Justia California Supreme Court Opinion Summaries

The City fired Plaintiff, a bus driver, for allegedly poor job performance. Plaintiff brought this action against the City, alleging she was fired because of her pregnancy in violation of the Fair Employment and Housing Act (FEHA). During trial, the City requested the court to instruct the jury that if it found a mix of discriminatory and legitimate motives, the City could avoid liability by proving that a legitimate motive alone would have led it to make the same decision to fire Plaintiff. The trial court refused the instruction, and the jury returned a verdict for Plaintiff. The court of appeal reversed, concluding that the refusal to give the requested instruction was prejudicial error. The Supreme Court affirmed the court of appeal's judgment overturning the damages verdict in this case and remanded, holding (1) under the FEHA, when a jury finds that unlawful discrimination was a substantial factor motivating a termination of employment, and when the employer proves it would have made the same decision absent such discrimination, a court may not award damages, backpay, or an order of reinstatement; but (2) Plaintiff in this circumstance could still be awarded, where appropriate, declaratory relief or injunctive relief to stop discriminatory practices. View "Harris v. City of Santa Monica" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and first degree robbery. After a penalty trial, the trial court imposed the death sentence for the murder and a prison term for the robbery and enhancements. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not commit reversible error in selecting the jury; (2) the trial court did not commit reversible error in the guilt phase or the penalty phase proceedings; (3) the prosecutor did not engage in impermissible misconduct; and (4) the imposition of the death penalty does not violate the Eighth Amendment. View "People v. Whalen" on Justia Law

After a labor union began picketing on a supermarket's privately owned walkway in front of the store's customer entrance, the supermarket owner sought a court injunction to prevent the picketing. The owner argued that because the union was using the walkway for expressive activity without complying with the supermarket's regulations, the union was trespassing on its property. The trial court denied relief, concluding that the supermarket owner had failed to satisfy Cal. Lab. Code 1138.1's requirements for obtaining an injunction against labor picketing. The court of appeal reversed, holding (1) the walkway was not a public forum, and therefore, the store owner could regulate speech in that area; and (2) both the Moscone Act and section 1138.1 violate free speech and equal protection because they give speech regarding a labor dispute greater protection that speech on other subjects. The Supreme Court reversed and remanded, holding (1) a union's picketing activities in the supermarket's privately owned entrance area do not have state constitutional protection; (2) however, those picketing activities do have statutory protection under the Moscone Act and section 1138.1; and (3) these statutory provisions do not violate the federal constitutional prohibition on content discrimination in speech regulations. View "Ralphs Grocery Co. v. United Food & Commercial Workers Union Local 8" on Justia Law

After a jury trial, Defendant was convicted of the first degree murder of Raymond Shield. In addition, the jury (1) found true the special circumstance allegation that Defendant murdered Shield while in the commission of an attempted robbery, (2) found Defendant guilty of second degree attempted robbery of Shield, and (3) found Defendant guilty of three other second degree robberies of four other victims. Defendant was sentenced to death for the murder and prison terms for the robberies. The Supreme Court affirmed the trial court's judgment in its entirety, holding that the trial court did not commit reversible error in its rulings regarding jury selection, regarding the guilt phase of the trial, and regarding the penalty phase of the trial. View "People v. Watkins" on Justia Law

Plaintiff, a wheelchair user, sued a grocery store owner, contending that a four-inch step located at the entry of the market was an architectural barrier that prevented him and other wheelchair-bound individuals from wheeling into the store and asserting four state and federal law disability access claims. The trial court granted summary judgment for Defendant. The trial court concluded fees for a prevailing defendant under Cal. Civ. Code 55 were mandatory and awarded Defendant $118,458. The court of appeal affirmed. The Supreme Court affirmed, holding that appellate court did not err in determining that Defendant, as the prevailing party, was entitled to costs and, under section 55, to appellate attorney fees as well, as (1) the plain language of section 55 makes an award of fees to any prevailing party mandatory; and (2) the federal Americans with Disabilities Act does not preempt this part of the state's attorney fee scheme for disability access suits. View "Jankey v. Lee" on Justia Law

This case involved the constitutional limits of a vehicle search based on a passenger's parole status. Here, an officer, aware that the front seat passenger was on parole, searched the back seat of Defendant's car and recovered drugs and drug paraphernalia from a chips bag and a pair of shoes. Defendant, the driver, sought to suppress that evidence. Defendant's suppression motion was denied, and Defendant pleaded guilty to four misdemeanor counts. The court of appeal reversed, holding that the search could not be justified on the basis of the front seat passenger's parole status. The Supreme Court reversed, holding that the search was reasonable under the Fourth Amendment where (1) the Constitutional permits a search of those areas of the passenger compartment where the officer reasoanbly expects that the parolee could have stowed personal belongings or discarded items when aware of police activity; and (2) additionally, the officer may search personal property located in those areas if the officer reasonably believes that the parolee owns those items or has the ability to exert control over them. View "People v. Schmitz" on Justia Law

Defendant and five others carried out the September 1985 murders of Vera and Gerald Woodman in California. In a federal prosecution against Defendant, a jury in 1991 convicted him of murder for hire, for which he was sentenced to life imprisonment. Thereafter, Defendant unsuccessfully requested the Los Angeles County Superior Court to dismiss the murder charges then pending against him in this case, asserting that Cal. Penal Code 656's prohibition against double jeopardy precluded the California prosecution because it was founded upon the same act that was the basis of his earlier conviction in federal court. A majority of the California Supreme Court upheld the trial court's rejection of Defendant's claims and affirmed Defendant's capital murder convictions, holding (1) unlike the preceding murder-for-hire federal prosecution, the California murder charges against Defendant included a lying-in-wait special-circumstance allegation, and thus, the California charges against Defendant required proof of conduct that was not required for conviction of the earlier federal charges; and (2) Defendant's remaining allegations of error did not result in prejudice to Defendant. View "People v. Homick" on Justia Law

Petitioner was convicted in 1997 for the murder of his wife. Petitioner subsequently sought habeas corpus relief, stating that his murder conviction was based on false evidence given at trial by the prosecution's dental expert. The dental expert stated that he had testified inaccurately at trial. Other dental experts agreed that the expert had testified inaccurately based on newly available computer technology. After an evidentiary hearing, the superior court granted habeas corpus relief. The court of appeals disagreed. At issue on appeal was whether a conviction is based on "false evidence" when it depends in part on the opinion of an expert witness, and posttrial advances in technology have raised doubts about the expert's trial testimony without conclusively proving that testimony to be untrue. The Supreme Court affirmed, holding (1) in such circumstances the expert's trial testimony was not shown to be "false evidence," but the information garnered from technological advances could be presented as newly discovered evidence in support of habeas corpus relief; and (2) habeas corpus relief should be granted only if the new evidence points unerringly to innocence or reduced culpability, a showing that Petitioner did not make. View "In re Richards" on Justia Law

Defendant was convicted on two counts of possessing a firearm after conviction of a felony in violation of Cal. Penal Code 12021(a)(1) and two counts of possession a firearm after conviction of a specified violent offense in violation of Cal. Penal Code 12021.1(a). All four counts were based on Defendant's simultaneous possession of two firearms. The court of appeal reversed Defendant's section 12021.1(a) convictions, finding that violent offender in possession under section 12021.1(a) was a necessarily included offense of offender in possession under section 12021(a)(1). The Supreme Court reversed, holding (1) Defendant was properly convicted of both offenses because neither section 12021.1(a) nor section 12021(a)(1) is a necessarily included offense of the other; and (2) Defendant may be separately punished for two violations of section 12021(a)(1) and of section 12021.1(a) based on his simultaneous possession of two firearms, but he may not also be separately punished for violations of section 12021(a)(1) and section 12021.1(a) based on possession of the same firearm. Remanded. View "People v. Sanders" on Justia Law

While in Defendant's care, Defendant's young son died of shock and hemorrhage due to blunt force trauma. A jury convicted Defendant of involuntary manslaughter and assault on a child causing death. As relevant here, the court of appeal reversed the conviction upon finding the trial court erroneously failed to instruct the jury, sua sponte, on simple assault as a lesser included offense. The Supreme Court reversed and remanded with directions to reinstate the conviction, holding that the trial court had no sua sponte duty to instruct on that lesser offense, as (1) such instructions are required only when there is substantial evidence that, if the defendant is guilty at all, he is guilty of the lesser offense, but not the greater; and (2) here, it would be speculative at best to construe the trial evidence in this case as supporting a verdict of only simple assault. View "People v. Wyatt" on Justia Law