Justia California Supreme Court Opinion Summaries

The Supreme Court held that, in disciplinary proceedings, private universities are not required to provide accused students the opportunity to directly or indirectly cross-examine the accuser and other witnesses at a live hearing with the accused student in attendance, either in person or virtually.The University of Southern California and its vice president of student affairs (collectively, USC) expelled Appellant after conducting an investigation and determining that Appellant violated USC's policy against engaging in intimate partner violence. Appellant filed a petition for a writ of administrative mandate, arguing that he was deprived of a fair trial under Cal. Code Civ. Proc. 1094.5. The court of appeals agreed, determining that USC's disciplinary procedures were unfair because they denied Appellant a meaningful opportunity to cross-examine critical witnesses at an in-person hearing. The Supreme Court reversed, holding that requiring private universities to conduct the hearing envisioned by the court of appeals was contrary to fair procedure caselaw. View "Boermeester v. Carry" on Justia Law

The Supreme Court affirmed Defendant's sentence of death, following resentencing, in connection with his convictions of first degree murder, two counts of forcible rape, and enhancements for personal use of a firearm, holding that any error in the resentencing was harmless beyond a reasonable doubt.When Defendant was convicted in 2000 the jury found true special circumstances for committing murder during a kidnapping and intentional infliction of torture and set the penalty at death. The Supreme Court upheld the guilt judgment but reversed the penalty verdict on the grounds that the trial court erroneously dismissed a juror during penalty phase deliberations. After a retrial, Defendant was again sentenced to death. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar Defendant's penalty retrial; (2) the penalty retrial did not violate due process; (3) Defendant's challenges to the constitutionality of California's death penalty statute were unavailing; and (4) any error brought about by retroactive application of Senate Bill 1437 was harmless beyond a reasonable doubt. View "People v. Wilson" on Justia Law

The Supreme Court held that Cal. Penal Code 667.6(d), which requires that a sentencing court impose "full, separate, and consecutive" terms for certain sex crimes if it finds certain facts, complies with the Sixth Amendment to the United States Constitution.Defendant was convicted of six counts of forcible lewd acts on a child under the age of fourteen and one lesser-included offense of attempt and sentenced to full, consecutive terms for each of his convictions. On appeal, Defendant argued that the trial court violated his Sixth Amendment right to a jury trial by sentencing him under section 667.6(d) without submitting to the jury the question of whether each of his offenses was committed on a separate occasion. The court of appeal denied relief. The Supreme Court affirmed, holding that the operation of section 667.6(d) does not violate the rule of Apprendi v. New Jersey, 530 U.S. 466 (2000), and Alleyne v. United States, 570 U.S. 99 (2013). View "People v. Catarino" on Justia Law

A gambling dispute incited a fistfight between gang subsets. Witnesses later testified that after they thought the fight was over, they saw Ferrell shoot a gun, then saw Rawlings, lying on the ground, bloodied. Ferrell dropped the gun and fled. Ferrell later claimed he had only shot once, into the air. The juvenile court transferred Ferrell, age 17, to a court of criminal jurisdiction, where he was charged with murder, with alleged sentencing enhancements for use of a firearm.The Court of Appeal affirmed Ferrell’s second-degree murder conviction and 40-year sentence. The California Supreme Court granted Ferrell habeas relief. The jury instructions erroneously permitted the conviction based on a felony-murder theory invalidated in 2009. The unadorned guilty verdict does not show that the jury avoided that theory. The court rejected an argument that the jury’s additional finding — that Ferrell intentionally discharged a firearm and caused death in committing his offense — along with other evidence, establish that any rational jury would have found Ferrell guilty under a valid theory of second-degree murder, implied malice. Even in light of the entire record, the jury’s additional finding fails to establish the mental component of implied malice, which requires a defendant to act with a conscious disregard for life, knowing his act endangers another’s life. The jury could have, consistent with its finding, concluded Ferrell shot Rawlings while trying to stop a fight without believing he was shooting toward any person. View "In re Ferrell" on Justia Law

In 2005, a jury convicted Lopez and three others of Gomez’s first-degree premeditated murder and found true the gang-murder special circumstance and the criminal street gang sentencing enhancement. Lopez was sentenced to life imprisonment without the possibility of parole. The Court of Appeal affirmed. Lopez sought habeas relief, alleging his jury had been instructed on the natural and probable consequences theory of aiding and abetting first-degree murder, found invalid in the California Supreme Court's 2014 "Chiu" decision. In 2019, the Court of Appeal held that the Chiu error was harmless beyond a reasonable doubt based on the gang-murder special circumstance, which required the jury to find that an aider and abettor acted with intent to kill, and the “overwhelming” evidence against Lopez generally. The court discounted the prosecutor’s discussion of the natural and probable consequences theory in his closing argument and found a jury note referencing that theory inconsequential under the circumstances.The California Supreme Court reversed. The gang-murder special circumstance here does not necessarily render the Chiu error harmless beyond a reasonable doubt but indications that the jury may have relied on an invalid theory, such as a prosecutor’s closing argument or a jury note, do not preclude a finding of harmlessness. The court must rigorously review the evidence to determine whether any rational juror who found the defendant guilty based on an invalid theory and made the factual findings reflected in the verdict, would necessarily have found the defendant guilty based on a valid theory. View "In re Lopez" on Justia Law

The Supreme Court affirmed Defendant's conviction for the first degree murder of Rafael Noriega and his sentence of death, holding that there was no reversible error in the proceedings below.A jury convicted Defendant of first degree murder and found true the special circumstance allegation that the murder was committed while Defendant was engaged in the commission of a robbery. The jury also found true the special circumstance allegation that Defendant was previously convicted of murder. The jury returned a verdict of death, and the trial court denied Defendant's ensuing motion for modification of his sentence. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant's right to self-representation in its rulings regarding Defendant's funding requests; (2) there was no error or abuse of discretion in the district court's evidentiary rulings; (3) Defendant's challenges to the special service allegations were unavailing; (4) there was no error in the jury instructions; (5) there was no error or abuse of discretion during the penalty phase; and (6) Defendant's challenges to the constitutionality of California's death penalty law failed. View "People v. Thomas" on Justia Law

The Supreme Court reversed Defendant's conviction for three counts of first degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request.Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless. View "People v. Waldon" on Justia Law

The Supreme Court held that a law enforcement officer's act of shining a spotlight for illumination does not ipso facto constitute a detention under the Fourth Amendment, but rather, the proper inquiry requires consideration of the totality of the circumstances, including the use of the spotlight.Defendant was charged with drug offenses after a law enforcement officer conducted a search of the car he was driving. At issue was whether the officer engaged in a consensual encounter when he pulled behind Defendant's car and turned on his spotlight. The court of appeal concluded that spotlight illumination and approach on foot did not "manifest a sufficient show of police authority to constitute a detention." The Supreme Court agreed, holding (1) under the totality of the circumstances, Defendant was not detained by the officer's use of a spotlight; and (2) remand was appropriate for a new factual finding as to whether the officer's detention of the vehicle's female passenger effectuated a detention of Defendant. View "People v. Tacardon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the juvenile court finding true that Minor had committed one count of violating Cal. Penal Code 288.5 and order probation, thus rejecting Minor's claims that a community service provision of the disposition violated separation of powers principles and infringed his due process rights, holding that there was no error.In affirming, the appellate court acknowledged that a juvenile court may not delegate to a probation officer the authority to determine that a minor is in violation of probation but held that, in this case, the juvenile court's order permitting the probation officer to offer Minor the option of community service for an alleged violation did not permit the probation department to decide if and when a violation of probation had occurred. The Supreme Court affirmed, holding that the juvenile court order authorizing the probation officer to offer Minor on probation the option of performing community service, in an amount chosen by the probation officer up to a maximum set by the court, in the event Minor was alleged to have violated a term of probation, did not violate due process or separation of powers principles. View "In re D.N." on Justia Law

The Supreme Court affirmed the decision of the court of appeal upholding the trial court's finding that trial may continue in Defendant's absence under Cal. Penal Code 1043(b)(2) because the absence was voluntary, holding that the trial court did not violate Defendant's constitutional rights by finding him to be voluntarily absent without conducting an evidentiary hearing regarding the circumstances of his absence.On appeal, the court of appeal concluded that substantial evidence supported the trial court's finding that Defendant voluntarily absented himself from trial and that the court's decision to proceed with trial rather than grant defense counsel's motion for a one-day continuance constituted harmless error. The Supreme Court affirmed, holding that substantial evidence supported the trial court's finding of voluntary absence under the circumstances of this case. View "People v. Ramirez" on Justia Law