Justia California Supreme Court Opinion Summaries

While in Defendant's care, Defendant's young son died of shock and hemorrhage due to blunt force trauma. A jury convicted Defendant of involuntary manslaughter and assault on a child causing death. As relevant here, the court of appeal reversed the conviction upon finding the trial court erroneously failed to instruct the jury, sua sponte, on simple assault as a lesser included offense. The Supreme Court reversed and remanded with directions to reinstate the conviction, holding that the trial court had no sua sponte duty to instruct on that lesser offense, as (1) such instructions are required only when there is substantial evidence that, if the defendant is guilty at all, he is guilty of the lesser offense, but not the greater; and (2) here, it would be speculative at best to construe the trial evidence in this case as supporting a verdict of only simple assault. View "People v. Wyatt" on Justia Law

Prison regulations promulgated by the California Department of Corrections and Rehabilitation (CDCR) provide that validation of an inmate as a gang member or associate can result in the inmate's placement in a security housing unit. The current dispute arose when the CDCR validated Petitioner as a gang associate. Petitioner filed a petition for writ of habeas corpus, which the superior court denied. The court of appeal granted relief based on a disagreement with the CDCR over the interpretation of the CDCR's regulation. The Supreme Court reversed, holding that the court of appeal failed to accord due deference to the CDCR's interpretation of its own regulations. View "In re Cabrera" on Justia Law

Defendant was charged with murder, pled not guilty, and also raised an insanity defense. At the guilt phase trial, the prosecutor requested a jury instruction that Defendant was conclusively presumed to have been sane at the time of the offense. Defendant objected that the instruction might lead the jury to disregard the evidence of his mental illness and its effect on the intent required for murder. The court overruled the objection, gave the instruction on the presumption of sanity, and refused Defendant's request for an instruction on the legal definition of sanity. The jury convicted Defendant of first degree murder. The court of appeal affirmed. The Supreme Court affirmed, holding (1) although Defendant established no due process violation, the instruction was erroneous under state law, as the question of a defendant's sanity is entirely irrelevant at the guilt phase of a bifurcated trial under Cal. Pen. Code 1026; but (2) the error was harmless in this case. View "People v. Mills" on Justia Law

Defendant and Codefendant were charged with murdering two men by running over each of them with a car. The prosecution's theory was that one of the two victims had been drugged before he was killed. To prove this point, the prosecution presented the testimony of a laboratory director who, relying on reports not prepared by him, testified that testing of the victim's blood samples by analysts at his laboratory had determined the presence of drugs that could have caused drowsiness. According to Defendant, that testimony violated her Sixth Amendment right to confront and cross-examine the analysts who had tested the blood samples. The jury found both Defendant and Codefendant guilty of two counts of first degree murder and two counts of conspiracy to commit murder. The court of appeal affirmed, holding that even if there was a confrontation right violation, the error was not prejudicial. The Supreme Court affirmed, holding that in light of the overwhelming evidence against Defendant, exclusion of the laboratory director's trial testimony would, beyond a reasonable doubt, not have affected the outcome of Defendant's trial. View "People v. Rutterschmidt" on Justia Law

Defendant was charged with vehicular manslaughter while intoxicated after her vehicle collided with another, killing its driver. To prove intoxication, the prosecution at trial introduced into evidence a laboratory analyst's report on the percentage of alcohol in a blood sample taken from Defendant two hours after the accident. The analyst did not testify, but a colleague did. A jury found Defendant guilty as charged. The court of appeal reversed, holding that the admission of the nontestifying analyst's laboratory report and the colleague's testimony relating some of the report's contents violated Defendant's right to confront and cross-examine the report's author. The Supreme Court reversed, holding that the nontestifying analyst's laboratory report was not testimonial in nature, and the trial court did not err in permitting the prosecution to introduce that portion of the report into evidence, and in permitting the colleague to testify regarding it. View "People v. Lopez" on Justia Law

At Defendant's murder trial, a forensic pathologist testifying for the prosecution described to the jury objective facts about the condition of the victim's body as recorded in the autopsy report and accompanying photographs. Based on those facts, the expert gave his independent opinion that the victim had died of strangulation. Neither the autopsy report, which was prepared by another pathologist who did not testify, nor the photographs were introduced into evidence. The court of appeal reversed Defendant's conviction for second degree murder, holding that the expert's testimony violated Defendant's Sixth Amendment right to confront and cross-examine the preparer of the autopsy report, and that the error was prejudicial. The Supreme Court reversed, holding that the trial court did not err in admitting the expert's testimony over a Confrontation Clause objection, as the statements of the preparer of the autopsy report were not testimonial, and the Confrontation Clause did not bar their use. View "People v. Dungo" on Justia Law

This case involved the second habeas corpus petition filed by Petitioner, who was sentenced to death. The petition was an "exhaustion petition," which sought to exhaust state claims in order to raise them in federal court. Nearly all of Petitioner's claims raised legal issues that were not cognizable or were procedurally barred. The Supreme Court denied the writ after taking the opportunity to establish new ground rules for exhaustion petitions in capital cases, holding (1) this petition exemplifies abusive writ practices; and (2) following finality of this opinion, exhaustion petitions in capital cases will be subject to the page limits and other rules described in this opinion. View "In re Reno" on Justia Law

In People v. Carmony (Carmony II), a decision of the California court of appeal concluded that a twenty-five-year-to-life sentence under the Three Strikes law constituted cruel and/or unusual punishment as applied to a defendant whose triggering offense was the failure to annually update his sex offender registration within five working days of his birthday. In the present habeas corpus proceeding, the court of appeal, considering the constitutionality of a twenty-five-year-to-life sentence imposed upon Defendant, who also was convicted of failing to update his sex offender registration within five working days of his birthday, expressly disagreed with the conclusion of the appellate court in Carmony II and held that the punishment was constitutionally permissible. The Supreme Court affirmed on other grounds, holding that Defendant's sentence here did not constitute cruel and unusual punishment under the circumstances of this case, but this holding did not rest upon a determination that Carmony II was wrongly decided. View "In re Coley" on Justia Law

Defendant was charged with two separate crimes, murder and participation in a criminal street gang. The court failed to include the standard reasonable doubt instruction prior to the jury's deliberations. The court's instructions with regard to the murder charge did inform the jury that it must find every element of that charge must be proved beyond a reasonable doubt. The instruction relating to the gang offense did not include similar reasonable doubt language. The jury found Defendant guilty of the lesser offense of voluntary manslaughter and of the gang offense. The court of appeals reversed Defendant's conviction of the gang offense. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court's omission of the standard reasonable doubt instruction did not constitute federal constitutional error as to the voluntary manslaughter conviction, and although the omission amounted to state law error as to that conviction, the error was harmless; and (2) with respect to the gang offense, the failure to instruct the jury to prove the elements of the crime beyond a reasonable doubt constituted error under both state law and the federal constitution, but the error was harmless. View "People v. Aranda" on Justia Law

Petitioner was found guilty of the murders of two brothers. The trial court sentenced Petitioner to death. The Supreme Court affirmed. Petitioner subsequently filed a habeas corpus petition for relief from the judgment of death. The Supreme Court ordered an evidentiary hearing on Petitioner's claim that the prosecution had failed to disclose evidence that would have supported a case in mitigation at the penalty phase that Petitioner committed the two murders because of a Colombian drug cartel's death threats against him and his family. The referee found merit to Petitioner's claim. The Supreme Court upheld the determination by the referee and granted Petitioner's habeas corpus petition, holding (1) substantial evidence supported the referee's determination, and (2) it was reasonably probable that Petitioner's penalty phase jury would have returned a verdict of life imprisonment without parole had it heard the evidence withheld by the prosecution. View "In re Bacigalupo" on Justia Law