Justia California Supreme Court Opinion Summaries

Defendant was convicted of four counts of first degree murder and sentenced to death. The Supreme Court affirmed, holding (1) there was no prejudicial error committed during the guilt phase or the penalty phase of trial; (2) Defendant’s request that the Court take judicial notice of the decision of the Commission on Judicial Performance removing Judge Platt from judicial office two years after the completion of Defendant’s trial, as well as Judge Platt’s temporary suspension from the practice of law for the same underlying incidents, is denied, as Judge Platt’s removal from the bench and subsequent suspension are irrelevant to the proceedings against Defendant; (3) the prosecutor did not commit prejudicial misconduct in either phase of the trial; and (4) California’s death penalty statute is not unconstitutional. View "People v. Peoples" on Justia Law

After a jury trial, Defendant was convicted of murder and attempted premeditated murder, among other crimes. After a penalty phase, the jury returned a death verdict. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) as to issues arising during the guilt phase, (i) there was sufficient evidence to support the first degree murder conviction and the lying-in-wait special circumstance, (ii) the trial court did not err in its evidentiary rulings, and (iii) the instructions to the jury were proper; (2) as to issues arising during the penalty phase, (i) the trial court erred in admitting certain evidence, but the error was harmless, (ii) the admission of evidence of Defendant’s juvenile misconduct in aggravation was not error, (iii) the imposition of the death penalty based on a sole lying-in-wait special circumstance renders a defendant eligible for the death penalty, and (iv) California’s death penalty law is not unconstitutional. View "People v. Casares" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, conspiracy to commit murder, and as an accessory after the fact. After a penalty phase trial, the jury returned a verdict of death. The Supreme Court affirmed the judgment, holding (1) sufficient evidence supported the first degree murder verdict based on the theory of lying in wait; (2) the lying-in-wait special circumstances satisfies the requirements of the Eighth Amendment; (3) the trial court did not err in instructing the jury; (4) the trial court did not err in allowing the prosecutor to present victim impact evidence relating to noncapital crimes; (5) Defendant forfeited his claim that the prosecutor committed misconduct during closing remarks at the penalty phase by addressing his argument to jurors individually; and (6) Defendant’s challenges to the constitutionality of California’s death penalty law were without merit. View "People v. Johnson" on Justia Law

In 2014, the California Legislature sought to place on the general election ballot Proposition 49, a nonbinding advisory question that would have asked the electorate whether Congress should propose, and the Legislature ratify, a federal constitutional amendment overturning the U.S. Supreme Court’s decision in Citizens United v. Federal Election Commission. Petitioners filed an original emergency petition for writ of mandate in the Supreme Court seeking to prevent the Secretary of State from proceeding with placement of Proposition 49 on the November 2014 ballot. The Supreme Court issued an order to show cause and stayed the Secretary from taking further actions in connection with Proposition 49 until after a final decision, effectively removing the advisory question from the November 2014 ballot. Despite this case being moot, the Court resolved the merits of Proposition 49’s constitutionality. The Court denied the instant petition for a writ of mandate, holding that Proposition 49 is reasonably related to the Legislature’s authority to use advisory questions to inform the Legislature’s exercise of its powers under U.S. Const., art. V, and therefore, Proposition 49 is constitutional. View "Howard Jarvis Taxpayers Ass’n v. Padilla" on Justia Law

This case was a putative class action challenging an herb grower’s (Defendant) marketing of its herbs as organic. Defendant sought judgment on the pleadings on federal preemption and primary jurisdiction grounds, arguing that the Organic Foods Production Act of 1990 vests the United States Department of Agriculture with exclusive authority to to regulate the labeling and marketing of organic products and both expressly and impliedly preempts state truth-in-advertising requirements. The trial court agreed and entered a judgment for Defendant. The Court of Appeals affirmed, concluding that the express preemption provisions in the Organic Food Act did not foreclose state false advertising suits, but such suits were impliedly preempted. The Supreme Court reversed, holding that a state law claim that produce is being intentionally mislabeled as organic is neither expressly nor impliedly preempted. Remanded. View "Quesada v. Herb Thyme Farms, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and of being a felon in possession of a firearm. The trial court sentenced Defendant to death for the two murders. The Supreme Court affirmed the judgment in its entirety, holding (1) during the guilt phase, the trial court did not err in admitting evidence of Defendant’s past crimes and bad acts against his family; (2) the evidence was sufficient to support the first-degree murder convictions; (3) the jury instructions during both the guilt phase and the penalty phase were constitutional; (4) the trial court did not err in admitting purported victim impact testimony during either the guilt phase or the penalty phase; (5) the trial court did not err in admitting crime scene and autopsy photographs during the guilt phase; (6) Defendant’s death sentence was not grossly disproportionate to Defendant’s personal culpability; and (7) Defendant’s challenges to California’s death penalty scheme failed. View "People v. Cage" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the delay in bringing charges against Defendant did not violate his due process rights; (2) the trial court did not commit prejudicial error in its evidentiary rulings during the guilt phase of trial; (3) the prosecutor did not commit misconduct during the guilt phase closing argument; (4) the trial court did not commit prejudicial error in its evidentiary rulings during the penalty phase of trial; (5) the trial court properly instructed the jury during the penalty phase; and (6) the remainder of Defendant’s claims have already been rejected by the Court. View "People v. Cordova" on Justia Law

After a jury trial, Defendant was convicted of attempted robbery and first degree murder, among other charges. The jury returned a verdict of death for the murder, and the trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion when it ordered the use of leg restraints during trial; (2) the trial court did not abuse its discretion in dismissing one juror during trial and another juror during deliberations; (3) the trial court did not err in instructing the jury; (4) the trial court’s responses to the jury’s requests for clarification regarding the law of conspiracy was not in error; (5) Defendant’s claim that the jury was coerced into reaching a verdict was without merit; (6) no prejudicial error occurred during the penalty phase; (7) Defendant’s challenge to California’s death penalty statute failed; and (8) Defendant’s claim that the trial court improperly imposed restitution without considering his ability to pay failed. View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. Defendant was sentenced to death for the murder. While this appeal was pending, the United States District Court for the Central District of California issued its opinion in Jones v. Chappell, which held that systemic delays in implementing the California death penalty law rendered it unconstitutional under the Eighth Amendment. The Supreme Court affirmed the guilt and penalty phase judgments in their entirety, holding (1) any evidentiary errors did not require reversal under either state law or federal law; (2) Defendant’s claim of judicial misconduct was forfeited for appeal; (3) certain of Defendant’s claims of prosecutorial misconduct during the guilt phase were forfeited, other prosecutorial misconduct claims were without merit, and while the prosecutor committed misconduct in other instances, the misconduct was harmless; (4) the jury instructions were not in error; (5) no prejudicial misconduct occurred during the penalty phase; (6) a Jones claim has not been proved here; and (7) Defendant’s constitutional challenges to California’s death penalty statute failed. View "People v. Seumanu" on Justia Law

A police officer investigating an emergency call regarding a fight pulled behind Defendant’s parked vehicle and activated the emergency lights on his patrol car. The officer approached and spoke with Defendant, who was sitting behind the wheel of the vehicle, apparently intoxicated. Charged with felony driving under the influence, Defendant moved to suppress evidence of his physical condition, statements, and breath test results as the fruits of an unlawful search. The trial court denied the motion. The court of appeal affirmed. The Supreme Court affirmed, holding (1) the officer’s use of emergency lights in this situation constituted a detention of Defendant; and (2) Defendant’s brief detention was supported by reasonable suspicion. View "People v. Brown" on Justia Law