Justia California Supreme Court Opinion Summaries

The defendant used a false pretense to enter the motel room of Carole Sund, her daughter Juli Sund, and family friend Silvina Pelosso. Once inside, he brandished a gun, used duct tape to bind the three, and murdered Carole and Silvina by strangulation and suffocation. Over several hours, he sexually assaulted Juli, then kidnapped her, assaulted her again, and ultimately killed her by slitting her throat. Months later, he also kidnapped, murdered, and decapitated Joie Armstrong. The defendant confessed to these crimes in detail. Physical evidence and testimony corroborated his confession. Evidence related to the Armstrong murder, prosecuted federally, was introduced during the penalty phase.A jury in the Santa Clara County Superior Court convicted the defendant of three counts of first-degree murder and one count of kidnapping. The jury found true multiple enhancement allegations, including use of a deadly weapon and firearm, and five special circumstances: multiple murders, kidnapping murder, attempted rape murder, forcible oral copulation murder, and burglary murder. The jury found not true the alleged robbery-murder special circumstance. In a separate sanity phase, the jury found the defendant sane at the time of the offenses, and in the penalty phase, recommended the death penalty. The trial court denied motions for a new trial and sentence modification, imposing death plus a consecutive prison term.On automatic appeal, the Supreme Court of California reviewed numerous claims, including challenges to the admission of the defendant’s confession, claims of evidentiary and procedural error, allegations of juror misconduct, and arguments regarding the constitutionality of California’s death penalty scheme. The Court held that the confession was properly admitted, the evidentiary and procedural rulings were within the trial court’s discretion, and that there was no prejudicial juror misconduct or judicial bias. The Court also rejected constitutional challenges to the death penalty statute. The Supreme Court of California affirmed the judgment in its entirety. View "People v. Stayner" on Justia Law

A man was arrested after attempting to purchase food at a restaurant using several credit cards, three of which were lost cards belonging to other individuals. When the first five cards were declined, he discarded them; the sixth card worked, but after a dispute with the manager over a refund, he left without the food and was later taken into custody. He was charged with multiple counts, including felony vandalism, identity theft, and petty theft. At arraignment, the trial court denied his motion for release on his own recognizance and set bail at $75,000, citing his extensive criminal history and past failures to appear. After further hearings, the trial court ultimately denied bail altogether.The defendant filed a petition for writ of habeas corpus in the California Court of Appeal, First Appellate District, Division Three, challenging the denial of bail. While the petition was pending, he entered a plea agreement, resulting in his release. The appellate court dismissed the petition as moot, but the Supreme Court of California directed the Court of Appeal to address unresolved constitutional questions regarding bail. The Court of Appeal issued a published opinion addressing the relationship between two California constitutional provisions on bail and whether a trial court may set bail above a defendant’s ability to pay. The appellate court's reasoning conflicted with another appellate decision, In re Brown.The Supreme Court of California reviewed the case to resolve these issues. It held that Article I, section 12, subdivisions (b) and (c), defines the exclusive circumstances under which bail may be denied in noncapital cases, and Article I, section 28(f)(3), can be harmonized with, but does not expand, these exceptions. The court further held that, except where pretrial detention is authorized, bail must be set in an amount reasonably attainable given the defendant’s circumstances; courts may not set bail at an amount that is objectively unattainable based solely on indigency. The Supreme Court affirmed the judgment of the Court of Appeal. View "In re Kowalczyk" on Justia Law

Two defendants were implicated in the 1985 kidnapping, rape, and murder of a woman in California. Evidence showed that they were previously involved in a string of armed robberies and planned to escape law enforcement by stealing a vehicle from a shopping center parking lot. They kidnapped the victim, drove her hundreds of miles, sexually assaulted her, and killed her before disposing of her body in a canal. Forensic evidence, including eyewitness testimony and DNA analysis, linked both men to the crimes. Both were arrested years later after advances in DNA technology allowed for retesting of biological evidence.The Sacramento County Superior Court tried the defendants together with separate juries. Each was found guilty of murder, rape, and kidnapping, with special circumstances for kidnapping-murder, robbery-murder, and rape-murder. One defendant was also convicted of sodomy with a sodomy-murder special circumstance. Both were sentenced to death after separate penalty phase trials. The court also imposed various prison terms and restitution fines, staying the execution of the prison sentences.The Supreme Court of California reviewed the case on automatic appeal. It affirmed the convictions of both defendants and the death sentence for one. However, it reversed the death sentence for the second defendant, finding that subsequent changes in the law—specifically regarding the competency of defendants with mental illness to represent themselves—required reversal of his sentence, including the death judgment. The court also vacated any balance of restitution fines for both defendants, pursuant to recent statutory amendments. The case was remanded for further proceedings as to the sentencing of the second defendant. View "P. v. Bertsch" on Justia Law

The case concerns a California statute that makes it a crime to knowingly file a false allegation of police misconduct and requires complainants to sign an advisory warning of potential criminal liability before their complaint is accepted. The Los Angeles Police Protective League sought an injunction compelling the City of Los Angeles to enforce this advisory requirement. The City had previously entered into a consent decree with the federal government prohibiting enforcement of the advisory, and even after the consent decree expired, continued not to require the advisory due to concerns about the statute’s constitutionality.The Superior Court of Los Angeles County, relying on the California Supreme Court’s earlier decision in People v. Stanistreet, granted the injunction and ordered the City to require the statutory advisory. The California Court of Appeal affirmed, adhering to Stanistreet’s reasoning that had upheld the statute’s constitutionality. The City then petitioned to the Supreme Court of California, arguing that subsequent federal decisions—especially Chaker v. Crogan by the Ninth Circuit—cast serious doubt on the continuing validity of Stanistreet and the constitutionality of the statute.Reviewing the case, the Supreme Court of California reconsidered its prior Stanistreet decision in light of more recent U.S. Supreme Court rulings, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that the statutory scheme—combining criminal penalties with a mandatory and prominently worded advisory—created a consequential risk of chilling truthful or well-intentioned complaints of police misconduct. The court concluded that this risk triggered heightened constitutional scrutiny under the First Amendment. The statute failed intermediate scrutiny because it was not narrowly tailored and burdened substantially more speech than necessary to serve the state’s legitimate interests. The court therefore reversed the judgment of the Court of Appeal. View "L.A. Police Protective League v. City of L.A." on Justia Law

One defendant in this case was a high-ranking member of the Varrio Fallbrook Locos gang and the Mexican Mafia, while a codefendant acted as a secretary within the gang structure. In December 2013, the defendant participated in a meeting regarding methamphetamine sales, which resulted in the violent assault of another gang member, A.C., after accusations of unpaid debts. Following the assault, the defendant attempted to prevent A.C. from testifying and conspired to arrange the murder of another gang affiliate. The defendant was convicted by a jury of multiple offenses, including assault with a deadly weapon, conspiracy to commit murder, and conspiracy to dissuade a witness, among others. The trial court imposed a lengthy prison sentence and ordered the defendant to pay various fines and ancillary costs, despite defense counsel’s request to consider the defendant’s inability to pay.The Court of Appeal for the Fourth Appellate District, Division One, reviewed the monetary orders. It held that the trial court should have considered the defendant’s ability to pay before imposing ancillary costs but rejected the argument that an ability-to-pay finding was required for punitive fines. The appellate court clarified that fines could still be challenged under the excessive fines clauses of the federal and state constitutions and remanded the case for resentencing and further proceedings regarding the fines and costs.The Supreme Court of California reviewed the case to resolve inconsistent approaches among lower courts concerning court-ordered financial obligations. The Court held that challenges to the amount of criminal fines must be reviewed under the excessive fines clauses of the United States and California Constitutions. Separately, the Court held that, upon request, a sentencing court must consider a defendant’s inability to pay before imposing court operations and facilities assessments, as failing to do so violates equal protection. The judgment was reversed in part and remanded for further proceedings consistent with these holdings. View "P. v. Kopp" on Justia Law

The case arises from the enactment of the 2017 Lesbian, Gay, Bisexual, and Transgender Long-Term Care Facility Residents’ Bill of Rights in California, which, among other things, prohibits 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 plaintiff, an association claiming taxpayer status, challenged this provision before it took effect, arguing that it was facially unconstitutional under the First Amendment.The Sacramento County Superior Court denied the petition for a writ of mandate, finding the pronouns provision to be a permissible, content-neutral restriction narrowly tailored to serve the state’s interest in preventing discrimination and harassment in long-term care facilities. The trial court rejected arguments that the law compelled speech or censored viewpoints, and found no First Amendment violation. On appeal, the California Court of Appeal, Third Appellate District, reversed in part. It held that the provision was content-based, subject to strict scrutiny, and was overinclusive, restricting more speech than necessary to achieve the government’s compelling interest in eliminating discrimination. The appellate court did not address standing.Upon review, the Supreme Court of California first concluded that the plaintiff lacked standing under the current version of Code of Civil Procedure section 526a, as amended in 2018, which limits taxpayer standing to suits against local, not state, entities. Nevertheless, due to the procedural posture and public importance, the court exercised its discretion to decide the merits. The Supreme Court of California held that the pronouns provision is a regulation of discriminatory conduct, not subject to First Amendment scrutiny as speech. Even if intermediate scrutiny applied, the law would be upheld. The court reversed the judgment of the Court of Appeal. View "Taking Offense v. State" on Justia Law

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