Articles Posted in Constitutional Law

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The Supreme Court affirmed Defendant’s convictions of kidnapping, robbing, raping, torturing, and murder but reversed his death sentence, holding that multiple prospective jurors were improperly excused for cause. Defendant in this case was a black man sentenced to death for murdering a white woman. The prosecutor struck four black male jurors, leaving no black man on the jury. The Supreme Court held (1) under the standards of Witherspoon v. Illinois, 391 U.S. 510 (1968) and Wainwright v. Witt, 469 U.S. 412 (1985), the trial court erred by excusing jury candidates on the ground that they could not fairly and impartially consider whether death was the appropriate punishment; but (2) the trial court properly rejected Defendant’s Armstrong’s Batson claims. View "People v. Armstrong" on Justia Law

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The Supreme Court affirmed in part and reversed and remanded in part the judgment of the appellate court reversing the judgment of the trial court granted Defendants’ special motions to strike the second through sixth causes of action advanced by Plaintiffs in Plaintiffs’ dispute with the City of Carson and other defendants, holding that some of Plaintiffs’ causes of action were based on protected activities under Cal. Code Civ. Proc. 425.26(e)(2) and (e)(4) but others were not. After Plaintiffs brought this lawsuit Defendants responded by making a motion under the anti-SLAPP statute. The Supreme Court held that the causes of action asserted in Plaintiffs’ dispute with Defendants did not arise from Defendants’ acts in furtherance of their right of free speech in connection with a public issue with the exception of two discrete claims, which were within the scope of subdivision (e)(2) and (e)(4) of the anti-SLAPP statute, thus affirming in part and reversing in part the appellate court’s judgment. View "Rand Resources, LLC v. City of Carson" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of first degree murder and sentence of death on the murder count, holding that no reversible error occurred in the proceedings below. Specifically, the Court held (1) the trial court did not err in denying Defendant’s motion to suppress; (2) the trial court did not err in denying Defendant’s challenges for cause concerning a prospective juror or Defendant’s motion for additional peremptory challenges; (3) the trial court did not abuse its discretion in deciding not to sequester the jury; (4) Defendant’s child pornography charge was validly joined with his kidnapping and murder charges; (5) assuming the trial court erred in allowing certain testimony, the error was harmless; (6) any other error in the trial court’s evidentiary rulings was harmless; (7) the trial court did not commit prejudicial error in its instructions to the jury; and (8) Defendant’s challenges to the constitutionality of California’s death penalty law were unavailing. View "People v. Westerfield" on Justia 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