Justia California Supreme Court Opinion Summaries

Articles Posted in Civil Rights
by
The Supreme Court affirmed Defendant's conviction of two counts of first degree murder, two counts of attempted murder, and possession of a firearm by a felon, holding that there was no reversible error.Specifically, the Supreme Court held (1) the prosecutor's use of a peremptory strike during jury selection prior to the guilt phase did not violate Batson v. Kentucky, 476 U.S. 79 (1986), or People v. Wheeler, 22 Cal. 3d 258 (1978); (2) the trial court did not err in denying Defendant's motion to suppress the gun discovered during a traffic stop; (3) the trial court did not err in admitting hearsay evidence that was the basis for the gang enhancement; (4) there was sufficient evidence to support Defendant's gang enhancement conviction; and (5) the court erred in admitting evidence of the victim's cancer diagnoses during the penalty phase, but there was no reasonable possibility that the victim impact testimony affected the verdict. View "People v. McDaniel" on Justia Law

by
The Supreme Court vacated the judgment of the court of appeal and its award of costs on appeal, holding that a claim for failure to promote brought under the harassment provision of the Fair Employment and Housing Act (FEHA), Cal. Gov. Code 12940, subd. (j), 12960, accrues, and thus the statute of limitations begins to run, at the point when an employee knows or reasonably should know of the employer's allegedly unlawful refusal to promote the employee.Plaintiff alleged that her employer passed her over for promotions because she refused to have sex with the company's executive vice-president, Michael Kelso. The trial court granted summary judgment for Kelso, finding no triable issue of fact as to Kelso's statute of limitations defense. The court of appeal affirmed the trial court's grant of summary judgment for Kelso and two other defendants and awarded costs on appeal to all three defendants. The Supreme Court reversed, holding (1) the court of appeals erred in concluding that the statute of limitations began to run when Plaintiff's employer offered a promotion to someone else and she accepted it; and (2) the court of appeal erred in awarding costs on appeal to Defendants without first finding that Plaintiff's underlying claim was objectively groundless. View "Pollock v. Tri-Modal Distribution Services, Inc." on Justia Law

by
The Supreme Court affirmed Defendant's conviction of one count each of murder and rape and his sentence of death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err in excluding defense evidence relating to third party culpability and victim character; (2) the trial court did not by admitting three photographs of the victim proffered by the prosecutor while excluding a booking photograph of the victim offered by Defendant; (3) the trial court did not abuse its discretion in excluding certain newspaper articles or evidence of other crimes; (4) the trial court did not err in permitting the prosecutor to elicit testimony from Defendant's wife and from the victim's father; (5) assuming the trial court's instruction pursuant to CALJIC No. 2.50.01 was erroneous, there was no prejudice; (6) the trial court did not abuse its discretion in denying Defendant discovery of a witness's medical records; (7) any error in the admission of evidence and regiment regarding Defendant's lack of remorse was harmless; (8) assuming that the prosecutor erred in her penalty phase argument, the error was not prejudicial; and (9) Defendant's challenges to his sentence were unavailing. View "People v. Dworak" on Justia Law

by
The Supreme Court affirmed the judgment of the court of appeal in this case involving allegations of active gang participation and gang enhancements attached to other offenses, holding that the commission of two or more predicate offenses must be proven by independent admissible evidence, and such proof may not be established solely by the testimony of an expert who has no personal knowledge of facts otherwise necessary to satisfy the prosecution's burden.The two defendants in this case were charged with two counts of attempted murder, assault with a firearm, and active street gang participation. Gang and firearm enhancements were attached to the charges. The first trial ended when the jury hung on almost all charges, but a second jury convicted Defendants of the remaining allegations. The court of appeal reversed the active gang participation and enhancement allegations, as well as Defendant's firearm enhancements attached to those allegations, and otherwise affirmed, holding that some of an expert's testimony constituted inadmissible hearsay. The Supreme Court affirmed, holding (1) the jury was permitted to improperly rely on hearsay to conclude that the predicate offenses had been proven and that Defendants acted with intent to benefit a gang when they committed the crimes with which they were charged; and (2) the error was not harmless. View "People v. Valencia" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court convicting Defendant of kidnapping and killing Shirley and Andrew Demko after burglarizing and robbing their home, holding that there was no error in the proceedings below.On appeal, Defendant raised numerous allegations of error both during the guilt phase and the penalty phase. The Supreme Court rejected the claims and affirmed the judgment in its entirety, holding (1) the trial court did not err in denying Defendant's Batson/Wheeler motion upon finding that the prosecutor did not make a prima facie showing that the prosecutor exercised a peremptory challenge in a discriminatory manner; (2) assuming, without deciding, that the trial court erred in admitting statements that Defendant identified as implicating prior burglaries, any error was harmless as a matter of law; and (3) there were no penalty phase errors and no cumulative prejudice to consider. View "People v. Battle" on Justia Law

by
The Supreme Court affirmed Defendant's convictions for the first-degree murder and robbery of a deputy sheriff and his sentence of death, holding that Defendant's claims of error lacked merit.Specifically, the Supreme Court assumed error, but found no prejudice, as to (1) the trial court's failure to give a pinpoint jury instruction on Defendant's claim of accident relating to a felony-murder special-circumstance allegation; (2) the admission of a photograph of Defendant at the time of his prior sexual assault of Diane K.; and (3) the admission of certain victim impact testimony. Further, the trial court committed harmless error by using the 1996 revised version of CALJIC No. 8.71. The Court held that the cumulative effect of the three assumed error and the one harmless error did not warrant reversal. The Court remanded the matter for resentencing to strike a three-year prison term enhancement and otherwise affirmed. View "People v. Scully" on Justia Law

by
The Supreme Court affirmed Defendant's convictions of the first degree murder of her four daughters and the attempted murder of her son but reversed her death sentence, holding that judicial misconduct during the penalty phase was prejudicial.The Supreme Court found or assumed seven errors in this case, including error in the guilt phase instructions regarding discovery violations, error limiting mental state testimony by defense experts in the guilt phase, error in excluding a neuropsychological expert's testimony in the penalty phase, error in excluding Defendant's positron emission tomography scan results from the penalty phase, error in failing to admit mitigating evidence from lay witnesses, erroneous penalty phase instructions regarding discovery violations, and judicial misconduct. The Supreme Court held (1) considered cumulatively, the errors during the guilt phase did not warrant reversal of the guilt judgment; (2) judicial misconduct in the penalty phase was prejudicial and warranted reversal of Defendant's death sentence; and (3) the prejudicial impact of additional penalty phase errors increased when considered together with the judicial misconduct. View "People v. Nieves" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of first degree murder and verdict of death, holding that there was no prejudicial error in the proceedings below and that Defendant was not entitled to reversal of his conviction.A jury convicted Defendant of the first degree murder of a deputy sheriff. When the jury was unable to reach a penalty verdict the trial court declared a mistrial. Following a penalty retrial, the jury returned a verdict of death. The Supreme Court affirmed, holding (1) even if prosecutorial misconduct occurred during the guilt phase, it was not prejudicial, and there were no other errors during the guilt phase; and (2) no prejudicial error occurred during the penalty phase, and Defendant's challenges to the constitutionality of the death penalty statute were unavailing. View "People v. Steskal" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of the murders of four young men during the robbery of a car wash and his sentence of death, holding that there was no merit to any of Defendant's claims.Specifically, the Supreme Court held (1) the trial court did not err by denying a motion to suppress two witnesses' identifications of Defendant; (2) Defendant's Sixth Amendment right to confrontation was not violated by the trial court's admission of certain testimony; (3) the trial court did not err by failing to instruct the jury on the lesser-included offense of unpremeditated second-degree murder, and there was no other instructional error; (4) Defendant's claims of trial error in the admission of allegedly prejudicial hearsay were without merit; (5) the trial court's denial of Defendant's new trial motion was not erroneous; (6) the trial court did not abuse its discretion by failing to investigate certain allegations raised by Defendant; and (7) Defendant's objections to the constitutionality of California's death penalty scheme were unavailing. View "People v. Wilson" on Justia Law

by
The Supreme Court held that when the court-appointed attorneys of parents in termination proceedings have failed to timely file a notice of appeal of an order terminating parental rights, parents whose rights have been terminated may seek relief based on the attorney's failure to provide competent representation.After M.B.'s parental rights to her child were terminated, M.B. timely asked her new court-appointed counsel to file an appeal. The attorney, however, did not file an appeal until after the sixty-day filing deadline had passed. The court of appeal dismissed the appeal as untimely. The Supreme Court reversed, holding (1) every parent facing the termination of parental rights is entitled to the assistance of competent counsel; and (2) when an attorney fails to file a timely appeal in accordance with his or her client's instructions, the parent may seek relief based on the denial of the statutory right to the assurance of competent counsel. View "In re A.R." on Justia Law