Justia California Supreme Court Opinion Summaries

At issue in this criminal case was whether the prosecution’s obligation under Brady v. Maryland and its progeny would be satisfied if it simply informs the defense that the confidential personnel records of police officers might contain Brady material, which would allow the defense to decide for itself whether to seek discovery of that material pursuant to statutory procedures. The superior court denied the prosecution’s motion asking the court to review in camera the personnel records of two San Francisco police officers, potentially important witnesses in this criminal case, to determine whether they contained any material exculpatory information under Brady v. Maryland that was subject to disclosure. The Court of Appeal concluded that the prosecution may and, before the court becomes involved, should itself review the personnel files of peace officer witnesses for Brady material. The Supreme Court reversed, holding (1) the prosecution must follow the same procedures that apply to criminal defendants, i.e., make a Pitchess motion, in order to seek information in the confidential personnel records of police officers who are potential witnesses in criminal cases; and (2) the prosecution fulfills its Brady duty if it informs the defense of what the police department informed it, namely, that the specified records might contain exculpatory information. View "People v. Superior Court" on Justia Law

After a bench trial, Defendant was convicted of the first degree murders of three victims. A jury was sworn for the penalty phase and returned a verdict of death. The trial court sentenced Defendant to death for the three first degree murders with special circumstances. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no abuse of discretion in the use of physical restraints during Defendant’s transit through the hallways of the courthouse; (2) the trial court did not violate Defendant’s rights to due process and a fair trial when it excluded him from numerous pretrial proceedings and the guilt phase of his trial; (3) Defendant’s waiver of a guilt phase jury was knowing, intelligent, and voluntary; (4) Defense counsel provided effective assistance; (5) the trial court did not err in its evidentiary rulings; (6) there was no prejudicial error committed during jury selection; (7) the trial court did not err in denying Defendant’s automatic application for modification of the death verdict; (8) Defendant’s sentence was not disproportionate; and (9) Defendant’s challenges to the constitutionality of California’s death penalty scheme failed. View "People v. Cunningham" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder, sixteen counts of robbery, and three counts of assault with a deadly weapon, and related charges. The jury sentenced Defendant to death. Defendant appealed, arguing, among other things, that the trial court improperly excluded three prospective jurors based on their death penalty views. The Supreme Court (1) reversed the judgment of death and remanded the matter for a new penalty determination, holding that written and oral voir dire responses of the three excused panelists did not give the trial court sufficient information to conclude that they were incapable of performing their duties as capital jurors, and therefore, the record did not support the jurors’ dismissals; and (2) affirmed the judgment in all other respects. View "People v. Leon" on Justia Law

Defendant was convicted of three first degree murders and of conspiracy to participate in a criminal street gang and to commit murder and assault with a deadly weapon. The jury found true several enhancements. Defendant was sentenced to 100 years to life in prison. Before trial, Defendant moved to exclude his admissions of gang membership during booking and classification interviews at a county jail, asserting a Miranda violation. The trial court held that Defendant’s statements about his gang membership were admissible under Miranda’s booking exception. The Supreme Court affirmed, holding (1) the questions posed to Defendant while he was being processed into jail exceeded the scope of the booking exception, and while the officers were permitted to ask these questions for institutional security purposes, Defendant’s un-Mirandized responses were inadmissible against him during the case-in-chief; but (2) the erroneous admission of Defendant’s challenged statements was harmless beyond a reasonable doubt because Defendant’s gang affiliation was amply established by independent and uncontradicted evidence. View "People v. Elizalde" on Justia Law

After a jury trial in 1989, David Welch was found guilty of six counts of first degree murder and two counts of attempted murder. The trial court sentenced Welch to death. The Supreme Court affirmed on appeal. Welch later filed a habeas corpus petition, alleging, among other claims, juror misconduct and ineffective assistance of counsel at the penalty phase. The Supreme Court issued to the Director of the Department of Corrections an order to show cause why it should not grant Welch relief on his jury misconduct and ineffective assistance of counsel claims. An appointed referee conducted an evidentiary reference hearing and filed a report with recommendations. The Supreme Court then discharged the order to show cause, holding that Defendant failed to establish that he was entitled to habeas corpus relief on his claims of juror misconduct and ineffective assistance of trial counsel for not investigating and presenting certain mitigating evidence at the penalty phase of his capital trial. View "In re Welch" on Justia Law

In 2010, the City of San Jose enacted an inclusionary housing ordinance that requires all new residential development projects of twenty or more units to sell at least fifteen percent of the for-sale units at a price affordable to low or moderate income households. California Building Industry Association (CBIA) filed this lawsuit, arguing that the San Jose ordinance was invalid on its face because the conditions imposed by the ordinance constituted “exactions” under the takings clauses of the state and federal Constitutions. The superior court agreed with CBIA and enjoined the City from enforcing the ordinance. The Court of Appeal reversed, concluding that the superior court erred in interpreting the controlling constitutional principles and the decision in San Remo Hotel v. City and County of San Francisco as limiting the conditions that may be imposed by such an ordinance to only those conditions that are reasonably related to the adverse impact the development projects that are subject to the ordinance themselves impose on the City’s affordable housing problem. The Supreme Court affirmed, holding that the conditions that the San Jose ordinance imposes on future developments do not impose “exactions” upon the developers’ property. View "Cal. Bldg. Indus. Ass’n v. City of San Jose" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, rape, and sodomy. Defendant also pleaded guilty to charges arising from separate burglaries committed after the charged murder. The trial court sentenced him to death. Defendant appealed, arguing, among other things, that the prosecutor violated Batson v. Kentucky and People v. Wheeler by peremptorily excusing two African American prospective jurors. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court correctly concluded that Defendant failed to make out a prima facie case of discrimination as to either strike; (2) the trial court did not abuse its discretion in denying Defendant’s pretrial motion to sever the homicide charges from the burglary charges; and (3) any remaining errors or assumed errors were not prejudicial. View "People v. Scott" on Justia Law

After a jury trial in 1999, Defendant was convicted of first degree murder, second degree murder, and second degree robbery. Defendant stipulated to a 1971 prior second degree murder conviction alleged as a special circumstance. As to both murder counts, the jury found true the special-circumstance allegation of multiple murder. The trial court imposed a sentence of death that was supported by the multiple murder special-circumstance finding. The Supreme Court reversed the judgment of conviction for second degree murder and reversed the penalty judgment, holding (1) Defendant’s 1971 second degree murder conviction was obtained in violation of the double jeopardy clause, and therefore, this special-circumstance finding must be set aside; (2) the trial court erred by allowing the prosecution to refile the second degree murder charge, which had previously been dismissed; (3) the multiple murder special circumstance is vacated because it was based in part on the invalid second degree murder conviction; and (4) therefore, the judgment of death must be reversed. Remanded for resentencing. View "People v. Trujeque" on Justia Law

After a jury trial, Defendant was convicted of the first degree murders of Mary Kopatz and Carley Kopatz. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress evidence of his videotaped interview with the police; (2) the trial court did not err in admitting a deceased witness’s prior consistent statement; (3) the victim impact evidence was neither unduly prejudicial nor so inflammatory that it invited the jury to make its penalty determination on a purely irrational basis; (4) Defendant was not prejudiced by a multiple-murder special-circumstance instruction and attendant verdict forms; and (5) Defendant’s challenges to the death penalty law failed. View "People v. Kopatz" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, with the special circumstance of torture, false imprisonment by violence, and conspiracy to commit murder. The jury recommended a sentence of death, and the trial court imposed that sentence. The Supreme Court affirmed the convictions but reversed the penalty judgment, holding that, during the penalty phase, the court violated Defendant’s federal constitutional rights to due process by excluding expert testimony about prison security measures for those sentenced to life without possibility of parole because Defendant was deprived of the opportunity to counter aggravating evidence and argument suggesting that he would be a dangerous life prisoner. View "People v. Smith" on Justia Law