Justia California Supreme Court Opinion Summaries

This case involved a ward on probation for an offense that made him eligible for commitment to the Division of Juvenile Facilities (DJF). The ward subsequently committed a new offense that was not listed in Cal. Code Welf. & Inst. 733(c). Section 733(c) states that a ward cannot be committed to DJF unless "the most recent offense" alleged in any petition is one of several enumerated violent offenses. If the prosecution files a notice of probation violation under section 777, the court may revoke the ward's probation and commit the ward to DJF. However, if the prosecution files a new section 602 petition, section 733(c) will prohibit the court from ordering a DJF commitment if the allegation is found true. At issue in this case was whether, under these circumstances, the juvenile court may use its discretion under section 782, which allows the juvenile court to dismiss any wardship petition if the interests of justice, to dismiss the second petition so the matter can be treated as a probation violation, allowing the ward to be committed to DJF. The Supreme Court concluded (1) the court has that discretion; and (2) the juvenile court here had authority to dismiss the 602 petition. View "In re Greg F." on Justia Law

Six days after his birth, Plaintiff suffered irreversible brain damage. Through his mother as guardian ad litem, Plaintiff sued his pediatrician and the hospital in which he was born. Before trial, Plaintiff and the pediatrician agreed to settlement of $1 million. At a jury trial, Plaintiff was awarded both economic and noneconomic damages. The jury found the pediatrician was fifty-five percent at fault and the hospital forty percent at fault. The court of appeal reversed the portion of the trial court's judgment awarding Plaintiff economic damages against the hospital after applying the common law "release rule," under which Plaintiff's settlement with the pediatrician also released the nonsettling hospital from liability for Plaintiff's economic damages. The Supreme Court reversed, holding (1) the common law release rule is no longer to be followed in California; and (2) therefore, the defendant hospital remained jointly and severally liable for Plaintiff's economic damages. View "Leung v. Verdugo Hills Hosp." on Justia Law

Cal. Lab. Code 4558 contains a power press exception to the general rule that workers' compensation is the exclusive remedy of an injured worker against the employer. Employee was injured while operating a power press without a point of operation guard. Employee and his wife (Spouse) brought a civil suit against Employer under the power press exception that included a claim for loss of consortium on behalf of Spouse, predicated on the facts allegedly establishing a section 4558 violation. The trial court sustained Employer's demurrer to all of Spouse's causes of action except her claim for loss of consortium. The court of appeal disagreed with the trial court, concluding Spouse could plead a claim for damages for loss of consortium because such a claim fell outside the workers' compensation laws and hence was not barred by the exclusivity rule. The Supreme Court (1) reversed the portion of the judgment of the court of appeal as to Spouse's consortium claim, holding that where the worker's power press injuries do not prove fatal, the Legislature has restricted standing to bring the action at law authorized under section 4558 to the injured worker alone; and (2) affirmed in all other respects. Remanded. View "LeFiell Mfg. Co. v. Superior Court" on Justia Law

An owners association for a construction defect action against a condominium developer, seeking recovery for damage to its property and damage to the separate interests of the condominium owners who composed its membership. In response, the developer filed a motion to compel arbitration based on a clause in the recorded declaration of covenants, conditions, and restrictions providing that the association and the individual owners agreed to resolve any construction dispute with the developer through binding arbitration. The trial court determined that the clause embodied an agreement to arbitrate between the developer and the association but invalidated the agreement upon finding it marked by slight substantive unconscionability and a high degree of procedural unconscionability. The court of appeal affirmed. The Supreme Court reversed, holding that the arbitration clause bound the association and was not unconscionable. View "Pinnacle Museum Tower Ass'n v. Pinnacle Market Dev." on Justia Law

In 2007, sixteen-year-old Defendant opened fire on three teenage boys who were members of a rival gang. A jury convicted Defendant of three counts of attempted murder. The jury found true that Defendant personally and intentionally discharged a firearm and inflicted great bodily harm on one victim and that Defendant committed the crimes for the benefit of a criminal street gang. Defendant's total sentence was 110 years to life. The court of appeal affirmed. At issue before the Supreme Court was whether the sentence contravened the mandate in Graham v. Florida against cruel and unusual punishment of juveniles convicted of nonhomicide offenses and sentenced to life imprisonment without the possibility of parole. The Court reversed, holding that consistent with the U.S. Supreme Court's holding in Graham, sentencing a juvenile offender for a nonhomicide offense to a term of years with a parole eligibility date that falls outside the juvenile offender's natural life expectancy constitutes cruel and unusual punishment in violation of the Eighth Amendment. View "People v. Caballero" on Justia Law

After a jury trial, Defendant, who spoke Spanish, was convicted of first degree murder. At issue on appeal was whether, while Defendant was in custody and after a law enforcement officer read Defendant his Miranda rights, Defendant's response to whether a detective could speak to Defendant was sufficiently ambiguous to justify the officer in seeking to clarify whether Defendant was attempting to invoke his right to counsel, or whether he was desirous of waiving his Miranda rights and speaking with the detective without an attorney present. The trial court concluded that Defendant's waiver of Miranda rights was voluntary, knowing and intelligent. The court of appeals reversed. The Supreme Court reversed, holding (1) Defendant's reply to the officer's inquiry was sufficiently ambiguous to justify her seeking further clarification of his intent, consistent with the Court's holding in People v. Williams; (2) Defendant's responses made clear he was willing to speak with the detective at that time without an attorney present; and (3) therefore, under the totality of the circumstances, Defendant's waiver of Miranda rights, including his right to counsel, was voluntary, knowing, and intelligent. View "P. v. Sauceda-Contreras" on Justia Law

This case considered complex questions of insurance policy coverage interpretation in connection with a federal court-ordered cleanup of the state's Stringfellow Acid Pits waste site. The Supreme Court affirmed the court of appeal's judgment, holding (1) the "continuous injury trigger" and "all sums" rule announced in Montrose Chemical Corp. v. Admiral Ins. Co. and Aerojet-General Corp. v. Transport Indemnity Co. applied to the State's successive property or long-tail first party property loss, triggering the duty to indemnify here; and (2) the court of appeal correctly applied the "all-sums-with-stacking" allocation rule in allocating the indemnity duty among the insurers responsible for covering the property loss. View "State v. Cont'l Ins. Co." on Justia Law

A jury convicted Defendant Richard Valdez of five counts of first degree murder. As to each count, the jury found true special circumstance allegations of multiple murder and gang and weapon enhancement allegations. The evidence presented at trial established that Defendant was a member of the Sangra street gang. The jury returned a verdict of death as to each of the victims. The trial court denied the automatic application to modify the verdict and sentenced Defendant to death for the five murders. The Supreme Court affirmed, holding, among other things, that Defendant's claims alleging numerous errors in connection with protective orders the trial court issued delaying and limiting disclosure of the identities of certain prosecution witnesses failed, and that the trial judge did not prejudicially err in refusing to declare a mistrial after the jurors declared they were at an impasse and could not reach a unanimous verdict on any count. View "People v. Valdez" on Justia Law

Defendant, an ex-felon on probation, planted an object near a government building that resembled a bomb and that caused fear and disruption when discovered. Defendant was convicted of violating Cal. Penal Code 148.1(d), which allows misdemeanor or felony punishment for anyone who maliciously places a false bomb with the intent to cause another person to fear for his own safety or the safety of others. Defendant's sentence included a twenty-five-years-to-life three strikes term based on the section 148.1(d) felony count and his prior serious and violent felony convictions. The court of appeal reduced the section 148.1(d) conviction to a misdemeanor, finding that the felony provision under which Defendant was convicted and sentenced denied him equal protection of the law when compared to an entirely different statute, Cal. Penal Code 11418.1, which provides that anyone who places a WMD with the intent to cause fear in others can be convicted of a felony only if the perpetrator's conduct causes another person to be placed in sustained fear, an element not necessary under the false bomb statute. The Supreme Court reversed, holding that no equal protection violation occurred, as the challenged distinction was not irrational. View "People v. Turnage" on Justia Law

The Minor in this case was the subject of several delinquency petitions. Minor was eventually placed in foster care. Minor appealed, arguing the dispositional order placing him in foster care had to be reversed because the juvenile court had failed to comply with the notice requirements of the Indian Child Welfare Act (INCA). The court of appeals affirmed, holding notice was not required because federal law specifically excludes delinquency cases from ICWA, and any interpretation of California law that would expand ICWA's application to delinquencies would be invalid under federal preemption principles. The Supreme Court affirmed, holding (1) California law requires the court to inquire about a child's Indian status at the outset of all juvenile proceedings, but ICWA's additional procedures are not required in most delinquency cases; (2) a delinquency court must ensure that notice is given and other ICWA procedures are complied with only under certain circumstances; and (3) assuming Minor was an Indian child, the juvenile court did not err in failing to give notice under ICWA in this case. View "People v. W.B." on Justia Law