Justia California Supreme Court Opinion Summaries

Defendant, a prison inmate, was charged with escape from custody. However, Defendant only broke out of his cell and breached interior security barriers. The jury found Defendant guilty of escape from prison without force or violence. The court of appeal reversed, finding insufficient evidence of escape and concluding that the term "escape" under the relevant statute required an actual escape beyond the outer boundary of the prison facility having custody of that prisoner. The court refused to modify the escape conviction to attempt to escape. The Supreme Court affirmed, holding that the court of appeal correctly determined it could not modify the escape conviction to an attempt to escape, as the record contained evidence that could lead a rational jury to find the element of specific intent lacking. View "People v. Bailey" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, burglary, and robbery. The trial court sentenced Defendant to death. The Supreme Court remanded the case, holding that the trial court committed reversible error by permitting Defendant to represent himself during proceedings to determine whether he was mentally competent to stand trial. To remedy the error, the Court remanded the case for further proceedings to allow the trial court to determine whether a retrospective evaluation of Defendant's competence to stand trial was feasible and, if it was, to hold such a hearing. If the trial court determined that such a hearing was not feasible or Defendant was incompetent, Defendant was entitled to a new trial. View "People v. Lightsey" on Justia Law

Defendant Perla Gonzalez (Perla) recruited her brother and her boyfriend to assault Roberto Canas-Fuentes (Canas). After Canas fended off a knife attack and gained the upper hand in the fight, Perla handed the boyfriend a loaded rifle. Canas wrested the rifle away and shot the boyfriend dead. The jury convicted Perla of the attempted premeditated and deliberate murder of Canas and, based on the provocative act doctrine, the first degree murder of her boyfriend. The Supreme Court affirmed, holding (1) substantial evidence supported Perla's conviction for the murder of her boyfriend; and (2) the trial court erred in instructing the jury on the requirements for premeditated and deliberate first degree murder, but the error was harmless beyond a reasonable doubt. View "People v. Gonzalez" on Justia Law

In 1984 a jury convicted Defendant of first degree murder, attempted murder, attempted rape, and burglary. After a penalty trial, the jury set the penalty at death. The Supreme Court affirmed. In 1997, the Ninth Circuit Court of Appeals, while affirming the federal district court's denial of Defendant's petition for writ of habeas corpus as to the guilt phase, reversed its denial of the writ as to the death sentence. After the first retrial of the penalty phase resulted in a mistrial, a second penalty retrial was held, in which the jury returned a verdict of death. The Supreme Court affirmed, holding (1) the second penalty retrial was constitutional; (2) the trial court did not err by excusing prospective jurors; (3) the court did not erroneously admit victim impact evidence and giving related instructions; (4) the court did not err in excluding proffered defense expert opinion testimony or mitigating evidence; (5) there was no prejudicial prosecutorial misconduct; and (6) California's death penalty law and related standard jury instructions were constitutional and lawful. View "People v. McDowell" on Justia Law

Defendant, a convicted felon, carried a loaded and concealed firearm. A jury convicted Defendant of possession of a firearm by a felon, carrying a readily accessible concealed and unregistered firearm, and carrying an unregistered loaded firearm in public. Defendant appealed, arguing that Cal. Penal Code 654, which prohibits multiple punishment for an act that is punishable in different ways by different provisions of law, prohibited multiple punishment for his convictions. The court of appeal modified the judgment to stay execution of the sentence on count three and affirmed the judgment as modified. The Supreme Court reversed, holding that because different provisions of law punish in different ways Defendant's single act, section 654's plain language prohibits punishment for more than one of those crimes. Remanded. View "People v. Jones" on Justia Law

After police found Defendant Victor Correa hiding in a closet with a cache of guns, Defendant was convicted of seven counts of being a felon in possession of a firearm. The court of appeal affirmed. The Supreme Court initially limited review to the question of whether imposing sentence on more than one of these counts violated Cal. Penal Code 654's prohibition against multiple punishment for the same criminal act. The Court then requested supplemental briefing on the question of whether section 654 applies to multiple violations of the same criminal statute. The Supreme Court affirmed, holding (1) by its plain language, section 654 does not bar multiple punishment for multiple violations of the same criminal statute, but this interpretation was not applied to Defendant because the new rule may be applied prospectively only; and (2) even so, Defendant's sentence did not violate section 654 because specific statutory authority makes possession of each weapon a separate offense. View "People v. Correa" on Justia Law

This case arose from litigation challenging the validity, under the United States Constitution, of the initiative measure (Proposition 8) that added a section to the California Constitution providing that "[o]nly marriage between a man and a woman is valid or recognized in California" (Cal. Const., art. I, section 7.5). The Ninth Circuit posed the following procedural issue to the court, "[w]hether under article II, section 8 of the California Constitution, or otherwise under California law, the official proponents of an initiative measure possess either a particularized interest in the initiative's validity or the authority to assert the State's interest in the initiative's validity, which would enable them to defend the constitutionality of the initiative upon its adoption or appeal a judgment invalidating the initiative, when the public officials charged with that duty refused to do so." In response, the court concluded that when the public officials who ordinarily defended a challenged state law or appealed a judgment invalidating the law declined to do so, under article II, section 8 of the California Constitution and the relevant provisions of the Election Code, the official proponents of a voter-approved initiative measure were authorized to assert the state's interest in the initiative's validity, enabling the proponents to defend the constitutionality of the initiative and to appeal a judgment invalidating the initiative. View "Perry v. Brown" on Justia Law

Defendant had twice been convicted and sentenced to death for robbing and murdering the two managers of an apartment where he had lived. On his automatic appeal, the court addressed defendant's numerous claims of error. The court rejected defendant's claims and held that in those few instances in which the court found error or assumed the existence of error, the court concluded that any error was harmless. The court also held that, in combination, these errors did not compel the conclusion that defendant was denied a fair trial. Accordingly, the court affirmed the convictions and sentence of death. View "People v. Moore" on Justia Law

Real party in interest, as personal representative of his son's estate, filed a complaint in 2006 seeking a refund of state personal income taxes for the years 2000 and 2001, alleging that the estate had paid over $15 million as part of a tax amnesty program, reserving the right to seek a refund, and demanding a jury trial. At issue was whether a taxpayer had the right to a jury trial in an action for a refund of state income taxes. The court held that article I, section 16 of the California Constitution did not require a jury trial in a statutory action for a state income tax refund where the statutory cause of action for a tax refund was a purely legislative creation with no foundation in contract and where such statutory right of action occupied a different class from the common law form of action in which a jury trial was available. View "Franchise Tax Board v. The Superior Court of the City and County of San Francisco" on Justia Law