Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a witness, murder, in the commission of kidnapping, and lying in weight. The jury also found Defendant guilty of kidnapping, rape, and dissuading a witness. After a penalty trial, the jury returned a verdict of death for the murder conviction. The trial court imposed a judgment of death. The Supreme Court reversed the lying-in-wait special-circumstance finding for insufficient evidence but otherwise affirmed the judgment, holding (1) the evidence did not support the lying-in-wait special-circumstance finding, but no other prejudicial error occurred during the guilt phase of trial; and (2) there was no prejudicial error during the penalty phase of trial. View "Poeple v. Becerrada" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and other crimes. The jury found true special-circumstance allegations. After a penalty phase, the jury returned a verdict of death.The trial court denied Defendant’s motion for modification of his sentence to life without the possibility of parole. The Supreme Court affirmed, holding (1) no prejudicial error occurred during the pretrial phase of trial or during the guilt phase of trial; (2) substantial evidence supported Defendant’s convictions; (3) no prejudicial error occurred during the penalty phase of trial; and (4) Defendant’s challenges to the constitutionality of California’s death penalty scheme were unavailing. View "People v. Brooks" on Justia Law

Defendant pleaded no contest to two counts of nonforcible lewd conduct. The trial court placed Defendant on probation, ordered him to register as a sex offender, mandated his participation in an approved sex offender management program, and imposed two probation conditions that were the subject of this appeal - (1) that Defendant waive any privilege against self-incrimination and participate in polygraph examinations, pursuant to Cal. Penal Code 1203.067(b)(3); and (2) that Defendant waive any psychotherapist-patient privilege, pursuant to Cal. Penal Code 1203.067(b)(4). Defendant appealed, arguing that conditioning probation on the waiver of his privilege against self-incrimination and on his participation in polygraph examinations violated his Fifth Amendment rights and, like the waiver of his psychotherapist-patient privilege, was unconstitutionally overbroad. The Court of Appeal upheld the validity of the subdivision (b)(4) and (b)(3) conditions. The Supreme Court affirmed, holding that the probation conditions challenged in this case were not unconstitutional where they enabled those charged with monitoring the probation to obtain the information they need while otherwise safeguarding the probation’s privacy and protecting the probation from compelled self-incrimination. View "People v. Garcia" on Justia Law

In People v. Hosner, the Supreme Court held that an indigent criminal defendant facing retrial is presumptively entitled to a full and complete transcript of the prior proceedings. Defendant in this case was an indigent pro se defendant charged with making criminal threats, among other offenses. A jury deadlocked on the charges, the court declared a mistrial, and retrial was set. At a pretrial hearing, the trial court granted Defendant’s motion for a “complete record of trial transcripts.” Defendant received a transcript that included all witness testimony from the first trial but omitted the opening statements and closing arguments. The court then denied Defendant’s request for a transcript of the opening statements and closing arguments. After a trial, the jury found Defendant guilty as charged. The Court of Appeal affirmed, holding that Hosner’s presumption applies only to transcripts of witness testimony and not to transcripts of opening statements and closing arguments. The Supreme Court affirmed on different grounds, holding (1) a defendant facing retrial is presumptively entitled to a full transcript of the previous trial, including opening and closing statements; (2) when a defendant is denied only a portion of the transcript, the harmless error rule applies; and (3) the error was harmless in this case. View "People v. Reese" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, two counts of assault by a life prisoner with malice aforethought, and possession of a sharp instrument by a prisoner. The jury also found that Defendant had suffered two prior felony convictions within the meaning of the “Three Strikes” law. The jury returned a death verdict. The trial court sentenced Defendant accordingly. The Supreme Court affirmed, holding (1) no reversible error occurred during either the guilt phase or penalty phase of trial; and (2) Defendant’s attacks on the constitutionality of California’s death penalty statute and related standard jury instructions were unavailing. View "People v. Delgado" on Justia Law

After a jury trial, Defendant was convicted of murder in the course of a robbery with personal use of a deadly weapon. Defendant was sentenced to death. The Supreme Court affirmed, holding (1) there was no Pitchess error; (2) the trial court did not err in its jury selection rulings; (3) the trial court did not err in admitting Defendant’s incriminating recorded statements, as the statements were voluntarily given; (4) the trial court did not err in denying Defendant’s motion for severance; (5) the trial court did not abuse its discretion in admitting photographs of the victim; (6) any error in the stationing of a deputy near the witness stand during Defendant’s testimony was harmless; (7) no prejudicial error occurred during the penalty phase of trial; (8) the trial court did not err in denying Defendant’s automatic motion to modify the death verdict; and (9) California’s use of the death penalty does not violate international norms of evolving standards of decency in violation of the Eighth and Fourteenth Amendments. View "People v. Winbush" on Justia Law

The ACLU submitted a request under the California Public Records Act (PRA) to the Los Angeles County Counsel seeking invoices specifying the amounts that the County and been billed by any law firm in connection with several different lawsuits alleging excessive force against jail inmates. The County refused to provide invoices for the lawsuits that were still pending on the basis of attorney-client privilege. The ACLU petitioned for writ of mandate seeking to compel the County to disclose the requested records. The superior court granted the petition, concluding that the County had failed to show that the invoices were attorney-client privileged communications. The County then filed a petition for writ of mandate. The court of appeal granted the petition and vacated the superior court’s order, concluding that the invoices were confidential communications within the meaning of Cal. Evid. Code 952. The Supreme Court affirmed, holding (1) the attorney-client privilege does not categorically shield everything in a billing invoice from PRA disclosure, but invoices for work in pending and active legal matters implicate the attorney-client privilege; and (2) therefore, the privilege protects the confidentiality of invoices for work in pending and active legal matters. View "Los Angeles County Board of Supervisors v. Superior Court of Los Angeles County" on Justia Law

After a jury trial, Defendant was convicted of the first degree murder of a peace officer. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not err in failing to suspend proceedings and investigate whether Defendant was competent to stand trial; (2) Defendant’s ineffective assistance of counsel claim was inappropriate to address on appeal; (3) the trial court’s failure to suspend proceedings and hold a competency hearing prior to judgment did not violate Defendant’s due process rights; (4) the trial court did not err in allowing Defendant to waive his right to counsel; (5) the trial court did not err by failing to revoke Defendant’s self-representation during the penalty phase pursuant to Cal. Penal Code 686.1; (6) the trial court did not err in failing to obtain an updated Faretta waiver after the People filed a notice of intent to seek death; (7) Defendant’s claim that certain jurors should have been excused for cause was forfeited; (8) the trial court did not deprive Defendant of his constitutional right to testify in his own defense by excluding his liberty defense; and (9) Defendant’s challenges to the death penalty statute were without merit. View "People v. Mickel" on Justia Law

Defendant filed a motion to suppress the evidence found on his phone, arguing that the search of his phone resulted from an unduly prolonged and unjustified detention. The trial court denied the motion, concluding that the phone search was justified under the existing authority of People v. Diaz. The court of appeals affirmed, acknowledging that Diaz’s reasoning was repudiated in Riley v. California but determining that the good faith exception applied because Diaz was controlling law at the time. The Supreme Court reversed, holding (1) the phone search was conducted without a warrant and was improper; and (2) the good faith exception did not apply in this case because the search was not authorized by Diaz. View "People v. Macabeo" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. The jury returned a verdict of death, and the trial court entered the death judgment. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in denying Defendant’s motion for mistrial for discovery violations; (2) the prosecutor did not engage in prejudicial misconduct; (3) the trial court’s rulings regarding Defendant’s proffered third party culpability evidence were not in error; (4) the trial court did not abuse its discretion when it failed to exclude evidence of Defendant’s past uncharged incidents of sexual misconduct; (5) the trial court did not violate Defendant’s due process right to a fair trial in refusing to allow into evidence videotaped interviews of defense witnesses; (6) the trial court did not err in sustaining the prosecution’s objection to testimony that Defendant was alcohol dependent; (7) the trial court did not err in instructing the jury during the penalty phase; and (8) there was no constitutional violation of the state’s death penalty law. View "People v. Williams" on Justia Law