Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of murder, sixteen counts of robbery, and three counts of assault with a deadly weapon, and related charges. The jury sentenced Defendant to death. Defendant appealed, arguing, among other things, that the trial court improperly excluded three prospective jurors based on their death penalty views. The Supreme Court (1) reversed the judgment of death and remanded the matter for a new penalty determination, holding that written and oral voir dire responses of the three excused panelists did not give the trial court sufficient information to conclude that they were incapable of performing their duties as capital jurors, and therefore, the record did not support the jurors’ dismissals; and (2) affirmed the judgment in all other respects. View "People v. Leon" on Justia Law

Defendant was convicted of three first degree murders and of conspiracy to participate in a criminal street gang and to commit murder and assault with a deadly weapon. The jury found true several enhancements. Defendant was sentenced to 100 years to life in prison. Before trial, Defendant moved to exclude his admissions of gang membership during booking and classification interviews at a county jail, asserting a Miranda violation. The trial court held that Defendant’s statements about his gang membership were admissible under Miranda’s booking exception. The Supreme Court affirmed, holding (1) the questions posed to Defendant while he was being processed into jail exceeded the scope of the booking exception, and while the officers were permitted to ask these questions for institutional security purposes, Defendant’s un-Mirandized responses were inadmissible against him during the case-in-chief; but (2) the erroneous admission of Defendant’s challenged statements was harmless beyond a reasonable doubt because Defendant’s gang affiliation was amply established by independent and uncontradicted evidence. View "People v. Elizalde" on Justia Law

After a jury trial in 1989, David Welch was found guilty of six counts of first degree murder and two counts of attempted murder. The trial court sentenced Welch to death. The Supreme Court affirmed on appeal. Welch later filed a habeas corpus petition, alleging, among other claims, juror misconduct and ineffective assistance of counsel at the penalty phase. The Supreme Court issued to the Director of the Department of Corrections an order to show cause why it should not grant Welch relief on his jury misconduct and ineffective assistance of counsel claims. An appointed referee conducted an evidentiary reference hearing and filed a report with recommendations. The Supreme Court then discharged the order to show cause, holding that Defendant failed to establish that he was entitled to habeas corpus relief on his claims of juror misconduct and ineffective assistance of trial counsel for not investigating and presenting certain mitigating evidence at the penalty phase of his capital trial. View "In re Welch" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, rape, and sodomy. Defendant also pleaded guilty to charges arising from separate burglaries committed after the charged murder. The trial court sentenced him to death. Defendant appealed, arguing, among other things, that the prosecutor violated Batson v. Kentucky and People v. Wheeler by peremptorily excusing two African American prospective jurors. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court correctly concluded that Defendant failed to make out a prima facie case of discrimination as to either strike; (2) the trial court did not abuse its discretion in denying Defendant’s pretrial motion to sever the homicide charges from the burglary charges; and (3) any remaining errors or assumed errors were not prejudicial. View "People v. Scott" on Justia Law

Plaintiff, a firefighter, sued Defendant, his employer, alleging disability discrimination in violation of the California Fair Employment and Housing Act (FEHA). The trial court granted summary judgment in favor of Defendant. Without making any finding that Plaintiff’s action was frivolous, unreasonable, or groundless, the trial court awarded Defendant its court costs. The court of appeal affirmed. The Supreme Court reversed, holding (1) Cal. Gov’t Code 12965(b) governs cost awards in FEHA actions, allowing trial courts discretion in awards of both attorney fees and costs to prevailing FEHA parties; and (2) the standard set forth in Christiansburg Garment Co. v. EEOC applies to discretionary awards of both attorney fees and costs to prevailing FEHA parties under section 12965(b), but a prevailing defendant should not be awarded fees or costs unless the plaintiff brought or continued litigating the action without an objective basis for believing it had potential merit. View "Williams v. Chino Valley Indep. Fire Dist." on Justia Law

After a jury trial, Defendant was convicted of the first degree murders of Mary Kopatz and Carley Kopatz. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress evidence of his videotaped interview with the police; (2) the trial court did not err in admitting a deceased witness’s prior consistent statement; (3) the victim impact evidence was neither unduly prejudicial nor so inflammatory that it invited the jury to make its penalty determination on a purely irrational basis; (4) Defendant was not prejudiced by a multiple-murder special-circumstance instruction and attendant verdict forms; and (5) Defendant’s challenges to the death penalty law failed. View "People v. Kopatz" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, with the special circumstance of torture, false imprisonment by violence, and conspiracy to commit murder. The jury recommended a sentence of death, and the trial court imposed that sentence. The Supreme Court affirmed the convictions but reversed the penalty judgment, holding that, during the penalty phase, the court violated Defendant’s federal constitutional rights to due process by excluding expert testimony about prison security measures for those sentenced to life without possibility of parole because Defendant was deprived of the opportunity to counter aggravating evidence and argument suggesting that he would be a dangerous life prisoner. View "People v. Smith" on Justia Law

Petitioners in this consolidated habeas corpus proceeding were registered sex offenders on active parole in San Diego County against whom Cal. Pen. Code 3003.5(b) was applied. Section 3003.5(b) imposed mandatory residency restrictions against paroled registered sex offenders. The trial court concluded that the mandatory residency restrictions were unconstitutional as applied to all registered sex offenders on parole in San Diego County and enjoined enforcement of the statute in the county. The Court of Appeal affirmed. The Supreme Court affirmed, holding (1) section 3003.5(b)’s residency restrictions are unconstitutional as applied to petitioners and similarly situated registered sex offenders on parole in San Diego County; but (2) as the lower courts made clear, the California Department of Corrections and Rehabilitation retains the statutory authority to impose special restrictions on registered sex offenders, including residency restrictions, so long as they are based on the specific circumstances of each individual parolee. View "In re Taylor" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, first degree burglary, first degree robbery, and carjacking. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial judge’s failure to disqualify himself because of his relationship with the prosecutor did not violate Defendant’s constitutional rights; (2) the trial judge did not prejudicially err in denying Defendant’s motion to change venue; (3) the evidence was sufficient to support the carjacking conviction; (4) the trial court adequately instructed the jury regarding victim impact evidence; (5) the trial court did not err in its treatment of one of Defendant’s prior crimes; and (6) Defendant’s challenges to California’s death penalty law were without merit. View "People v. Johnson" on Justia Law

Plaintiff was convicted of nonforcible oral copulation by an adult over twenty-one years with a person under sixteen years of age in violation of Cal. Penal Code 288a(b)(2). Plaintiff’s conviction resulted in mandatory sex offender registration under Cal. Penal Code 290. The Supreme Court subsequently issued its decision in People v. Hofsheier, which found an equal protection violation in section 290’s mandatory registration provision for a different subdivision of section 288a. Citing Hofsheier and its progeny, Plaintiff filed a petition for a writ of mandate in the superior court seeking his removal from the sex offender registry and relief from future registration obligations. The superior court denied the petition in reliance on People v. Manchel, a case that had rejected a Hofsheier claim by a defendant convicted of the same felony oral copulation offense at issue in this case. The Court of Appeal reversed, concluding that section 290’s registration requirement violated Plaintiff’s equal protection rights. The Supreme Court reversed, holding that Hofsheier’s constitutional analysis was faulty and therefore, Hofsheier is overruled. View "Johnson v. Dep’t of Justice" on Justia Law