Justia California Supreme Court Opinion Summaries

Sheriff's deputies came to the home of Shane Hayes in response to a call from a neighbor. When the deputies arrived, Hayes's girlfriend informe them that Hayes was suicidal. The deputies then entered the house, where Hayes came toward them with a large knife raised in his right hand. The deputies simultaneously drew their guns and fired at Hayes, who died from the gunshot wounds. Hayes's daughter filed a complaint in federal district court against the County of San Diego and the deputies, alleging three federal law claims and two state law claims. The district court granted summary judgment for Defendants on all claims, finding that the deputies owed Plaintiff no duty of care with respect to their preshooting conduct. The Ninth Circuit Court of Appeals asked the California Supreme Court to answer a question of state law. The Court answered by holding that, under California negligence law, liability can arise from tactical conduct and decisions employed by law enforcement preceding the use of deadly force if the conduct and decisions leading to the use of deadly force show, as part of the totality of the circumstances, that the use of deadly force was unreasonable.View "Hayes v. County of San Diego" on Justia Law

A jury convicted Defendants Stanley Bryant, Donald Franklin Smith, and Leroy Wheeler were convicted of various crimes relating to the fatal shooting of four individuals. Bryant and Wheeler were convicted of four counts of first degree murder and one count of attempted murder, and Smith was convicted of two counts of first degree murder, two counts of second degree murder, and one count of attempted murder. The jury returned verdicts of death. The Supreme Court affirmed the judgments, holding that any error or any error assumed for the sake of argument that occurred during the pretrial proceedings, the guilt phase, or the penalty phase were harmless. View "People v. Bryant" on Justia Law

Pursuant to the terms of a plea bargain, Defendant, who was an eighteen-year-old citizen of Mexico at the time, pleaded guilty to the sale or transportation of marijuana. After completing his probation, Defendant sought an adjustment in status to lawful permanent residency. Defendant's application was denied because of his conviction, and removal proceedings were initiated against him. Defendant filed a motion to vacate his conviction pursuant to Cal. Penal Code 1016.5, asserting that had he known the immigration consequences of pleading guilty, he would have rejected the plea offer. The only issue adjudicated at the hearing on Defendant's motion was whether he would have received a more favorable outcome had he rejected the plea bargain. The trial court denied the motion without considering the possibility Defendant might have rejected the plea bargain even if it were not reasonably probable he would have received a more favorable outcome. The Supreme Court reversed, holding (1) relief is available under section 1016.5 if the defendant establishes he would have rejected the existing bargain to accept or attempt to negotiate another; and (2) the trial court applied the incorrect test for prejudice in this case. Remanded. View "People v. Martinez" on Justia Law

After a jury trial, Defendant, an alleged member of the Mexican Mafia, was convicted of the first degree murders of three adults and two children. The jury also found true multiple-murder special-circumstance and weapon use sentence enhancement allegations. Defendant was sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in its rulings and decisions prior to trial; (2) the evidence was sufficient to support Defendant's convictions and the multiple-murder special-circumstance true finding; (3) the trial court did not err in the remainder of its rulings during the guilt phase of Defendant's trial; (4) the trial court did not engage in judicial misconduct during either the guilt phase or the penalty phase; (5) the prosecutor did not commit prejudicial misconduct during closing argument; (6) the trial court did not err in the remainder of its rulings during the penalty phase; and (7) California's death penalty statute is not constitutionally invalid.View "People v. Maciel" on Justia Law

After a jury trial, Defendant was found guilty of three counts of first degree murder, one count of attempted murder, and two counts of kidnapping. The jury found, among other things, that Defendant personally used a knife during each crime and inflicted great bodily injury on the kidnapping victims. The jury returned a verdict of death following the penalty phase of the trial. The trial rendered judgment on the verdict and sentenced Defendant to death. The Supreme Court affirmed the judgment, holding that there was no prejudicial error during pretrial proceedings, the guilt phase, or the penalty phase. View "People v. Lucas" on Justia Law

Three trials were held on the State’s petition to commit Defendant for secure confinement and treatment as a sexually violent predatory (SVP) under the Sexually Violent Predators Act. After a third jury trial and a second SVP finding, the Court of Appeal overturned the trial court’s judgment, concluding that multiple incidents of prosecutorial misconduct prejudiced Defendant and created a fundamentally unfair trial. The Supreme Court reversed after identifying one clear instance of misconduct and one other instance of arguable misconduct, holding that there was no reasonable probability that these incidents affected the outcome of the third trial, nor did they render the trial fundamentally unfair. Remanded to the Court of Appeal to address several additional claims raised by Defendant. View "People v. Shazier" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, among other crimes. The jury found true the special circumstance allegations that the murder was committed while Defendant was engaged in the commission of rape and oral copulation and the allegation that Defendant personally used a deadly weapon. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) juror misconduct occurred during the guilt phase, but Defendant was not prejudiced by that misconduct, and any error in the trial court’s evidentiary rulings was harmless; (2) there was no cumulative effect of error during the guilt phase; (2) there was no error at the penalty phase; and (3) Defendant’s challenges to the constitutionality of California’s death penalty law were without merit. View "People v. Merriman" on Justia Law

Defendant broadsided at high speed a vehicle driving by Loraine Wong. Wong’s younger daughter, Sydney, was killed, and her older daughter, Kendall, sustained serious injuries. A jury convicted Defendant of vehicular manslaughter with gross negligence and found true the allegation that he personally inflicted great bodily injury on Kendall. At issue on appeal was whether the trial court violated Defendant’s Fifth Amendment privilege against self-incrimination by admitting evidence that Defendant, following his arrest but before receipt of Miranda warnings, failed to inquire about the other people involved in the collision. The court of appeal reversed, holding that the trial court violated the Fifth Amendment privilege against self-crimination by admitting evidence of Defendant’s post-arrest, pre-Miranda failure to inquire about the welfare of the occupants of the other vehicle. The Supreme Court reversed, holding that Defendant needed to make a timely and unambiguous assertion of his Fifth Amendment privilege against self-incrimination in order to benefit from it. Remanded. View "People v. Tom" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and kidnapping with the purpose to commit a lewd act on a child under fourteen years old. The jury found true the special circumstance allegation of kidnapping murder and returned a verdict of death. The trial court sentenced Defendant to death on the murder count. The Supreme Court affirmed, holding (1) any error in the trial court’s rulings during the pretrial stage of the proceedings did not influence the verdict; (2) no prejudicial error occurred during the guilt phase; (3) the trial court did not abuse its discretion excluding certain statements from the penalty phase; and (4) Defendant’s challenges to California’s death penalty were without merit. View "People v. McCurdy" on Justia Law

After a jury trial in 1998 Defendant was convicted of two counts of first degree murder and one count of attempted murder, among other crimes. The jury found true the allegation that the attempted murder was committed willfully, deliberately and with premeditation. After a penalty phase retrial, the trial court imposed a sentence of death. The Supreme Court reduced the conviction of willful, deliberate, and premeditated attempted murder to attempted murder and, in all other respects, affirmed the judgment, holding (1) the trial court did not err in overruling Defendant’s objection to the prosecutor’s use of peremptory challenges against three black prospective jurors; (2) the jury was not properly instructed on the meaning of the terms “willful,” “deliberate,” and “premeditated,” and therefore, a reduction of Defendant’s conviction on count two to a conviction for regular attempted murder was warranted; (3) the trial court did not commit prejudicial error in its evidentiary rulings; (4) Defendant failed to establish that his attorney rendered ineffective assistance or that he was denied his right to a fair trial before an unbiased judge; and (5) during the penalty phase, the trial court erred by excluding evidence of institutional failure, evidence regarding Defendant’s antisocial personality disorder, and evidence about lingering doubt, but the errors were harmless. View "People v. Banks" on Justia Law