Justia California Supreme Court Opinion Summaries

Articles Posted in Civil Rights
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After a jury trial, Defendant was convicted of first degree murder, unlawful taking of a vehicle, and arson. The jury returned a verdict of death. The trial court sentenced Defendant to death on the murder count and imposed a determinate sentence on the remaining counts and enhancements. The Supreme Court affirmed, holding, (1) the trial court properly denied Defendant's motions for a change of venue; (2) the trial court did not err in its rulings regarding the selection of the jury; (3) the trial court did not prejudicially err in its decisions during the guilt phase of trial; (3) the trial court did not prejudicially err in its decisions during the penalty phase of trial; and (4) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Harris" on Justia Law

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After a jury trial, Defendant was convicted of two counts of first degree murder, two counts of attempted murder, and of committing forcible rape, sodomy, and oral copulation. Following a penalty trial, Defendant was sentenced to death. The Supreme Court affirmed in all respects, holding (1) the trial court did not err in its pretrial rulings contested by Defendant; (2) the trial court did not err in its rulings made during the guilt phasel; (3) the trial court did not err when instructing the jury during the guilt phase; (4) the trial court did not err during the penalty phase of the trial; and (5) having found no legal error, Defendant's claim that the cumulative effect of all errors required reversal was rejected. View "People v. Jones" on Justia Law

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After a jury-waived trial, Defendant was convicted of first degree murder. The court found true the special circumstance that the killing was intentional and that Defendant knew or should have known the victim was a peace officer engaged in the performance of duty. After a penalty jury returned a death verdict, Defendant was sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) Defendant's counsel did not labor under a conflict of interest or provide ineffective assistance; (2) the evidence supporting the special circumstance finding that Defendant intentionally killed a police officer engaged in the performance of duty was legally sufficient; (3) a certain juror was not biased on the issue of penalty; (4) substantial evidence supported the race-neutral reasons given by the prosecutor for his excusal of African-American prospective jurors; (5) the trial procedures did not deny Defendant reliable determinations of death eligibility and of the appropriate penalty; and (6) California's death penalty statute is not unconstitutional. View "People v. Mai" on Justia Law

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After a jury trial, Defendant was convicted of the first degree murder of Monique Cleveland, the willful, deliberate, and premeditated attempted murder of Robert Cleveland, and being a felon in possession of a firearm. After a penalty retrial, the jury returned a verdict of death on the murder conviction. The Supreme Court affirmed, holding that (1) any error on the trial court’s part in ordering Defendant to wear a stun belt during his trial was harmless because there was no reasonable possibility that Defendant would have received a more favorable verdict had the trial court not required him to wear a stun belt; (2) the evidence was sufficient to support Defendant’s convictions; and (3) the trial court did not commit reversible error in its rulings during the penalty retrial. View "People v. Jackson" on Justia Law

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After a jury trial, Defendant was convicted of resisting an executive officer in the performance of his duties pursuant to Cal. Penal Code 69. Defendant appealed, arguing that the trial court erred by denying his request to instruct the jury that it could instead convict him of the lesser offense of resisting a public officer under Cal. Penal Code 148(a)(1). The Supreme Court affirmed, holding (1) section 148(a)(1) was a necessarily included lesser offense of section 69 as alleged in the amended information; but (2) because substantial evidence did not reveal Defendant violated section 148(a)(1) without also violating section 69, the trial court did not err in refusing to instruct the jury on section 148(a)(1). View "People v. Smith" on Justia Law

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Defendants were part of a Bakersfield gang and were involved in various retaliatory shootings against perceived rivals. After a jury trial, Defendants were convicted of, inter alia, first degree murder with multiple-murder and gang-murder special circumstances, active gang participation, and conspiracy. The conspiracy count alleged that each Defendant had engaged in conspiracy to commit felony assault, robbery, murder, and gang participation. The court of appeals affirmed the conspiracy convictions, holding that conspiracy to actively participate in a criminal street gang did not qualify as a crime, but each conspiracy count was also based on the valid theory of conspiracy to commit murder. The Supreme Court reversed, holding that that a defendant may conspire to actively participate in a criminal street gang and may be separately charged once a conspirator has committed an overt act. Remanded. View "People v. Johnson" on Justia Law

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Plaintiff, a nonprofit public benefit corporation that was granted a charter in 2003 to serve Los Angeles County, had its charter revoked by the County Board of Education in 2007. Plaintiff appealed, contending that the revocation proceedings violated due process and revocation was not based on substantial evidence. The State Board of Education affirmed the revocation. The trial court issued a writ setting aside the revocation of the charter, finding that Plaintiff was not afforded a hearing before an impartial adjudicator because the County Board has an interest in ensuring that funds flowing to charter schools are reallocated to other public schools. The court of appeal reversed. The Supreme Court affirmed, holding that the school failed to establish that the Legislature's chosen procedures denied it the opportunity to be heard at a "meaningful time and in a meaningful manner" by a decision maker without financial or other bias. View "TodayÂ's Fresh Start, Inc. v. Los Angeles County Office of Educ. " on Justia Law

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At issue in this case was the database of information about land parcels in a geographic information system (GIS) file format maintained by Orange County and whether it was subject to disclosure at the actual cost of duplication under the California Public Records Act (PRA) or whether it was covered by the PRA's exclusion of "computer software" from the definition of a public record. Sierra Club requested a copy of the OC Landbase pursuant to the PRA. The County agreed to produce the records but refused to provide the records in GIS format unless Sierra Club paid a licensing fee and agreed to the license's restrictions on disclosure and distribution. Sierra Club subsequently sought a writ of mandate to compel the County to provide the OC Landbase in a GIS file format as a public record with no requirement that Sierra Club comply with the licensing agreement. The superior court denied the petition for writ of mandate, concluding that the OC Landbase in GIS file format was excluded from the PRA's general rules of disclosure. The Supreme Court reversed, holding that GIS-formatted databases like the OC Landbase are public records that must be produced upon request at the actual cost of duplication. View "Sierra Club v. Superior Court" on Justia Law

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After a jury trial, Defendant was convicted of possession of cocaine and resisting a peace officer. On appeal, Defendant argued that the trial court committed reversible error when, after finding the prosecution improperly used a peremptory challenge to discharge a prospective juror under People v. Wheeler, it reseated the juror instead of discharging the entire jury venire. The court of appeal agreed, finding that Defendant did not consent to the court's remedy of reseating the juror, therefore reversing Defendant's conviction. The Supreme Court reversed, holding (1) in the context of a trial court's order to reseat an improperly discharged prospective juror after the court granted the complaining party's Wheeler motion, the complaining party's assent to reseating the improperly discharged juror can be found on the basis of implied consent; and (2) in this case, Defendant did impliedly consent to the alternative remedy of reseating the juror. View "People v. Mata" on Justia Law

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After a jury trial, Defendant was convicted of first degree murder, kidnapping for child molestation, forcible rape, sodomy, and committing a lewd and lascivious act upon a child under fourteen. Prior to sentencing, the trial court ordered a new trial based on juror misconduct. On retrial, the second jury found Defendant guilty of the same charges. The trial court imposed a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not prejudicially err in its rulings during the guilt phase, sanity phase, and penalty phase of trial; (2) California's death penalty scheme and related jury instructions do not violate the United States Constitution; (3) the trial court did not prejudicially err in sentencing Defendant; and (4) the cumulative effect of the trial court's few errors did not warrant reversal. View "People v. DeHoyos" on Justia Law