Articles Posted in Constitutional Law

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The Supreme Court affirmed the trial court’s judgment convicting Defendant of the first degree murders of her three children, vacated two of the jury’s three multiple-murder special-circumstance findings, reversed Defendant’s sentence of death, and remanded the matter for a new penalty determination. The Supreme Court held (1) the trial court did not commit reversible error in denying Defendant’s request for self-representation under Faretta v. California, 422 U.S. 806 (1975), and no other prejudicial error occurred during the guilt phase proceedings; (2) two of the three multiple-murder special-circumstance allegations were erroneously charged and found true in this case; and (3) the trial court erred in excusing a prospective juror for cause based solely on her written questionnaire responses concerning her personal views on the death penalty, requiring reversal of Defendant’s penalty judgment. View "People v. Buenrostro" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree murder and sentencing him to death, holding that Defendant suffered no prejudice in the proceedings below. Specifically, the Court held (1) Defendant’s guilty plea was valid because Cal. Penal Code 1018 allows advisory counsel to satisfy the statutory requirements imposed on counsel in the case of a defendant who has exercised the right to self-representation; (2) the restraints placed on Defendant during the penalty trial and the denial of any writing instrument did not violate Defendant’s right to participate in his own defense or any other constitutional rights; and (3) Defendant’s challenges to California’s death penalty scheme and standard jury instructions were unavailing. View "People v. Miracle" on Justia Law

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The Supreme Court reversed the judgment of the Court of Appeal and remanded with directions to reverse Defendant’s judgment of conviction, holding that the trial court erred in failing to suspend the criminal trial and initiate competency proceedings when defense counsel declared a doubt about her client’s competence. Here, Defendant, a formerly incompetent defendant, was restored to competence primarily through administration of medication. At the start of Defendant’s jury trial, Defendant began exhibiting signs of incompetence, and the trial court learned that Defendant had stopped taking his medication. After counsel declared a doubt as to Defendant’s competence the trial court conducted a brief colloquy with Defendant. The court then ruled that the trial could proceed. Defendant was ultimately convicted on several counts and sentenced to multiple life terms. The Supreme Court reversed, holding that the trial court’s failure to suspend proceedings and conduct a formal investigation into Defendant’s incompetence violated Defendant’s constitutional guarantee of due process. View "People v. Rodas" on Justia Law

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The Supreme Court affirmed in its entirety the judgment of the trial court imposing a sentence of death after a jury convicted Defendant of first degree murder, holding that no reversible error occurred in the proceedings below. Defendant was convicted of first degree murder, robbery, and grand theft. The jury found that the murder occurred during a robbery and that Defendant personally used a firearm. The jury then returned a verdict of death. The trial court imposed that sentence, as well as an aggregate determinate sentence of eight years four months. The Supreme Court affirmed, holding that no prejudicial error occurred during the pretrial proceedings, the guilt phase proceedings, or the penalty phase proceedings. Further, the Court held that Defendant’s death judgment did not constitute cruel and unusual punishment in light of his youth and intellectual shortcomings, that Defendant’s challenges to the constitutionality of California’s death penalty statute failed, and that Defendant’s claim of cumulative prejudice must be rejected. View "People v. Powell" on Justia Law

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The Supreme Court held that voter approval was not required for a transfer from a utility’s enterprise fund to the city’s general fund. Cal. Const. art. XIIIC prohibits local governments from imposing or increasing any tax without voter approval. Any charge imposed for a service or product that does not exceed the reasonable costs of providing it is excepted from the definition of tax. The City of Redding operated an electric utility as a department of its city government. At issue was whether an annual interfund transfer from the utility’s enterprise fund to the city’s general fund required voter approval where the transfer was intended to compensate the general fund for costs of services that other city departments provide to the utility. The Supreme Court held that because neither the budgetary transfer nor the rate the city charged its utility customers constituted a tax, voter approval was not required. View "Citizens for Fair REU Rates v. City of Redding" on Justia Law

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The Supreme Court affirmed the judgment of the Court of Appeal concluding that some overlap between the Investigative Consumer Reporting Agencies Act (ICRAA), Cal. Civ. Code 1786 et seq. and the Consumer Credit Reporting Agencies Act (CCRAA), Cal. Civ. Code 1785.1 et seq., does not render ICRAA unconstitutionally vague as applied to employer background checks when the statutes are otherwise unambiguous. In this class action, Plaintiff sued Defendants, investigative consumer reporting agencies, for violating ICRAA because Defendants did not obtain her written authorization to conduct a background check. Defendants moved for summary judgment, claiming (1) ICRAA was unconstitutionally vague as applied to Plaintiff’s claim because it overlapped with CCRAA, and (2) Defendants satisfied CCRAA. The trial court granted the motion. The Court of Appeal reversed. The Supreme Court affirmed and remanded, holding (1) the background check that Defendants conducted was an investigative consumer report under ICRAA; and (2) although the CCRAA also applied here, Defendants were not exempted from the requirement that they obtain Plaintiff’s written authorization under ICRAA before conducting or procuring a background investigation. View "Connor v. First Student, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death following a second penalty proceeding, holding that there was no error requiring reversal. Specifically, the Court held (1) the Ireland merger doctrine did not bar Defendant’s convictions for torture murder and mayhem murder; (2) the evidence was sufficient to support Defendant’s convictions for torture murder and rape murder; (3) the trial court’s admission of gang affiliation evidence during the guilt phase of trial was harmless; (4) the evidence supported the special circumstance findings of torture murder and mayhem murder; (5) the jury’s finding that Defendant was sane at the time of the killing did not require reversal; (6) the trial court did not err in admitting evidence of Defendant’s possible gang affiliation and racist beliefs during the penalty phase; (7) imposition of the death penalty on a mentally ill defendant does not violate the Eighth Amendment; and (8) Defendant’s constitutional challenges to California’s imposition of the death penalty failed. View "People v. Powell" on Justia Law

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After issuing an order to show cause with respect to Petitioner habeas claim that prejudicial juror misconduct occurred when a juror did not timely disclose a history of childhood abuse, the Supreme Court discharged the order to show cause and held that Petitioner was not entitled to relief. Petitioner was convicted of four counts of first degree murder and was sentenced to death. Petitioner then filed this amended habeas corpus petition alleging that the jury foreperson had committed misconduct by concealing that he was abused as a child. The Supreme Court issued an order to show cause and ordered a reference hearing directing a referee to answer four questions. After an evidentiary hearing, the referee found that there was no prejudicial juror misconduct because the juror’s nondisclosure was neither intentional nor deliberate and that juror was not biased against Petitioner. The Supreme Court agreed generally with the referee’s findings and held that Petitioner failed to establish that he was entitled to habeas corpus relief on his claim of prejudicial juror misconduct. View "In re Manriquez" on Justia Law

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The Supreme Court reversed the sentence of death imposed in connection with Defendant’s conviction for the first degree murder of a police officer and the attempted murder of a police officer, holding that the trial court, over defense objection, erroneously excused for cause a prospective juror based on his written response to questions about his view on capital punishment, requiring reversal of the penalty verdict. After finding that Defendant did not have an intellectual disability, and following a penalty trial, the jury returned a verdict of death. The trial court imposed a judgment of death after denying the automatic motion to modify the verdict. The court also imposed a prison sentence on the other counts for which Defendant was convicted and enhancement allegations. The Supreme Court held (1) the trial court erred in excusing a prospective juror based on his questionnaire responses, an error that automatically compelled reversal of the penalty phase; and (2) the trial court’s judgment is affirmed in all other respects. View "People v. Woodruff" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of murdering James Madden and sentencing Defendant to death. On appeal, Defendant raised a number of issues, most of which focused on purported errors made by the trial court. Defendant also took issue with the Supreme Court’s decision not to supplement the appellate record with the trial transcripts of his codefendants and also challenged the constitutionality of California’s death penalty scheme. The Supreme Court affirmed the judgment of the trial court in its entirety, holding that there was no reversible error in this case. View "People v. Spencer" on Justia Law