Justia California Supreme Court Opinion Summaries

The sentences imposed on Defendants, two juvenile nohomicide offenders, violated the Eighth Amendment as interpreted in People v. Caballero, 55 Cal.4th 262, 268 (2012) and Graham v. Florida, 460 U.S. 48 (2010).Defendants, Leonel Contreras and William Rodriguez, were convicted in a joint trial of kidnapping and sexual offenses that they committed when they were sixteen years old. Contreras was sentenced to a term of fifty-eight years to life, and Rodriguez was sentenced to a term of fifty years to life. The Court of Appeal affirmed Defendants’ convictions but reversed their sentences and remanded for resentencing, holding that Defendants’ sentences fell short of giving them a realistic chance for release, as contemplated by Graham. The Supreme Court affirmed, holding that Defendants’ sentences violated the Eighth Amendment under the standards articulated in Graham. The court directed the sentencing court, upon resentencing, any mitigating circumstances of Defendants’ lives and crimes and the impact of any new legislation and regulations on appropriate sentencing. View "People v. Contreras" on Justia Law

The sentences imposed on Defendants, two juvenile nohomicide offenders, violated the Eighth Amendment as interpreted in People v. Caballero, 55 Cal.4th 262, 268 (2012) and Graham v. Florida, 460 U.S. 48 (2010).Defendants, Leonel Contreras and William Rodriguez, were convicted in a joint trial of kidnapping and sexual offenses that they committed when they were sixteen years old. Contreras was sentenced to a term of fifty-eight years to life, and Rodriguez was sentenced to a term of fifty years to life. The Court of Appeal affirmed Defendants’ convictions but reversed their sentences and remanded for resentencing, holding that Defendants’ sentences fell short of giving them a realistic chance for release, as contemplated by Graham. The Supreme Court affirmed, holding that Defendants’ sentences violated the Eighth Amendment under the standards articulated in Graham. The court directed the sentencing court, upon resentencing, any mitigating circumstances of Defendants’ lives and crimes and the impact of any new legislation and regulations on appropriate sentencing. View "People v. Contreras" on Justia Law

Chatman, convicted of robbery in 2001, was sentenced to five years of felony probation plus 180 days in jail. Two years later, Chatman was convicted of misdemeanor reckless driving with alcohol. In 2006-2007 both convictions were dismissed under Penal Code section 1203.4. In 2008, Chatman was convicted of misdemeanor driving under the influence and was sentenced to three years of probation plus 10 days of imprisonment. In 2014, Chatman was offered a job that required a community care license from the Department of Social Services. Although Chatman’s robbery conviction bars him from obtaining that license, the Department may grant an exemption if a prospective employee has a Section 4852.01 certificate of rehabilitation (Health & Saf. Code 1522(g)(1)(A)(ii)). Once former probationers have their convictions dismissed under section 1203.4, section 4852.01 renders them ineligible for a certificate of rehabilitation if they are subsequently incarcerated. Former prisoners –– whether subsequently incarcerated or not –– face no such restriction. Chatman claimed that the unequal treatment was unconstitutional. The Supreme Court of California rejected that argument. Section 4852.01’s eligibility criteria survive rational basis review. Former probationers, as opposed to former prisoners, can seek some relief from the effects of their convictions through section 1203.4, and so have less relative need for certificate of rehabilitation relief. Instead of choosing an arbitrary means of limiting access to certificates, legislators used subsequent incarceration as a means of determining which former probationers show the most promise for rehabilitation. View "People v. Chatman" on Justia Law

The trial court violated Defendant’s Sixth Amendment right to a jury trial when it found a disputed fact about the conduct underlying Defendant’s assault conviction that had not been established by virtue of the conviction itself.Defendant was convicted of second degree robbery and transportation of a controlled substances, among other offenses. The prosecution sought an increased sentence from the maximum term of imprisonment on the ground that Defendant had previously been convicted of a “serious felony” under Cal. Penal Code 667(a) that was also a strike for purposes of the Three Strikes law. That conviction was for assault with a deadly weapon or with force likely to produce great bodily injury. The trial court determined that Defendant did commit the assault with a deadly weapon and sentenced her to a term of eleven years’ imprisonment. On appeal, Defendant argued that her increased sentence rested upon an exercise in judicial fact-finding that violated her Sixth Amendment right to a jury trial. The Supreme Court disapproved of People v. McGee, 38 Cal.4th 682 (Cal. 2006) insofar as it suggested that the trial court’s factfinding was constitutionally permissible and held that Defendant’s increased sentence rested on an exercise in judicial fact-finding that violated her Sixth Amendment right to a jury trial. View "People v. Gallardo" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant’s automatic motion to modify the jury’s verdict of death and imposing a judgment of death in this case in which Defendant pleaded guilty to two counts of first degree murder under the special circumstances of multiple murder and murder in the course of a robbery.In affirming, the Supreme Court held (1) Defendant’s counsel provided constitutionally effective assistance; (2) the trial court did not prejudicially err in denying Defendant’s motion to change venue; (3) no prejudicial error occurred during jury selection; (4) Defendant’s challenges to the admission of certain testimony were unavailing; (5) reliance on evidence in aggravation of two crimes of violence Defendant committed when he was seventeen years old and of his conviction for one of those crimes did not violate Defendant’s rights under the Eighth Amendment; (6) there was no error in excluding evidence of the impact of Defendant’s execution on his family; and (7) none of Defendant’s remaining arguments warranted relief from the judgment. View "People v. Rices" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of first degree murder and one count of second degree murder and sentencing him to death. The court held (1) Defendant was not deprived of the right to a jury drawn from a fair cross-section of the community; (2) the trial court did not err in ruling that evidence of an uncharged murder would be admissible to impeach Defendant’s witness under certain circumstances; (3) the trial court did not err in ruling that the prosecution could admit evidence that Defendant had attempted to escape from jail; (4) the trial court did not err in admitting the victim’s statement that Defendant was into “heavy stuff” or in admitting victim impact evidence; (4) there was no prejudicial error in the jury instruction; (5) the trial court did not err in denying Defendant’s requests for a separate penalty phase jury and sequestered voir dire; (6) Defendant was not prejudiced by any improper argument by the prosecutor; (7) the trial court did not abuse its discretion in admitting photographs of the victims or evidence that Defendant will kill a guard to escape; and (8) Defendant’s sentence was constitutional. View "People v. Henriquez" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the court of appeal in this case concerning the application of constitutional limitations to a statutorily authorized ground water charge imposed on well operators by a local water conservation district to fund certain conservation activities. The City of San Buenaventura argued (1) the charges violate article XIII D of the California Constitution; and (2) alternatively, the charges violate article XIII C of the California Constitution, as amended by Proposition 26. The Supreme Court held (1) the court of appeal properly concluded that article XIII C, as amended by Proposition 26, rather than article XIII D, supplies the proper framework for evaluating the constitutionality of the groundwater pumping charges at issue in this case; but (2) because the court of appeal did not address the City’s argument that the charges do not bear a fair or reasonable relationship to the payor’s burdens or on benefits from the United Water Conservation District’s conservation activities, as required by article XIII C, this case must be remanded for consideration of that question. View "City of San Buenaventura v. United Water Conservation District" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of first-degree murder and other crimes and sentencing him to death but remanded the case to the trial court for reconsideration of Defendant’s restitution fine. The court held (1) although Defendant’s absent from portions of the proceedings violated his statutory right to be present, the error was harmless; (2) the trial court did not violate Defendant’s right to an impartial jury by excusing a prospective juror for cause because of her views on the death penalty; (3) the trial court did not err in admitting Defendant’s confession; (4) the trial court did not abuse its discretion by excluding evidence of a conditional plea offer as mitigation during the penalty phase; (5) Defendant’s challenges to California’s death penalty scheme were unavailing; and (6) the trial court applied the wrong statute in imposing Defendant’s restitution fine. View "People v. Wall" on Justia Law

The scan data gathered by automated license plate reader (ALPR) technology in this case was not subject to Cal. Gov. Code 6254(f)’s exemption for record of investigations.Petitioners filed a request under the California Public Records Act (CPRA) for all ALPR data collected during a one-week period by the Los Angeles Police Department and the Los Angeles Sheriff’s Department. At issue before the Supreme Court was whether the requested ALPR data was exempt from disclosure as falling within the CPRA provision protecting police and state records of investigations under section 6254(f). The trial court concluded that the data came within section 6254(f)’s records of investigations exemption. The Court of Appeal affirmed. The Supreme Court reversed the Court of Appeal judgment insofar as it rendered anonymized or redacted ALPR data exempt from disclosure, holding that the ALPR scan data at issue was not subject to section 6254(f)’s exemption for records of investigations. The court remanded for further consideration of whether raw data may reasonably be anonymized or redacted such that the balance of interests would shift and disclosure of the data would be required under the CPRA. View "American Civil Liberties Union Foundation of Southern California v. Superior Court of Los Angeles County" on Justia Law

The Supreme Court of California held that, in light of the text and other indicia of the purpose associated with the relevant constitutional and statutory provisions, Cal. Const., art. XIII C, section 2 does not limit voters' power to raise taxes by statutory initiative. The court explained that a contrary conclusion would require an unreasonably broad construction of the term "local government" at the expense of the people’s constitutional right to direct democracy, undermining the longstanding and consistent view that courts should protect and liberally construe it. In this case, the California Cannabis Coalition drafted a medical marijuana initiative proposing to repeal an existing City ordinance. The Coalition subsequently petitioned for a writ of mandate when the City failed to submit the initiative to the voters at a special election. The supreme court affirmed the court of appeal's holding that article XIII C, section 2 only governs levies that are imposed by local government, and thus directed the superior court to issue a writ of mandate compelling the City to place the initiative on a special ballot in accordance with Elections Code section 9214. View "California Cannabis Coalition v. Upland" on Justia Law