Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder under the special circumstances of kidnapping- and robbery-murder, of kidnapping, and of robbery. The jury also found Defendant personally used a firearm in committing each crime. The trial court imposed a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not prejudicially err in denying Defendant's motion to change venue; (2) the trial court did not err with regard to jury selection issues; (3) the trial court did not err with regard to guilt and special circumstance issues; (4) the trial court did not err with regard to certain penalty issues; and (5) not giving criminal defendants the right to take depositions does not violate equal protection. View "People v. Rountree" on Justia Law

After a jury trial, Defendant was found guilty of attempted voluntary manslaughter and assault with a firearm. Defendant waived a jury trial on the prior conviction allegations and admitted having suffered a prior serious felony conviction. Defendant informed the court, however, that the prior conviction had been reduced to a misdemeanor. The court sentenced Defendant to a total term of twenty-four years, which included a five-year sentence enhancement under Cal. Penal Code 667(a) based on Defendant's previously having been convicted of a serious felony. The court of appeal upheld imposition of the five-year enhancement, concluding that the prior assault remained a serious felony conviction for purposes of section 667(a), notwithstanding its having been reduced to a misdemeanor pursuant to Cal. Penal Code 17(b)(3) in 2006 and thereafter dismissed altogether. The Supreme Court reversed the judgment of the court of appeal insofar as it upheld imposition of a five-year sentence enhancement pursuant to section 667(a), holding that when the court in the prior proceeding reduced the assault conviction to a misdemeanor, that offense no longer qualified as a prior serious felony within the meaning of section 667(a), and could not be used to enhance Defendant's sentence. Remanded for resentencing. View "People v. Park" on Justia Law

After a jury trial, Defendant was found guilty of two first degree murders and two counts of second degree robbery. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) the trial court did not commit prejudicial error in pretrial proceedings, including its denial of three Batson/Wheeler motions; (2) the trial court did not commit prejudicial error during the guilt phase of the trial, including its upholding of the prosecutor's objection to defense counsel's questioning of an accomplice; (3) the trial court did not commit prejudicial err during the penalty phase of the trial; (4) Defendant failed to demonstrate he was prejudiced by trial counsel's assistance, and the remainder of Defendant's ineffective assistance of counsel claims could only be addressed in a habeas corpus petition; and (5) California's death penalty law is constitutional. View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of being an accessory for intentionally aiding a parolee in absconding from parole supervision. Defendant appealed, arguing that the act of assisting a parolee abscond from supervision did not satisfy the statutory definition of being an accessory. The court of appeal disagreed and affirmed her conviction. The Supreme Court affirmed, holding (1) Defendant assisted a parolee in absconding from parole because, under the relevant statute, Defendant aiding a principal in a felony with the intent that the principal could escape punishment; and (2) the court of appeal properly found substantial evidence supported Defendant's conviction. View "People v. Nuckles" on Justia Law

Defendant pleaded no contest to being a convicted felon in possession of a firearm and admitted a prior prison term allegation. The trial court imposed the stipulated prison sentence of four years and ordered Defendant to pay a jail booking fee. Defendant appealed, arguing (1) the statute authorizing the court to impose the booking fee required the court to determine if Defendant was able to pay it, and (2) Defendant was entitled to challenge this fee order for sufficiency of the evidence for the first time on appeal. The court of appeal affirmed the trial court's booking fee order. The Supreme Court affirmed, holding that a defendant who fails to contest the booking fee when the court imposes it forfeits the right to challenge it on appeal. View "People v. McCullough" on Justia Law

Defendant was charged with an assortment of felony and misdemeanor charges, mostly theft related. Over the prosecution's objection, Defendant pleaded no contest to all charges and was sentenced to five years in prison. The court of appeal held that the five-year sentence was the product of an unlawful judicial plea bargain and vacated Defendant's pleas and admissions. The Supreme Court affirmed in part, holding that the record was ambiguous as to whether the sentence proposed by the trial court reflected what the court believed was the appropriate punishment for Defendant and his offenses, regardless of whether Defendant was convicted by plea or following trial, or instead reflected what the court believed was necessary to induce Defendant to enter a plea. Remanded to the trial court to clarify the ambiguity. View "People v. Clancey" on Justia Law

After a jury trial, Defendant was found guilty of making a criminal threat, assault with a deadly weapon, and brandishing a weapon. Defendant was sentenced to a prison term of four years eight months. Defendant appealed, arguing that her state constitutional right to a unanimous jury verdict was violated because the court failed to ask the jury foreperson or the jurors to affirm their verdict as required by Cal. Penal Code 1149. The appeals court agreed, concluding that the error was structural and, thus, reversible per se. The Supreme Court reversed the court of appeal's judgment and affirmed the judgment of the trial court, holding (1) the error was not structural and instead was procedural error subject to harmless error review; and (2) the trial court's failure to follow section 1149's requirement was harmless in this case. View "People v. Anzalone" on Justia Law

Cal. Penal Code former section 1202.2(a) provided that the revocation of probation, "summary or otherwise, shall serve to toll the running of the probationary period." At issue in this case was whether, once probation has been summarily revoked, this tolling provision permits a trial court to find a violation of probation and then reinstate or terminate probation based solely on conduct that occurred after the court-imposed period of probation has elapsed. In this case, a three-year probation period was imposed on Defendant in 2000. In 2001, Defendant's probation was summarily revoked based on failure to report. Defendant failed to report or appear in court because he had been deported. The trial court later extended Defendant's probation as of 2007, after the expiration of the original three-year probationary period. In 2009, the court extended Defendant's probation and imposed a prison sentence based on conduct that occurred later in 2009. The court of appeal upheld the trial court's orders. The Supreme Court reversed, holding that section 1203.2(a)'s tolling provision preserves the trial court's authority to adjudicate, in a subsequent formal probation violation hearing, whether the probationer violated probation during, but not after the court-imposed probationary period. View "People v. Leiva" on Justia Law

Defendant was charged with sexually molesting two victims. A jury convicted Defendant of some counts involving one victim but deadlocked on all counts involving the other victim. Nevertheless, the jury returned a true finding on an allegation that Defendant had committed offenses against multiple victims. Believing the jury's true finding was in error, the trial court ordered further deliberations. The jury eventually returned with a blank verdict form and indicated it had deadlocked on the multiple victim allegation. A mistrial was declared, and Defendant was retried. A second jury convicted Defendant of counts involving the other victim and found true the multiple victim allegation. The court reversed the second jury's true finding on the multiple victim allegation, concluding that double jeopardy principles barred Defendant's retrial on the multiple victim allegation. The Supreme Court reversed, holding that because the first jury had no authority to decide or even to consider the multiple victim allegation after it deadlocked on the counts involving the other victim, no valid verdict could have been rendered on that allegation, and thus double jeopardy did not bar retrial on that allegation. View "People v. Carbajal" on Justia Law

Defendant was convicted of robbery and kidnapping for purposes of robbery on evidence from which a jury could have determined an accomplice, rather than Defendant, personally performed the act of asportation necessary to the offense of kidnapping. Defendant appealed, contending that the trial court erred in failing to instruct, sua sponte, on the law of accomplice liability. The court of appeal affirmed, holding that the trial court was obliged to instruct in principles of accomplice liability as to the kidnapping charge, but the error was harmless. The Supreme Court affirmed, holding (1) the trial court was required to instruct on aiding and abetting liability as a general legal principle raised by the evidence and necessary for the jury's understanding of the case; but (2) the error was harmless, as no reasonable probability existed of a more favorable outcome had accomplice liability instructions been given. View "People v. Delgado" on Justia Law