Justia California Supreme Court Opinion Summaries

The Supreme Court granted review in this criminal case to determine the continued viability of Cal. Penal Code 632(d) in light of the limits placed on the exclusion of evidence by the "Right to Truth in Evidence" provision of the California Constitution, holding that nothing in the amendments to section 632 evidenced an intent on the part of the Legislature to render surreptitious recordings once again inadmissible in criminal proceedings.Defendant was convicted of two counts of committing a lewd and lascivious act upon a child. The conviction was largely based on a secretly recorded conversation that violated section 632. The court of appeal, however, found that section 632(d), which prohibits the admission of "evidence obtained...in violation of this section...in any judicial, administrative, legislative, or other proceeding," had been abrogated by the Right to Truth in Evidence constitutional provision, which instructs that "except as provided by statute hereafter enacted...relevant evidence shall not be excluded in any criminal proceeding." The Supreme Court affirmed, holding (1) to the extent section 632(d) demanded suppression of relevant evidence in a criminal proceeding, it was abrogated by the voters' approval of Proposition 8; and (2) none of the Legislature's subsequent amendments to section 632 revived the exclusionary remedy of section 632(d). View "People v. Guzman" on Justia Law

The Supreme Court affirmed, as modified in this opinion, the judgments of the trial court convicting James David Beck and Gerald Dean Cruz of four counts of first degree murder and entering judgments of death based on the murders, holding that certain true findings as to Defendants' convictions of conspiracy to commit murder were unauthorized.Defendants were convicted of four counts of first degree murder and of conspiracy to commit murder. The jury also found true a multiple murder special circumstance allegation and allegations of personal use of a deadly weapon. The trial court entered judgments of death. The Supreme Court vacated the multiple murder special circumstances true findings as to conspiracy to commit murder, as well as the death sentences imposed for that count, and otherwise affirmed, holding (1) the trial court erred in imposing a death sentence based upon Defendants' conspiracy convictions because conspiracy to commit murder alone cannot make a defendant death eligible; and (2) there was error but no prejudice in some of the trial court's instructions, the prosecutor's argument during the penalty phase, the imposition of the death penalty for the convictions of conspiracy to commit murder, and in the admission of certain testimony, but these errors were not prejudicial when considered individually or cumulatively. View "People v. Beck" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death, holding that there were four possible errors during the penalty phase of trial, but none of those errors was prejudicial.Defendant was convicted of first degree murder, and the jury found true the special circumstance allegation that Defendant committed the murder while engaged in a home invasion robbery. The prosecution retried the penalty phase, and, after a second penalty phase, the trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's sentence, holding that the trial court's errors regarding the admission of certain testimony regarding Defendant's remorselessness, the admission of hearsay testimony, an erroneous instruction, and the failure to transfer a certain exhibit to the jury were not prejudicial. The dissent would have reversed on the grounds that the prosecution disproportionately excused black prospective jurors during the jury selection process. View "People v. Johnson" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant was not entitled to relief on his allegations of error.Defendant was convicted of first degree murder with special circumstances of murder in the commission of forcible sodomy, murder in the commission of a lewd act on a child, and murder by torture. The trial court sentenced Defendant to death. On appeal, Defendant asserted multiple claims of error. The Supreme Court affirmed, holding (1) there was no prejudicial error during the guilt phase of trial; and (2) the only errors committed during the penalty phase were two instances of prosecutorial misconduct in argument to the jury, and these errors were not prejudicial either individually or cumulatively. View "People v. Rhoades" on Justia Law

The Supreme Court reversed the opinion of the court of appeal reversing the judgment of the trial court ruling that the search of Defendant's car was invalid on the basis that the search was authorized under In re Arturo D., 27 Cal.4th 60 (Cal. 2002), holding that the desire to obtain a driver's identification following a traffic stop does not constitute an independent, categorical exception to the Fourth Amendment's warrant requirement, and to the extent Arturo D. held otherwise it should no longer be followed.Acting on a tip about Defendant's erratic driving, a police officer approached Defendant after she parked and exited her car. The police detained Defendant for unlicensed driving and, without asking her name, searched the car for Defendant's personal identification. The trial court held that the search was invalid under Arizona v. Gant, 556 U.S. 332 (2009). The Court of Appeals reversed, holding that the search was authorized under the Supreme Court's pre-Gant decision in Arturo D. The Supreme Court reversed, holding that the warrantless search of Defendant's vehicle in this case violated the Fourth Amendment. View "People v. Lopez" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of two counts of first-degree murder and related crimes and sentencing Defendant to death for each of the murder convictions, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) there was substantial evidence to support the trial court's denial of Defendant's Batson/Wheeler challenge; (2) as to the admission of Defendant's confession, the investigator should have stopped the interrogation on April 21, 1999 sooner than he did, but the error did not compel the exclusion of the confession obtained on April 22, 1999 or thereafter; (3) Defendant's arguments involving testimony of Defendant's volitional impairment did not require reversal of the death sentence; (4) the trial court did not err in admitting testimony by Defendant's former girlfriend, a photograph of Defendant, and evidence that Defendant lied about shooting a person; and (5) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Krebs" on Justia Law

The Supreme Court exercised its original jurisdiction to entertain an emergency petition for a writ of mandate that would forbid the Secretary of State from enforcing portions of the recently enabled Presidential Tax Transparency and Accountability Act, Cal. Elec. Code 6880 et seq. The Supreme Court granted that writ, holding that portions of the Act conflict with Cal. Const. art. II, 5(c) and are therefore invalid.Specifically, the Court held that Elections Code sections 6883 and 6884 are invalid under article II, section 5(c) insofar as they require someone who is recognized as a candidate for the office of President of the United States to file with the Secretary of State federal income tax returns for the five most recent taxable years as a necessary condition for appearing on the primary election ballot of a qualified political party. The Court held that this additional prerequisite conflicts with the California Constitution's specification of an inclusive open presidential primary ballot and therefore cannot lawfully be enforced. View "Patterson v. Padilla" on Justia Law

The Supreme Court reversed the judgment of the court of appeal finding the City of Oroville liable in inverse condemnation for property damage suffered by a dental practice when raw sewage began spewing from the toilets, sinks, and drains of its building, holding that where the dentists did not install a legally required backwater valve on their premises the City was not liable for the property damage.The dentists argued that the City was legally responsible for the property damage because it was caused by the sewer system's failure to function as intended. The City argued in response that the damage occurred because the dentists failed to install the backwater valve that would have prevented sewage from entering their building in the event of a sewer main backup. The trial court concluded that an inverse condemnation had occurred. The court of appeal affirmed. The Supreme Court reversed, holding that the damage was not substantially caused by the sewer system when the dentists failed to fulfill a responsibility to install a backwater valve that would have prevented or substantially diminished the risk of the mishap that occurred in this case. View "City of Oroville v. Superior Court of Butte County" on Justia Law

The Supreme Court disapproved the lead opinion in People v. Ray, 21 Cal.4th 464 (1999), in which the Court articulated a "community caretaking" exception to the warrant requirement for government entry into a private residence, holding that such an entry for reasons short of a perceived emergency, or similar exigency, fails to satisfy the relevant constitutional standard.Defendant was charged with manufacturing a controlled substance and firearm-related charges. Defendant filed a motion to suppress the evidence found in his home. The trial court denied the motion. Defendant later pleaded guilty. The court of appeal affirmed, concluding that, even in the absence of exigency, the warrantless entry of Defendant's home was justified under the "community caretaking" exception. The Supreme Court reversed, holding that the community caretaking exception asserted in the absence of exigency is not one of the carefully delineated exceptions to the residential warrant requirement recognized by the United States Supreme Court. View "People v. Ovieda" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and sentence of death, holding that there was no error in the proceedings below that entitled Defendant to reversal of his convictions.Specifically, the Court held (1) both prongs of Cal. Const. art. I, 28(d)'s requirement were met in this case, and allowing the jury to judge the relevant evidence did not violate Defendant's due process rights; (2) a witness's decision not to testify, upheld by the court, did not deny Defendant the right to present a defense; (3) the state and federal constitutions supported the trial court's decision to grant the witness her Fifth Amendment privilege; (4) Defendant's challenges to California's death penalty law were unavailing; and (5) Defendant failed to establish cumulative error because there were no errors to aggregate. View "People v. Capers" on Justia Law