Justia California Supreme Court Opinion Summaries

In 2005, a jury convicted Lopez and three others of Gomez’s first-degree premeditated murder and found true the gang-murder special circumstance and the criminal street gang sentencing enhancement. Lopez was sentenced to life imprisonment without the possibility of parole. The Court of Appeal affirmed. Lopez sought habeas relief, alleging his jury had been instructed on the natural and probable consequences theory of aiding and abetting first-degree murder, found invalid in the California Supreme Court's 2014 "Chiu" decision. In 2019, the Court of Appeal held that the Chiu error was harmless beyond a reasonable doubt based on the gang-murder special circumstance, which required the jury to find that an aider and abettor acted with intent to kill, and the “overwhelming” evidence against Lopez generally. The court discounted the prosecutor’s discussion of the natural and probable consequences theory in his closing argument and found a jury note referencing that theory inconsequential under the circumstances.The California Supreme Court reversed. The gang-murder special circumstance here does not necessarily render the Chiu error harmless beyond a reasonable doubt but indications that the jury may have relied on an invalid theory, such as a prosecutor’s closing argument or a jury note, do not preclude a finding of harmlessness. The court must rigorously review the evidence to determine whether any rational juror who found the defendant guilty based on an invalid theory and made the factual findings reflected in the verdict, would necessarily have found the defendant guilty based on a valid theory. View "In re Lopez" on Justia Law

The Supreme Court affirmed Defendant's conviction for the first degree murder of Rafael Noriega and his sentence of death, holding that there was no reversible error in the proceedings below.A jury convicted Defendant of first degree murder and found true the special circumstance allegation that the murder was committed while Defendant was engaged in the commission of a robbery. The jury also found true the special circumstance allegation that Defendant was previously convicted of murder. The jury returned a verdict of death, and the trial court denied Defendant's ensuing motion for modification of his sentence. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant's right to self-representation in its rulings regarding Defendant's funding requests; (2) there was no error or abuse of discretion in the district court's evidentiary rulings; (3) Defendant's challenges to the special service allegations were unavailing; (4) there was no error in the jury instructions; (5) there was no error or abuse of discretion during the penalty phase; and (6) Defendant's challenges to the constitutionality of California's death penalty law failed. View "People v. Thomas" on Justia Law

The Supreme Court reversed Defendant's conviction for three counts of first degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request.Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless. View "People v. Waldon" on Justia Law

The Supreme Court held that a law enforcement officer's act of shining a spotlight for illumination does not ipso facto constitute a detention under the Fourth Amendment, but rather, the proper inquiry requires consideration of the totality of the circumstances, including the use of the spotlight.Defendant was charged with drug offenses after a law enforcement officer conducted a search of the car he was driving. At issue was whether the officer engaged in a consensual encounter when he pulled behind Defendant's car and turned on his spotlight. The court of appeal concluded that spotlight illumination and approach on foot did not "manifest a sufficient show of police authority to constitute a detention." The Supreme Court agreed, holding (1) under the totality of the circumstances, Defendant was not detained by the officer's use of a spotlight; and (2) remand was appropriate for a new factual finding as to whether the officer's detention of the vehicle's female passenger effectuated a detention of Defendant. View "People v. Tacardon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the juvenile court finding true that Minor had committed one count of violating Cal. Penal Code 288.5 and order probation, thus rejecting Minor's claims that a community service provision of the disposition violated separation of powers principles and infringed his due process rights, holding that there was no error.In affirming, the appellate court acknowledged that a juvenile court may not delegate to a probation officer the authority to determine that a minor is in violation of probation but held that, in this case, the juvenile court's order permitting the probation officer to offer Minor the option of community service for an alleged violation did not permit the probation department to decide if and when a violation of probation had occurred. The Supreme Court affirmed, holding that the juvenile court order authorizing the probation officer to offer Minor on probation the option of performing community service, in an amount chosen by the probation officer up to a maximum set by the court, in the event Minor was alleged to have violated a term of probation, did not violate due process or separation of powers principles. View "In re D.N." on Justia Law

The Supreme Court affirmed the decision of the court of appeal upholding the trial court's finding that trial may continue in Defendant's absence under Cal. Penal Code 1043(b)(2) because the absence was voluntary, holding that the trial court did not violate Defendant's constitutional rights by finding him to be voluntarily absent without conducting an evidentiary hearing regarding the circumstances of his absence.On appeal, the court of appeal concluded that substantial evidence supported the trial court's finding that Defendant voluntarily absented himself from trial and that the court's decision to proceed with trial rather than grant defense counsel's motion for a one-day continuance constituted harmless error. The Supreme Court affirmed, holding that substantial evidence supported the trial court's finding of voluntary absence under the circumstances of this case. View "People v. Ramirez" on Justia Law

The Supreme Court affirmed the judgment of the superior convicting Defendant, following a jury trial, of first degree murder and sentencing him to death, holding that Defendant failed to demonstrate that alleged errors occurring at the guilt phase of trial cumulated in his not having received a "fair trial on the issue of his mental state at the time of the shooting."Specifically, the Supreme Court held (1) the trial court committed error under state law by ordering that Defendant submit to an examination by the prosecution expert and allowing the jury to learn of Defendant's refusal to be examined, but these errors were not prejudicial; (2) the prosecutor's comments regarding the ethics of forensic psychiatry did not infect the trial with unfairness that rose to the level of prejudicial error; (3) the trial court erred in admitting a law enforcement officer's statement under People v. Sanchez, 63 Cal.4th 665 (2016), but the error did not contribute to the jury's verdict; (4) the guilt phase errors were not cumulatively prejudicial; (5) the trial court did not err in excusing a prospective juror for cause because of her views on the death penalty; and (6) no other prejudicial error occurred during the penalty phase of the trial. View "People v. Camacho" on Justia Law

The Supreme Court reversed the judgment of the court of appeal holding that a sidewalk picket purporting to protest a real estate company's business practices after the company evicted two long-term residents from their home did not constitute speech in connection with a public issue under the anti-SLAPP statute's catchall provision, holding that the sidewalk protest constituted protected activity within the meaning of Cal. Code Civ. Proc. 425.16(e)(4).The court of appeal held that the sidewalk picket at issue was beyond the scope of anti-SLAPP protection because the picket did not implicate a public issue. Rather, the court of appeal concluded that the picket concerned only a private dispute between the real estate company and the two residents. The Supreme Court reversed after applying both steps of the analysis set forth in FilmOn.com Inc v. DoubleVerify Inc., 7 Cal.5th 133 (2019), holding that the sidewalk protest furthered public discussion of the public issues it implicated. View "Geiser v. Kuhns" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death but struck the enhancement that Defendant committed the murder for the benefit of, at the direction of, or in association with a criminal street gang, holding that there was no basis for reversing Defendant's convictions or sentence.After a jury trial, Defendant was convicted of first-degree murder. The jury found true the gang enhancement and the special circumstances of robbery murder and torture murder. The jury returned a verdict of death, and the trial court denied Defendant's motions for a new trial, for reduced punishment, and to modify the verdict. The Supreme Court struck the gang enhancement and otherwise affirmed, holding (1) there was assumed or either found error regarding certain jury instructions, the failure to bifurcate, and the admission of hearsay and certain evidence, but each assumed or found error was harmless; (2) Defendant's gang enhancement was incorrectly imposed, but this error did not require reversal of the guilty verdicts or death judgment; and (3) there was no other basis for reversing Defendant's convictions or sentence. View "People v. Tran" on Justia Law

The Supreme Court affirmed Defendant's convictions and life sentences for first-degree murder, robbery, kidnapping, carjacking, and drug-related offenses, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant was not entitled to relief on his claims of error during jury selection; (2) the trial judge was neither biased nor prejudiced against Defendant nor his counsel during voir dire; (3) as to Defendant's claims of error during the guilt phase of his trial, he failed to establish that the trial court committed prejudicial error in its evidentiary rulings; (4) the prosecutor did not commit misconduct rendering Defendant's trial fundamentally unfair; and (5) as to the penalty phase issues raised by Defendant, there was no prejudicial error. View "People v. Ramirez" on Justia Law