding that the faxed document was an accurate copy of an authentic court record from the Circuit Court of Lauderdale County, Alabama. View "People v. Skiles" on Justia Law