Justia California Supreme Court Opinion Summaries

At issue in this divorce case was whether Husband's retirement benefits were community or separate property. Husband, a firefighter, rendered military services before he married Wife. During the parties' marriage, Husband purchased four years' worth of additional retirement credit for his premarital military services. Some of the funds Husband used to pay to obtain this additional credit came from community property. The trial court ordered Husband to pay Wife one-half of the amount the community expended to obtain the credit plus interest. The Supreme Court affirmed the decision of the trial court, holding that the court acted within its discretion in using this method to compensate Wife for her share of the community's interest in the property. View "Green v. Green" on Justia Law

After declaring a fiscal emergency, the City of Los Angeles adopted a mandatory furlough program for its civilian employees. Many of those employees that were represented by a union (Union) filed grievances against the City, contending that the furloughs violated memorandums of understanding (MOUs) governing the terms and conditions of their employment. The grievances were denied, and the City denied the employees' request to arbitrate. The superior court subsequently granted the Union's petition for an order compelling the City to arbitrate the dispute. The court of appeal granted the City's petition for a writ of mandate, concluding that the City could not be compelled to arbitrate under the terms of the MOUs because arbitration would constitute an unlawful delegation to the arbitrator of discretionary policymaking powers that the City's charter vested in its city council. The Supreme Court reversed, holding (1) arbitration of the employee furlough dispute did not constitute an unlawful delegation of discretionary authority to the arbitrator; and (2) the City was contractually obligated to arbitrate the dispute. View "City of Los Angeles v. Superior Court" on Justia Law

Decedent was already married when he and Plaintiff obtained a marriage license and held their wedding ceremony. Three years later, Decedent was killed in an accident at a construction site. Plaintiff filed this wrongful death action against Defendant, claiming she was the putative spouse of Decedent. Defendant moved for summary judgment, contending that Plaintiff lacked standing to sue in this case because she did not have the requisite "good faith belief" under Cal. Civ. P. Code 377.60 that her marriage to Decedent was valid. The trial court granted summary judgment for Defendant after applying an objective test for putative spouse status. The court of appeal reversed, holding that Plaintiff's subjective state of mind, if found credible by the trial court, could support a finding of good faith belief and establish putative spouse status. The Supreme Court affirmed, holding (1) section 377.60 contemplates a subjective standard that focuses on the alleged putative spouse's state of mind to determine whether she had a genuine belief in the validity of the marriage; and (2) the trial court erred in applying a reasonable person test that required Plaintiff's belief in the validity of the marriage to be objectively reasonable. View "Ceja v. Rudolph & Sletten, Inc." on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, assault by means of force likely to produce great bodily injury and/or with a deadly weapon, and first-degree residential burglary. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not err in its rulings surrounding jury selection issues; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) the evidence was sufficient to support Defendant's conviction of first-degree murder; (4) the prosecutor did not commit misconduct during closing argument; (5) the trial court did not prejudicially err in instructing the jury during the guilt phase; (6) the trial court did not prejudicially err in its rulings during the penalty phase; (7) California's death penalty statute is not unconstitutional; and (8) Defendant was not cumulatively prejudiced. View "People v. Lopez" on Justia Law

After a second jury trial, Defendant was convicted of one count of attempted mayhem and two counts of assault with a firearm. Defendant appealed, contending that the trial court erred in instructing the jury that a gunshot wound may constitute a "serious bodily injury" for purposes of the offense of attempted mayhem. The court of appeal reversed the attempted mayhem conviction, holding that the trial court erred in giving the instruction because the instruction suggested to the jury that Defendant could be found guilty of attempted mayhem if it found Defendant merely intended to inflict a gunshot wound rather than intending to inflict a wound that would seriously impair the victim's physical condition. The Supreme Court reversed, holding (1) the pattern jury instruction on mayhem improperly requires proof of a "serious bodily injury"; but (2) assuming the trial court erred in giving the instruction in this case, the error was harmless. View "People v. Santana" on Justia Law

Plaintiffs, Raymond and Gloria Martinez, sued Defendant for damages arising out of an electrical explosion that severely injured Raymond. Before trial, Plaintiffs served on Defendant two successive settlement offers pursuant to Cal. Civ. Proc. Code 998. Defendant failed to accept or reject the offers within the statutory thirty-day period. After a trial, judgments were entered in favor of Plaintiffs that were not more favorable to Defendant than either offer. Plaintiffs sought costs pursuant to section 998, including expert fees. Section 998 encourages the settlement of lawsuits prior to rial by providing that a defendant cover the plaintiff's postoffer costs of expert witness services when the judgment is not more favorable than the plaintiff's settlement offer. However, the statute is silent as to the effect of a party's multiple offers. The trial court disallowed the expert fees incurred by Gloria after her first settlement offer but before her second offer, finding that the most recently rejected offer is the only pertinent offer. The court of appeal reversed. The Supreme Court affirmed, holding that, under the circumstances presented here, allowing the recovery of expert fees incurred from the date of the first offer is consistent with section 998's language and purpose. View "Martinez v. Brownco Constr. Co." on Justia Law

Doctor applied for reappointment to Hospital's medical staff. Hospital denied the application. Doctor requested a review hearing to challenge the decision. Under Hospital's bylaws, Hospital's Medical Executive Committee (MEC) was responsible for selecting the hearing officer and panel members that would hear Doctor's claim. However, the MEC declined to exercise its authority, leaving the responsibility to Hospital's Governing Board. After a hearing, the Judicial Review Committee (JRC) concluded that the Governing Board's decision to deny Doctor's application for reappointment was reasonable. The Governing Board subsequently ordered that Doctor be terminated from the medical staff. Doctor filed an administrative mandate petition, asserting, among other claims, that he had been denied a fair proceeding because the Governing Board, rather than the MEC, had chosen the members of the JRC for his judicial review hearing. The court of appeal held that Doctor had been deprived of his right to a fair procedure and was entitled to a new judicial review hearing. The Supreme Court reversed, holding that the court of appeals incorrectly concluded that the MEC's delegation of the power to select the participants in the JRC was a material violation of Hospital's bylaws. Remanded. View "El-Attar v. Hollywood Presbyterian Med. Ctr." on Justia Law

After a jury trial, Defendant was convicted of second degree murder. The court of appeal reversed the murder conviction, concluding that the trial court erred by failing to sua sponte instruct the jury on voluntary manslaughter as a lesser included offense of murder on the theory that Defendant killed without malice in the commission of an inherently dangerous assaultive felony. The Supreme Court reversed, holding that because a killing without malice in the commission of an inherently dangerous assaultive felony is not voluntary manslaughter, the trial court could not have erred in failing to instruct the jury that it was. View "People v. Bryant" on Justia Law

Defendant was charged with murder and use of a deadly weapon. The trial court gave instructions on first and second degree murder as well as voluntary manslaughter based upon a sudden quarrel or heat of passion. The jury found Defendant guilty of second degree murder with a use enhancement. The court of appeal reversed Defendant's conviction, concluding that the voluntary manslaughter instruction was prejudicially erroneous. The Supreme Court reversed after clarifying what kind of provocation will suffice to constitute heat of passion and reduce a murder to manslaughter, holding that although the jury instruction properly conveyed the standard for determining heat of passion, the argument of counsel may have introduced ambiguity. However, the jury asked a clarifying question, and the trial court's response dispelled any confusion. View "People v. Beltran" on Justia Law

After a jury trial, Petitioner was convicted of two counts of first degree murder and of being a felon in possession of a firearm. Following the penalty phase of trial, the jury sentenced Petitioner to death. The Supreme Court affirmed. While Petitioner's appeal was pending, Petitioner also filed a petition for writ of habeas corpus. Having found the petition stated a prima facie case for relief on several claims of alleged juror misconduct, the Supreme Court issued an order to show cause why relief should not be granted. After an evidentiary hearing, a referee filed his report. The Supreme Court accepted the referee's report and findings as supported by substantial evidence, discharged the order to show cause, and denied relief, holding (1) there was no substantial likelihood that one juror was biased against Petitioner for failing to disclose certain personal information; and (2) the record rebutted the presumption of prejudice that arose from two other jurors' misconduct. View "In re Boyette" on Justia Law