Justia California Supreme Court Opinion Summaries

Defendant broadsided at high speed a vehicle driving by Loraine Wong. Wong’s younger daughter, Sydney, was killed, and her older daughter, Kendall, sustained serious injuries. A jury convicted Defendant of vehicular manslaughter with gross negligence and found true the allegation that he personally inflicted great bodily injury on Kendall. At issue on appeal was whether the trial court violated Defendant’s Fifth Amendment privilege against self-incrimination by admitting evidence that Defendant, following his arrest but before receipt of Miranda warnings, failed to inquire about the other people involved in the collision. The court of appeal reversed, holding that the trial court violated the Fifth Amendment privilege against self-crimination by admitting evidence of Defendant’s post-arrest, pre-Miranda failure to inquire about the welfare of the occupants of the other vehicle. The Supreme Court reversed, holding that Defendant needed to make a timely and unambiguous assertion of his Fifth Amendment privilege against self-incrimination in order to benefit from it. Remanded. View "People v. Tom" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and kidnapping with the purpose to commit a lewd act on a child under fourteen years old. The jury found true the special circumstance allegation of kidnapping murder and returned a verdict of death. The trial court sentenced Defendant to death on the murder count. The Supreme Court affirmed, holding (1) any error in the trial court’s rulings during the pretrial stage of the proceedings did not influence the verdict; (2) no prejudicial error occurred during the guilt phase; (3) the trial court did not abuse its discretion excluding certain statements from the penalty phase; and (4) Defendant’s challenges to California’s death penalty were without merit. View "People v. McCurdy" on Justia Law

After a jury trial in 1998 Defendant was convicted of two counts of first degree murder and one count of attempted murder, among other crimes. The jury found true the allegation that the attempted murder was committed willfully, deliberately and with premeditation. After a penalty phase retrial, the trial court imposed a sentence of death. The Supreme Court reduced the conviction of willful, deliberate, and premeditated attempted murder to attempted murder and, in all other respects, affirmed the judgment, holding (1) the trial court did not err in overruling Defendant’s objection to the prosecutor’s use of peremptory challenges against three black prospective jurors; (2) the jury was not properly instructed on the meaning of the terms “willful,” “deliberate,” and “premeditated,” and therefore, a reduction of Defendant’s conviction on count two to a conviction for regular attempted murder was warranted; (3) the trial court did not commit prejudicial error in its evidentiary rulings; (4) Defendant failed to establish that his attorney rendered ineffective assistance or that he was denied his right to a fair trial before an unbiased judge; and (5) during the penalty phase, the trial court erred by excluding evidence of institutional failure, evidence regarding Defendant’s antisocial personality disorder, and evidence about lingering doubt, but the errors were harmless. View "People v. Banks" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and arson of property. The jury found true the special circumstance that Defendant was previously convicted of first degree murder. The trial court imposed the death sentence for the murder. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not err in granting the prosecution's challenge for cause against a prospective juror; (2) the trial court did not err in admitting evidence of two uncharged murders; (3) the jury was properly instructed regarding flight; (4) the prior-murder-conviction special circumstance was valid; (5) the trial court did not err in its penalty phase rulings; and (6) Defendant's challenges to California's death penalty failed. View "People v. Rogers" on Justia Law

Petitioner was charged in a misdemeanor complaint electronically generated by a superior court clerk with willfully violating her written promise to appear. Petitioner pled no contest to the conviction. Petitioner subsequently challenged the conviction, contending that the complaint was void because it was not issued by an executive branch officer with prosecutorial authority in violation of the California Constitution’s separation of powers and due process clauses. The Supreme Court denied Petitioner’s petition for writ of mandate, holding the because the relevant prosecutorial agency has, through an established practice, implicitly approved in advance the clerk’s routine issuance of complaints for the offense of failure to appear, the practice is constitutional, and therefore, the complaint in this case is valid. View "Steen v. Appellate Div., Superior Court" on Justia Law

Defendant was charged with sale and possession for sale of a controlled substance. At trial, evidence showed that the pills contained 3,4-methylenedioxymethamphetamine (MDMA). The court of appeal affirmed, holding that although there was not a stipulation or expert testimony showing that MDMA met the definition of a controlled substance or controlled substance analog within the Health and Safety Code, the name supported the inference that the pills contained some quantity of methamphetamine or amphetamine. The Supreme Court reversed, holding that evidence of MDMA's chemical name, standing alone, was insufficient to prove the material is a controlled substance where MDMA is not listed in the Code.View " People v. Davis" on Justia Law

Defendant was charged with committing four lewd acts upon his niece. Before trial, the prosecution offered evidence under Cal. R. Evid. 1108 that Defendant had sexually abused his sister when Defendant was nearly fourteen. Defendant opposed the prosecutor's motion, arguing that the evidence should be excluded because, as a minor under the age of fourteen, he was presumed incapable of committing a crime. The court allowed the evidence. During trial, the trial court did not give an instruction directing the jury to assess Defendant's capacity to commit the offense admitted under section 1108 under Cal. Penal Code 26(1). The jury convicted Defendant on all counts. The court of appeal reversed, holding that the trial court erred by not sua sponte instructing the jury that the prosecution must prove by clear and convincing evidence that Defendant appreciated the wrongfulness of his conduct admitted under section 1108. The Supreme Court reversed, holding (1) proof was required that Defendant knew the conduct at issue was wrongful and was thus capable of committing a crime; and (2) the trial court was not required to sua sponte instruct the jury to consider Defendant's age at the time of his act admitted under section 1108. Remanded. View "People v. Cottone" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. After the penalty phase, the trial court declared a mistrial because the jury was unable to reach a penalty verdict. After a second penalty phase, the jury returned a verdict of death. The Supreme Court reversed the death sentence due to prejudicial juror misconduct and affirmed in all other respects, holding (1) the trial court did not commit prejudicial error during the guilt phase; but (2) there was a substantial likelihood that one juror was influenced or biased against Defendant by an improper conversation he had with his pastor during penalty deliberations and that the juror’s vote to impose the death penalty was not based solely on the evidence and instructions. Remanded for retrial of the penalty phase and resentencing on all counts. View "People v. Hensley" on Justia Law

Defendant, while acting as manager for a motorcycle dealership, arranged for the fraudulent sale of twenty vehicles to fictitious buyers. After a jury trial, Defendant was convicted of twenty counts of grand theft, one count for each of the vehicles fraudulently sold. On appeal, Defendant argued that he could be convicted of one count of grand theft only because all of the sales were part of a single scheme. The court of appeal affirmed the judgment of conviction for the twenty counts of grand theft. At issue before the Supreme Court was the correct interpretation of the language in People v. Bailey, which some courts of appeal have interpreted as permitting only one conviction of grand theft in circumstances such as those presented in this case. The Supreme Court reversed, holding (1) a defendant may be convicted of multiple counts of grand theft based on separate and distinct acts of theft, even if committed pursuant to a single overarching scheme; but (2) the Court cannot not retroactively apply this new rule to Defendant, and therefore, under the law that has existed for decades, Defendant could only have been convicted of a single count of grand theft. View "People v. Whitmer" on Justia Law

During the course of one evening, Defendant and another man burglarized two businesses, robbing several people inside, and killing off-duty peace officer Shayne York. After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a peace officer in retaliation for the performance of his duties and of murder during the commission of robbery and burglary. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed Defendant’s convictions, holding (1) the trial court did not err in its evidentiary rulings or in instructing the jury during the guilt phase; (2) sufficient evidence supported the finding that Defendant intentionally killed York in retaliation for the lawful performance of his duties, and the special circumstance allegation was constitutional; (3) Defendant’s challenges to the robbery-murder and burglary-murder special circumstances were unavailing; (4) Defendant’s Sixth Amendment right to self-representation was not violated at the penalty phase; (5) any error in the instructions during the penalty phase was harmless; and (6) Defendant’s death sentence was proportional and constitutional. View "People v. Boyce" on Justia Law