Justia California Supreme Court Opinion Summaries

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

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