Justia California Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court affirming the findings of the Commission on State Mandates rejecting the claims brought by Plaintiffs, several community college districts seeking reimbursement for regulations they must satisfy to avoid the possibility of having their state aid withheld, holding that the court of appeals erred.Plaintiffs filed a claim arguing that reimbursement was required under Cal. Const. art. XIII B because (1) the regulations imposed a legal duty to satisfy the conditions described (legal compulsion), or (2) the regulations compelled compliance as a practical matter (practical compulsion). The Commission rejected the claims, and the trial court affirmed. The court of appeals reversed. The Supreme Court reversed, holding that because the court of appeal chose not to address whether the districts established practical compulsion, remand was required to allow the court to evaluate that issue. View "Coast Community College District v. Commission on State Mandates" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeal in this dispute , holding that Oakland did not show on demurrer that its challenged fees at issue in this case were exempt from the voter approval requirements set forth in article XIII C of the California Constitution.In 2012, the City of Oakland approved two contract granting private waste haulers the right to operate a public utility for waste collection services. As consideration for the "special franchise right," the waste haulers agreed to pay certain fees to Oakland. In question was how such fees should be treated under article XIII C, which sets forth voter approval requirements that apply to taxes imposed by local government. The court of appeals concluded that the fees were not exempt from the requirements of section XIII C. The Supreme Court affirmed, holding that Oakland failed to show, as a matter of law, that article XIII C applied to the franchise fees at issue in this case. View "Zolly v. City of Oakland" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, attempted murder, and conspiracy to commit murder and sentencing Defendant to death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the trial court properly excluded two prospective jurors for cause; (2) the "substantial impairment" standard used for determining jury bias in capital cases did not violate Defendant's Sixth Amendment right to an impartial jury; (3) there was no constitutional violation in the denial of Defendant's motion to dismiss the charges against him; (4) there was no error in the court's evidentiary rulings; (5) the trial court erred by failing to provide the jury with a cautionary instructions defining confessions, but the error was harmless; (6) Defendant did not demonstrate any basis for the Court to find error in California's death penalty laws; and (7) a limited remand was appropriate for the sole purpose of allowing the trial court to consider whether to exercise its discretion to strike the prior serious felony enhancement and the firearm enhancements. View "People v. Mataele" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of two murders and finding true the special circumstances that one murder occurred during the commission of a robbery, that the other murder involved the killing of a witness and that Defendant had been convicted of multiple murders, and sentencing Defendant to death, holding that no errors required reversal of the judgment.Specifically, the Supreme Court held (1) substantial evidence supported the excusal of juror J.W. for cause; (2) assuming that the trial court erred when it allowed the prosecution to introduce "other acts" evidence at the guilt phase of trial, any error was harmless; (3) assuming that the trial court erred in introducing evidence at the penalty phase regarding Defendant's participation in mutual combat was harmless; and (4) there was no cumulative error requiring reversal of the judgment below. View "People v. Pineda" on Justia Law

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The Supreme Court affirmed the order of the trial court entering judgment upon the jury's verdict that Defendant committed first degree murder, robbery, burglary, and firearm possession by a felon and sentencing him to death, holding that while the court committed statutory error, there were no additional errors or rulings that caused Defendant undue prejudice.On appeal, Defendant asserted that several errors in the guilt and penalty phases occurred, resulting in cumulative prejudice warranting reversal of his convictions. The Supreme Court disagreed and affirmed, holding (1) the trial court erred by allowing Defendant to be absent from trial without a written waiver, but the error was not prejudicial; and (2) Defendant failed to identify any other reversible error on appeal. View "People v. Poore" on Justia Law

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The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of first degree murder and the jury's findings of the lying-in-wait special circumstance and the special circumstance allegations that Defendant intentionally killed the victim for financial gain while engaged in the commission or attempted commission of rape, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion by failing to initiate competency proceedings; (2) there was no error in the trial court's evidentiary rulings; (3) sufficient evidence supported the jury's true findings of the special circumstances, and the special circumstances, as applied, are not unconstitutional; (4) there was no instructional error; (5) Defendant's claims of prosecutorial misconduct were without merit; and (6) Defendant's remaining claims of error were unavailing. View "People v. Parker" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of the first-degree murder of his father and the second-degree murders of his stepmother and stepsister and sentencing him to death, holding that Defendant's second-degree murder convictions must be reversed.A federal court vacated Defendant's initial conviction and sentence. After a retrial, Defendant was convicted of first- and second-degree murder, and the jury found true a multiple-murder special-circumstance finding and various firearm- and weapon-use findings. Defendant was sentenced to death. At trial, Defendant's counsel conceded his responsibility for the deaths of all three victims, but Defendant was willing to accept responsibility only for the killing of his father and objected to admitting responsibility for the other two deaths. The Supreme Court held (1) defense counsel violated Defendant's Sixth Amendment rights to choose the fundamental objectives of his defense; and (2) while the error did not affect Defendant's first-degree murder conviction or the associated firearm-use finding, the error requires reversal of the remainder of the judgment and the judgment of death. View "People v. Bloom" on Justia Law

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The Supreme Court affirmed the judgment of the the trial court convicting defendants Karl Holmes, Herbert McClain, and Lorenzo Newborn of three counts of murder, five counts of attempted murder, and one count of conspiracy to commit murder and sentencing each defendant to death, holding that no prejudicial error occurred at either stage of the proceedings.After the jury failed to reach a penalty verdict, a new penalty phase was held, and death verdicts were returned against all defendants. On appeal, Defendants asserted several allegations of error argued that the cumulative prejudicial errors in both the guilt and penalty phases of the trials required the reversal of their convictions and sentences. The Supreme Court affirmed, holding (1) in the few instances in which this Court found or assumed error, no prejudice resulted; and (2) whether the claims are considered separately or cumulatively, no prejudicial error occurred. View "People v. Holmes" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first degree murder and other crimes and Defendant's death sentence, holding that any found or assumed errors were individually harmless and that there was no cumulation of error that merited reversal.Specifically, the Supreme Court found or assumed errors in the admission of prior crimes evidence, a prosecutorial misconduct claim concerning a jury argument that Defendant signed a parole form advising him of a possible life sentence, a claim that the defense was prevented from responding to the prosecutor's argument, a claim that certain expert testimony usurped the trial court's role to instruct the jury about the law, and four additional prosecutorial misconduct claims. The Court held (1) any assumed or actual error in each of these claims was individually harmless; and (2) there was no cumulative error warranting reversal. View "People v. Johnson" on Justia Law

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The Supreme Court held that the Department of Corrections and Rehabilitation acted within the authority provided by Cal. Const. art. I, 32(b) when it adopted regulations prohibiting early parole consideration under the scheme set forth in Proposition 57, The Public Safety and Rehabilitation Act of 2016, for inmates "currently serving a term of incarceration for a 'violent felony.'"After Petitioner was convicted of nine violent felony counts and six nonviolent felony counts voters approved Proposition 57. The Department subsequently adopted regulations implementing early parole considerations, including the regulations at issue here. Consistent with these regulations, the Department determined that Petitioner was ineligible for nonviolent offender early parole consideration because he was serving a term of incarceration for a violent felony. The court of appeal granted relief, concluding that the language of article I, section 32(a) requires early parole consideration for any inmate convicted of a nonviolent felony even when that inmate was also convicted of a violent felony. The Supreme Court reversed, holding that the Department acted within its authority provided by article I, section 32(b) when it adopted the regulation at issue. View "In re Mohammad" on Justia Law