Justia California Supreme Court Opinion Summaries

Petitioner was found not guilty by reason of insanity of killing his father in 1981. Petitioner was committed to state hospital for a period reflecting the maximum term for voluntary manslaughter. In 2012, the district attorney petitioned to extend Petitioner’s commitment under Cal. Pen. Code 1026.5, which allows the commitment of a person found not guilty of a felony by reason of insanity to be extended for longer than the maximum prison sentence for the offense if, because of a mental disorder, the person represents a substantial danger to others. Petitioner filed a motion in limine to preclude his compelled testimony as a witness for the People. The trial court denied the motion. The Court of Appeal granted Petitioner’s petition for writ of mandate, concluding that section 1026.5(b)(7) unambiguously provided commitment extension respondents the right not to testify. The Supreme Court affirmed, holding that a person facing extended commitment has the right to testify at his or her not guilty by reason of insanity commitment extension hearing. View "Hudec v. Superior Court" on Justia Law

After a jury trial, Appellant was convicted of one count of murder with burglary and robbery special circumstances and other offenses. The trial court sentenced Defendant to death for the murder. The Supreme Court affirmed, holding that no prejudicial error occurred during the pretrial phase, the guilt phase, or the penalty phase. The dissent disagreed, remarking that the trial court abused its discretion in excluding certain out-of-court hearsay statements on the basis that any error was harmless beyond a reasonable doubt as to the guilt and penalty verdicts where the Attorney General did not argue that any error in the exclusion of the hearsay statements was harmless. View "People v. Grimes" on Justia Law

Petitioner was charged with three counts of first degree murder and related charges. Petitioner filed a motion to recuse the lead prosecutor on the case on grounds that the prosecutor allegedly knew one of the victims in the case, that two of the prosecutor’s adult children knew Petitioner and would be called as witnesses by the defense at the penalty phase if Petitioner was found guilty, and that the prosecutor’s daughter dated Petitioner’s friend, a proposed prosecution and defense penalty phase witness. The trial court denied Petitioner’s request for an evidentiary hearing and denied his motion to recuse the prosecutor. The Supreme Court reversed, holding that the trial court abused its discretion by denying Petitioner’s request for an evidentiary hearing on the ground that Petitioner had failed to make a prima facie showing that recusal was warranted, as a hearing was necessary to determine whether the conflict in this case would render it unlikely that Petitioner would receive a fair trial if the prosecutor was not recused as lead prosecutor in the case. View "Packer v. Superior Court" on Justia Law

After a jury trial, Defendants were convicted of kidnapping, first degree murder, and torture. Defendants filed a motion for new trial, asserting that that the jurors improperly discussed and considered during their deliberations Defendants’ decisions not to testify. The Court of Appeal reversed the convictions and ordered a new trial, concluding that the discussion of Defendants’ decisions not to testify constituted misconduct and the misconduct was categorically prejudicial, even assuming the foreperson had promptly and correctly reminded the jury of the court’s instructions to disregard Defendants’ decisions not to testify. The Supreme Court reversed, holding that the Court of Appeal erred in finding the presumption of prejudice could not be rebutted even if the jurors had been reminded of the court’s instructions not to consider that issue and no objective evidence indicted the reminder would have been ineffective. Remanded to the trial court to determine the nature and scope of the misconduct and the existence and timing of any reminder of the court’s instructions to disregard Defendants’ decisions not to testify. View "People v. Lavender" on Justia Law

After a jury trial, Defendant was convicted of two counts of committing lewd acts on a child under the age of fourteen and one misdemeanor count of annoying or molesting a child under the age of eighteen. During trial, the prosecutor used a diagram showing the boundaries of California to illustrate the standard of proof and urged the jury to convict based on a “reasonable” view of the evidence. Defense counsel did not object to the prosecutor’s argument. The Supreme Court reversed, holding (1) there was a reasonable probability that the prosecutor’s argument caused one or more jurors to convict Defendant based on a lesser standard than proof beyond a reasonable doubt; and (2) defense counsel’s failure to object to the alleged prosecutorial misconduct violated Defendant’s constitutional right to the effective assistance of counsel. View "People v. Centeno" on Justia Law

After a jury trial, Defendant was convicted of two counts of conspiracy. Based on the insufficiency of the evidence, the trial court granted Defendant’s motion for a new trial and dismissed the two conspiracy counts. The court of appeal reversed, reinstated the jury’s verdict, and ordered that the trial court, upon remittitur issuance, could consider Defendant’s remaining grounds for a new trial but that double jeopardy protections prevented Defendant from being retried. The Supreme Court reversed the judgment of the court of appeal to the extent that it barred Defendant from being retried, holding that, if the trial court grants Defendant a new trial on any of his remaining claims, he may be retried. View "People v. Eroshevich" on Justia Law

After a jury trial, Defendant was convicted of three counts of first-degree murder, attempted murder, and carjacking. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no prosecutorial misconduct during the guilt phase, and any improper conduct by the prosecutor during the penalty phase was not prejudicial; (2) there was no error in the jury instructions; (3) the admission of Defendant’s uncharged violent criminal conduct was relevant to the jury’s penalty determination and did not render Defendant’s trial constitutionally unfair; (4) there was no cumulative effect of error requiring reversal of the judgment; and (5) Defendant’s challenges to the death penalty failed. View "People v. Adams" on Justia Law

After a jury trial, Defendant was convicted of several offenses, including robbery and theft. The convictions stemmed from Defendant's acquisition of gift cards through his false representation that he was using valid payment cards to purchase the gift cards. Defendant challenged his robbery convictions, contending that the type of theft that constitutes a "felonious taking," an element of robbery, was theft by larceny only and not theft by false pretenses, the type of theft that Defendant committed. The court of appeal affirmed Defendant's robbery convictions, holding that theft by false pretenses can satisfy the "felonious taking" requirement of robbery. The Supreme Court reversed, holding that theft by false pretenses cannot satisfy the "felonious taking" element of robbery. Remanded.View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. The jury also found true the special circumstance allegations of burglary-murder and torture-murder. After the jury was unable to agree on a sentence, the trial court declared a mistrial. At the second penalty phase trial, the trial court entered a judgment of death. The Supreme Court affirmed, holding (1) the trial court did not commit prejudicial error in its rulings regarding pretrial issues; (2) the trial court did not prejudicially err in its rulings during the guilt phase of trial; and (3) the trial court did not prejudicially err in its rulings during the second penalty phase.View "People v. Edwards" on Justia Law

Kevin Reilly was originally committed as a sexually violent predator (SVP) in 2000. In 2008, the Secretary of the Department of Corrections and Rehabilitation sought a petition for recommitment. Two evaluators evaluated Reilly under the Sexually Violent Predator Act (SVPA) and concluded he was an SVP. The Office of Administrative Law subsequently determined that the initial evaluations supporting the petition were conducted under an assessment protocol that amounted to an invalid regulation. The evaluators subsequently re-evaluated Reilly based on In re Ronje, this time concluding that he no longer met the criteria for commitment as an SVP. The court of appeal subsequently dismissed the SVPA commitment petition based on Ronje, which ordered replacement evaluations in these circumstances without requiring a determination that the underlying mistake in the assessment protocol amounted to material error. The Supreme Court reversed, holding (1) the Ronje decision was error; (2) an alleged SVP must show that any fault that did occur under the assessment protocol contained a material error; and (3) the court of appeal erroneously dismissed the petition against Reilly without requiring a finding of material error.View "Reilly v. Superior Court of Orange County" on Justia Law