Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant, who spoke Spanish, was convicted of first degree murder. At issue on appeal was whether, while Defendant was in custody and after a law enforcement officer read Defendant his Miranda rights, Defendant's response to whether a detective could speak to Defendant was sufficiently ambiguous to justify the officer in seeking to clarify whether Defendant was attempting to invoke his right to counsel, or whether he was desirous of waiving his Miranda rights and speaking with the detective without an attorney present. The trial court concluded that Defendant's waiver of Miranda rights was voluntary, knowing and intelligent. The court of appeals reversed. The Supreme Court reversed, holding (1) Defendant's reply to the officer's inquiry was sufficiently ambiguous to justify her seeking further clarification of his intent, consistent with the Court's holding in People v. Williams; (2) Defendant's responses made clear he was willing to speak with the detective at that time without an attorney present; and (3) therefore, under the totality of the circumstances, Defendant's waiver of Miranda rights, including his right to counsel, was voluntary, knowing, and intelligent. View "P. v. Sauceda-Contreras" on Justia Law

A jury convicted Defendant Richard Valdez of five counts of first degree murder. As to each count, the jury found true special circumstance allegations of multiple murder and gang and weapon enhancement allegations. The evidence presented at trial established that Defendant was a member of the Sangra street gang. The jury returned a verdict of death as to each of the victims. The trial court denied the automatic application to modify the verdict and sentenced Defendant to death for the five murders. The Supreme Court affirmed, holding, among other things, that Defendant's claims alleging numerous errors in connection with protective orders the trial court issued delaying and limiting disclosure of the identities of certain prosecution witnesses failed, and that the trial judge did not prejudicially err in refusing to declare a mistrial after the jurors declared they were at an impasse and could not reach a unanimous verdict on any count. View "People v. Valdez" on Justia Law

Defendant, an ex-felon on probation, planted an object near a government building that resembled a bomb and that caused fear and disruption when discovered. Defendant was convicted of violating Cal. Penal Code 148.1(d), which allows misdemeanor or felony punishment for anyone who maliciously places a false bomb with the intent to cause another person to fear for his own safety or the safety of others. Defendant's sentence included a twenty-five-years-to-life three strikes term based on the section 148.1(d) felony count and his prior serious and violent felony convictions. The court of appeal reduced the section 148.1(d) conviction to a misdemeanor, finding that the felony provision under which Defendant was convicted and sentenced denied him equal protection of the law when compared to an entirely different statute, Cal. Penal Code 11418.1, which provides that anyone who places a WMD with the intent to cause fear in others can be convicted of a felony only if the perpetrator's conduct causes another person to be placed in sustained fear, an element not necessary under the false bomb statute. The Supreme Court reversed, holding that no equal protection violation occurred, as the challenged distinction was not irrational. View "People v. Turnage" on Justia Law

The Minor in this case was the subject of several delinquency petitions. Minor was eventually placed in foster care. Minor appealed, arguing the dispositional order placing him in foster care had to be reversed because the juvenile court had failed to comply with the notice requirements of the Indian Child Welfare Act (INCA). The court of appeals affirmed, holding notice was not required because federal law specifically excludes delinquency cases from ICWA, and any interpretation of California law that would expand ICWA's application to delinquencies would be invalid under federal preemption principles. The Supreme Court affirmed, holding (1) California law requires the court to inquire about a child's Indian status at the outset of all juvenile proceedings, but ICWA's additional procedures are not required in most delinquency cases; (2) a delinquency court must ensure that notice is given and other ICWA procedures are complied with only under certain circumstances; and (3) assuming Minor was an Indian child, the juvenile court did not err in failing to give notice under ICWA in this case. View "People v. W.B." on Justia Law

A jury convicted Defendant of the first degree murder of a Los Angeles County sheriff's deputy. The jury found true the special circumstance allegations that Defendant committed the murder to avoid a lawful arrest and that he knew or should have known that the victim was a peace officer performing his duties. The jury also found that Defendant was armed with and personally used a firearm during the offense. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment after examining (1) pretrial and guilt phase issues, (2) penalty phase issues, and (3) challenges to the death penalty law, holding that the trial court correctly convicted and sentenced Defendant. View "People v. Duenas" on Justia Law

A jury convicted Defendant of first degree murder and found true the robbery-murder and burglary-murder special circumstance allegations. The jury also convicted Defendant of first degree robbery, first degree burglary, and kidnapping for robbery, finding as to these counts that the victim was sixty-five years or older. The jury additionally convicted Defendant of two counts of second degree burglary. The trial court imposed a sentence of death for the murder. With respect to the remaining counts, the trial court imposed, among other things, the upper term of nine years for carjacking plus one year for the elderly victim enhancement. The Supreme Court affirmed the death judgment as modified, concluding that the judgment should be modified to stay the sentence on the carjacking count, as Defendant could not be punished for both carjacking and kidnapping for robbery because the prosecutor argued to the jury that the victim's car was the object of the robbery. View "People v. McKinzie" on Justia Law

A jury convicted Defendant of the first degree murders of four persons and found true a multiple-murder special-circumstance allegation. The jury also convicted Defendant of the attempted murders of ten other persons and found true allegations that the attempted murders were willful, deliberate, and premeditated; that Defendant personally used a firearm in committing the murders and attempted murders; and that, except as to one person, Defendant personally inflicted great bodily injury in committing the attempted murders. The jury further convicted Defendant of assault with a firearm on three individuals and false imprisonment for the purpose of protection from arrest. After a sanity trial, the jury found Defendant to be sane. After a penalty phase, the jury returned a verdict of death. The trial court sentenced Defendant to death on the murder counts, life imprisonment on the attempted murder counts, and a determinate sentence on the remaining counts and enhancements. The Supreme Court affirmed the judgment of the district court, holding that the court did not err in its judgment. View "People v. Houston" on Justia Law

Defendant Ivan Joe Gonzales was convicted of murdering four-year-old Genny Rojas. The jury found as a special circumstances that the murder was intentional and involved the infliction of torture. However, it was unable to reach a penalty verdict. Another jury was impaneled, and the second penalty phase trial resulted in a death verdict. After analyzing several aspects of the conviction of and sentence, including (1) guilt phase issues, and (2) penalty phase issues, the Supreme Court affirmed the judgment of the trial court, holding that the court did not err in its judgment. View "People v. Gonzales " on Justia Law

After a jury trial, Defendant was convicted of various counts of kidnapping, robbery, and rape against five women. During the trial, the trial court modified pattern jury instruction CALCRIM No. 1191, which explains to a jury that it may consider a defendant's uncharged sexual offense as evidence of his or her propensity to commit a charged sexual offense, to permit to the jury to consider the defendant's charged sexual offenses as evidence of his propensity to commit the other charged sexual offenses. On appeal, Defendant challenged a modified pattern jury instruction based on People v. Quintanilla, which held that charged offenses could not be considered as propensity evidence under a similar provision and its corresponding jury instruction. The court of appeal rejected Defendant's challenges to the modified instruction. The Supreme Court affirmed, holding that under the facts of this case, the trial court did not err in giving the modified instruction. View "People v. Villatoro" on Justia Law

An amended information charged Defendant Richard Tully with the 1986 murder of Shirley Olsson and assault with intent to commit rape. The information also alleged a special circumstance that the murder was committed in the commission of a burglary and, as to both counts, that Defendant used a dangerous and deadly weapon: a knife. A jury convicted Defendant as charged and found true the special circumstance and weapon allegations. It then returned a verdict of death, which the trial court declined to modify. The Supreme Court affirmed the trial court's judgment in its entirety, holding, among other things, that California's death penalty statute was constitutional. View "People v. Tully" on Justia Law