Justia California Supreme Court Opinion Summaries

A police union sought an injunction requiring the City of Los Angeles to comply with a state law mandating that anyone filing a complaint of police misconduct must first read and sign an advisory warning that knowingly filing a false complaint is a crime. The law, Penal Code section 148.6(a), singles out complaints against peace officers for this treatment, and its legislative history shows it was enacted to address concerns about reputational and professional harm to officers from false complaints, as well as the administrative burden of investigating such claims.Previously, the Los Angeles County Superior Court granted the injunction, finding itself bound by the California Supreme Court’s earlier decision in People v. Stanistreet, which had upheld the constitutionality of section 148.6(a). The California Court of Appeal affirmed, also relying on Stanistreet, despite several federal court decisions—including Chaker v. Crogan and Hamilton v. City of San Bernardino—holding that the statute violated the First Amendment.The Supreme Court of California reviewed the case and reconsidered its prior holding in light of subsequent U.S. Supreme Court decisions, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that section 148.6(a) is a content-based regulation within a proscribable category of speech (defamation) but, as drafted, it incidentally burdens protected speech by deterring truthful or well-intentioned complaints of police misconduct. Applying intermediate scrutiny, the court found the statute was not narrowly tailored to serve the government’s interests and burdened substantially more speech than necessary. The Supreme Court of California reversed the Court of Appeal’s judgment and remanded the case for further proceedings. View "L.A. Police Protective League v. City of L.A." on Justia Law

In 2017, the California Legislature enacted the LGBT Long-Term Care Facility Residents’ Bill of Rights, which included a provision prohibiting staff at long-term care facilities from willfully and repeatedly failing to use a resident’s preferred name or pronouns after being clearly informed of them, when such conduct is based on the resident’s sexual orientation, gender identity, gender expression, or HIV status. The law was designed to address documented discrimination and mistreatment of LGBT seniors in long-term care settings, where residents are particularly vulnerable and often lack alternative support networks.Before the pronouns provision took effect, Taking Offense, an association opposed to laws requiring recognition of transgender identities, filed a petition for writ of mandate in Sacramento County Superior Court, seeking to block enforcement of the provision as facially unconstitutional under the First Amendment. The trial court denied the petition, finding the law to be a permissible, narrowly tailored regulation serving a significant state interest in preventing discrimination. On appeal, the California Court of Appeal, Third Appellate District, reversed in part, holding that the pronouns provision was a content-based restriction on speech that failed strict scrutiny and was therefore facially unconstitutional.The Supreme Court of California reviewed the case. The State argued for the first time that Taking Offense lacked taxpayer standing under Code of Civil Procedure section 526a, as amended in 2018, which now limits such standing to suits against local, not state, entities. The Supreme Court agreed but exercised its discretion to address the merits due to the public importance of the constitutional question. The Court held that the pronouns provision regulates discriminatory conduct that only incidentally affects speech, is not subject to First Amendment scrutiny as an abridgment of free speech, and, even if intermediate scrutiny applied, the provision would satisfy that standard. The Court reversed the Court of Appeal’s judgment. View "Taking Offense v. State of Cal." on Justia Law

In 2009, a defendant was sentenced to an indeterminate term of 28 years to life under California’s original Three Strikes law after his third felony conviction, which was not classified as serious or violent. He also received three one-year enhancements for prior prison terms. In 2012, California voters passed the Three Strikes Reform Act (Proposition 36), which limited indeterminate life sentences to cases where the third strike was serious or violent, and allowed those serving indeterminate sentences for nonserious, nonviolent felonies to petition for resentencing, subject to a discretionary public safety determination by the court.After the Reform Act, the defendant petitioned for resentencing under section 1170.126, but the Santa Barbara County Superior Court denied the petition, finding his release would pose an unreasonable risk to public safety. The California Court of Appeal affirmed this decision. In 2021, the Legislature enacted Senate Bill No. 483, which retroactively invalidated certain prior prison term enhancements and required courts to recall and resentence affected defendants, applying any changes in law that reduce sentences. The defendant sought resentencing under this new law, and the trial court resentenced him to a determinate eight-year term. The Santa Barbara District Attorney challenged this, arguing that the new law unconstitutionally amended the voter-enacted Reform Act by bypassing its public safety requirement. The Court of Appeal agreed and reversed the trial court’s decision.The Supreme Court of California reviewed whether Penal Code section 1172.75, as applied, unconstitutionally amended the Reform Act. The Court held that section 1172.75 must be interpreted to incorporate the Reform Act’s discretionary public safety determination for nonserious, nonviolent third strike offenders seeking resentencing. This interpretation harmonizes the statutes and avoids constitutional conflict, allowing the revised penalty provisions to apply only if the court finds resentencing does not pose an unreasonable risk to public safety. The Court reversed the Court of Appeal and remanded for further proceedings consistent with this holding. View "P. v. Guevara" on Justia Law

The case involved a defendant who was convicted by a jury of first-degree murder and two counts of attempted murder, all arising from a gang-related shooting in Visalia, California. The prosecution presented evidence that the defendant was a member of the North Side Visalia gang and that he shot individuals he believed to be rival gang members, resulting in one death and serious injury to another. The prosecution’s case relied heavily on expert testimony to establish the defendant’s gang membership and the gang-related nature of the crimes, as well as evidence of prior offenses by the defendant and other gang members. The defense argued that the shooting was not premeditated or gang-motivated, but rather stemmed from a personal dispute, and presented evidence that the defendant had renounced gang affiliation.The Tulare County Superior Court denied the defendant’s pretrial motion to recuse the entire District Attorney’s Office after his former defense attorney joined that office, finding that an effective ethical wall had been established. At trial, the jury found the defendant guilty on all counts, found true the gang enhancements and the gang-murder special circumstance, and returned a death verdict. The trial court entered judgment accordingly.On automatic appeal, the Supreme Court of California reviewed the case. The court held that, due to subsequent legal developments—specifically, its decision in People v. Sanchez and legislative amendments to Penal Code section 186.22 by Assembly Bill 333—the evidence was insufficient to support the gang enhancements and the gang-murder special circumstance. As a result, the court reversed the gang-related findings and the death judgment. The court also ordered a limited remand to allow the defendant to further develop his claim that his trial counsel violated his Sixth Amendment right of autonomy over the defense, as articulated in McCoy v. Louisiana. The convictions and death judgment were reversed and the case remanded for further proceedings. View "P. v. Cardenas" on Justia Law

William Cannon was convicted of assault with intent to commit rape and dissuading a witness, after attacking a 16-year-old girl and confessing to other attempted sexual assaults. Near the end of his prison sentence, the district attorney petitioned to commit him under the Sexually Violent Predator Act (SVPA), which allows for the civil commitment of certain sex offenders after their sentences if they are found to be sexually violent predators. During pretrial proceedings, Cannon’s attorney, without Cannon’s personal attendance or express waiver, waived his right to a jury trial. The trial court did not advise Cannon of his jury trial rights or seek his personal waiver, as the SVPA does not require these steps. Following a bench trial, Cannon was found to be a sexually violent predator and was committed.On appeal, Cannon argued for the first time that the SVPA’s procedures violated his state and federal equal protection rights because, unlike other civil commitment schemes for individuals found not guilty by reason of insanity (NGI) or those with mental health disorders (OMHD), the SVPA does not require a judicial advisement of the right to a jury trial or a personal waiver from the defendant. The Court of Appeal considered the equal protection claim despite it not being raised below, found that rational basis review was the appropriate standard, and remanded the case to the trial court to allow the parties to develop a fuller record and litigate the equal protection issue.The Supreme Court of California reviewed the case to determine the appropriate standard of scrutiny for Cannon’s equal protection challenge. The court held that rational basis review, not strict scrutiny, applies to the SVPA’s jury trial demand and waiver procedures. The court affirmed the Court of Appeal’s remand order, directing the trial court to determine whether the legislative choice of procedures is constitutionally justified under rational basis review and whether Cannon knowingly waived his right to a jury trial. The order of commitment is conditionally affirmed pending the outcome of those proceedings. View "P. v. Cannon" on Justia Law

An employee was hired by a company and, as a condition of employment, signed an agreement requiring all employment-related claims to be resolved through arbitration governed by the Federal Arbitration Act (FAA). The agreement specified that the employer would pay all arbitration costs except for certain fees. After the employee reported alleged workplace harassment and was subsequently terminated, he sued the employer in California Superior Court for retaliation and other violations. The employer moved to compel arbitration, which the court granted, and arbitration commenced. After about a year, the arbitrator issued invoices for fees, which the employer failed to pay within 30 days of receipt, as required by California Code of Civil Procedure section 1281.98. The employee then sought to withdraw from arbitration and proceed in court, arguing the employer’s late payment constituted a material breach under section 1281.98.The Superior Court denied the employee’s motion, reasoning that the arbitrator had set a new due date for payment and the employer paid within 30 days of that date. The California Court of Appeal reversed, holding that the statutory 30-day deadline applied from the original invoice date and that the employer’s late payment resulted in a material breach, allowing the employee to withdraw from arbitration. The Court of Appeal also held that section 1281.98 was not preempted by the FAA.The Supreme Court of California reviewed the case to determine whether section 1281.98 is preempted by the FAA. The court held that section 1281.98 is not preempted, but clarified that the statute does not abrogate longstanding contract principles allowing relief from forfeiture for non-willful, non-grossly negligent, or non-fraudulent breaches. The court reversed the Court of Appeal’s order lifting the stay and remanded for the trial court to determine whether the employer’s late payment was excusable and whether the employee suffered compensable harm. View "Hohenshelt v. Superior Court" on Justia Law

The defendant was convicted of three first-degree murders and several related offenses, including rape and sexual penetration with a foreign object, committed between 1988 and 1998 in Stockton and Oakland, California. The prosecution’s case relied heavily on DNA evidence linking the defendant to the victims, as well as ballistics evidence connecting the same firearm to multiple murders. The victims were found in isolated areas, often bound, and killed by gunshots to the head. The defendant was also convicted of the rape and kidnapping of another woman, Yvette R., who survived and testified. The defense presented no evidence at the guilt phase but, during the penalty phase, offered expert testimony about the defendant’s abusive childhood and mental health issues, including sexual sadism.The San Joaquin County Superior Court jury found the defendant guilty on all counts, found true the special circumstance allegations (multiple murders and murder during rape), and returned death verdicts for each murder. The court imposed a death sentence and additional terms for the noncapital offenses. The defendant’s appeal to the Supreme Court of California was automatic.The Supreme Court of California reviewed numerous claims, including alleged instructional errors, challenges to the constitutionality of special circumstances, claims of prosecutorial misconduct, and issues related to victim impact evidence and penalty phase instructions. The court held that there was no substantial evidence to support instructions on voluntary manslaughter or that the victims were dead at the time of sexual assault, and found no reversible error in the instructions given. The court also rejected challenges to the constitutionality of California’s death penalty scheme and the admission of victim impact evidence. The court found harmless any error in failing to redefine reasonable doubt at the penalty phase and in the response to a jury question about parole eligibility. The judgment was affirmed in its entirety, with a minor correction to the firearm enhancement terms. View "People v. Choyce" on Justia Law

Eric Wiley pled guilty to making a criminal threat in January 2020, for which the trial court imposed a three-year upper term prison sentence, suspended execution, and placed him on probation for three years. In March 2022, while on probation, Wiley pled guilty to being a felon in possession of a firearm. The trial court found he violated his probation terms, revoked probation, and sentenced him to the upper term of three years for the criminal threat and an additional eight months for the firearm possession.The Court of Appeal upheld Wiley’s sentence, rejecting his Sixth Amendment challenge. The court reasoned that the trial court’s findings regarding the increasing seriousness of Wiley’s prior convictions and his poor performance on probation were permissible under the Almendarez-Torres exception, which allows judges to consider recidivism-related facts without a jury.The Supreme Court of California reviewed the case and held that the trial court violated Wiley’s federal constitutional right to a jury trial by adjudicating underlying facts related to his prior convictions and relying on those conclusions to impose an upper term sentence. The court determined that under the recent U.S. Supreme Court decision in Erlinger v. United States, a judge may only determine the fact of a prior conviction and its elements, not make qualitative assessments about the seriousness of prior convictions or probation performance. The court overruled its previous decisions in People v. Towne and People v. Black, which had allowed broader judicial fact-finding related to recidivism.The Supreme Court of California found the error prejudicial and reversed the judgment of the Court of Appeal, remanding the case for further proceedings consistent with its opinion. View "P. v. Wiley" on Justia Law

The case involves Jeremiah Ira Williams, who was sentenced to an indeterminate prison term of 100 years to life plus 86 years and two months for committing multiple forcible sexual offenses under California's One Strike law when he was 24 years old. Williams argued that the exclusion of One Strike offenders from early parole eligibility under California’s youth offender parole statute (Pen. Code, § 3051) violated his equal protection rights under the Fourteenth Amendment. He contended that it was irrational to exclude young adults convicted of One Strike offenses from early parole while not excluding young adults convicted of murder without special circumstances.The San Diego County Superior Court convicted Williams on multiple counts, including robbery, forcible rape, and sodomy by use of force, among others. The jury found him guilty on most counts and found true several aggravating factors, including personal use of a firearm and infliction of great bodily injury. The trial court imposed the lengthy sentence based on these findings. Williams appealed to the Fourth Appellate District, Division One, arguing that the exclusion of One Strike offenders from early parole eligibility violated equal protection. The Court of Appeal rejected his claim, finding a rational basis for the differential treatment based on the threat of recidivism by violent sexual offenders.The Supreme Court of California reviewed the case and affirmed the Court of Appeal’s judgment. The court held that the Legislature could rationally exclude One Strike offenders from early parole eligibility under section 3051 based on concerns about the high risk of recidivism and the aggravated nature of their offenses. The court concluded that these concerns provided a rational basis for the differential treatment, thus rejecting Williams' equal protection challenge. The court remanded the matter to the Court of Appeal to consider any briefing on Williams' entitlement to the benefit of any ameliorative legislation enacted during the pendency of his appeal. View "People v. Williams" on Justia Law

Robert Ward Frazier was convicted by a jury of the murder, forcible rape, and forcible sodomy of Kathleen Loreck. The jury also found true two felony-murder special-circumstance allegations. At the penalty phase, the jury returned a death verdict, which the trial court upheld, sentencing Frazier to death. Frazier's appeal is automatic.The trial court excused a prospective juror for cause due to his views on the death penalty, denied Frazier's request for individually sequestered voir dire, and gave a jury instruction on flight from the scene of a crime. The court also denied Frazier's requests to represent himself during the penalty phase and post-verdict proceedings, including the hearing on his automatic motion to modify the death verdict and sentencing.The California Supreme Court affirmed the trial court's decisions. The court held that the trial court did not err in excusing the prospective juror, as substantial evidence supported the finding that the juror's views would substantially impair his performance. The court also found no error in denying individually sequestered voir dire, as there is no federal constitutional requirement for such in capital cases, and the trial court did not abuse its discretion under state law.The court upheld the flight instruction, finding sufficient evidence to support it and rejecting Frazier's additional arguments against the instruction. The court also ruled that Frazier's requests for self-representation were untimely and that the trial court did not abuse its discretion in denying them. Finally, the court rejected Frazier's claim that his Sixth Amendment right to choose the objective of his defense was violated by the presentation of certain mitigating evidence over his objection. View "P. v. Frazier" on Justia Law