Justia California Supreme Court Opinion Summaries

On February 10, Donald Smith and Christopher Sims were charged with felony first degree residential burglary. Smith did not waive his statutory right to be brought to trial within sixty days of his arraignment, but the trial date of Sims was continued beyond the sixty-day period for good cause. The trial was set for April 27, which meant that the last day for trial, pursuant to Cal. Penal Code 1382, was May 7. On May 1, Smith sought a writ of mandate in the court of appeal to stay further trial court proceedings against him. The court of appeal directed the superior court to enter an order dismissing the information pending against Smith. The Supreme Court reversed, holding (1) under section 1382, when one codefendant's trial is continued to a date within section 1382's ten-day grace period, the state's strong interests in joinder provide good cause to continue the trial for all properly joined codefendants to the same date within the ten-day period; and (2) therefore, the trial court did not abuse its discretion in continuing Smith's trial to a date within the ten-day period in order to permit Smith and Sims to be joined in a single trial. View "Smith v. Superior Court" on Justia Law

A charter city entered into certain contracts for the construction of public buildings. A federation of labor unions then petitioned the superior court for a peremptory writ of mandate, asserting that the city must comply with California's prevailing wage law notwithstanding local ordinances stating otherwise. The prevailing wage law requires that certain minimum wage levels be paid to contract workers constructing public works. At issue on appeal was whether, under the state constitution, the subject matter of the state's prevailing wage law was a "statewide concern" over which the state has primary legislative authority, or whether the matter was a municipal affair and therefore governed by the charter city's local ordinances. The Supreme Court affirmed the court of appeal, which in turn affirmed the trial court's judgment denying the union's petition for a writ of mandate, holding that there was no statewide concern at issue in this case, and therefore, the state's prevailing wage law did not apply to the charter city. View "State Bldg. & Constr. Trades Council v. City of Vista" on Justia Law

In 1984 a jury convicted Defendant of first degree murder, attempted murder, attempted rape, and burglary. After a penalty trial, the jury set the penalty at death. The Supreme Court affirmed. In 1997, the Ninth Circuit Court of Appeals, while affirming the federal district court's denial of Defendant's petition for writ of habeas corpus as to the guilt phase, reversed its denial of the writ as to the death sentence. After the first retrial of the penalty phase resulted in a mistrial, a second penalty retrial was held, in which the jury returned a verdict of death. The Supreme Court affirmed, holding (1) the second penalty retrial was constitutional; (2) the trial court did not err by excusing prospective jurors; (3) the court did not erroneously admit victim impact evidence and giving related instructions; (4) the court did not err in excluding proffered defense expert opinion testimony or mitigating evidence; (5) there was no prejudicial prosecutorial misconduct; and (6) California's death penalty law and related standard jury instructions were constitutional and lawful. View "People v. McDowell" on Justia Law

Defendant, a convicted felon, carried a loaded and concealed firearm. A jury convicted Defendant of possession of a firearm by a felon, carrying a readily accessible concealed and unregistered firearm, and carrying an unregistered loaded firearm in public. Defendant appealed, arguing that Cal. Penal Code 654, which prohibits multiple punishment for an act that is punishable in different ways by different provisions of law, prohibited multiple punishment for his convictions. The court of appeal modified the judgment to stay execution of the sentence on count three and affirmed the judgment as modified. The Supreme Court reversed, holding that because different provisions of law punish in different ways Defendant's single act, section 654's plain language prohibits punishment for more than one of those crimes. Remanded. View "People v. Jones" on Justia Law

After police found Defendant Victor Correa hiding in a closet with a cache of guns, Defendant was convicted of seven counts of being a felon in possession of a firearm. The court of appeal affirmed. The Supreme Court initially limited review to the question of whether imposing sentence on more than one of these counts violated Cal. Penal Code 654's prohibition against multiple punishment for the same criminal act. The Court then requested supplemental briefing on the question of whether section 654 applies to multiple violations of the same criminal statute. The Supreme Court affirmed, holding (1) by its plain language, section 654 does not bar multiple punishment for multiple violations of the same criminal statute, but this interpretation was not applied to Defendant because the new rule may be applied prospectively only; and (2) even so, Defendant's sentence did not violate section 654 because specific statutory authority makes possession of each weapon a separate offense. View "People v. Correa" on Justia Law

Defendant MBNA America Bank issued a credit card to Plaintiff Allan Parks. As part of its service to cardholders, MBNA extended credit to Plaintiff by sending him convenience checks that did not include disclosures required by Cal. Civ. Code 1748.9. Plaintiff later sued MBNA on behalf of himself and similarly situated MBNA customers, alleging that the bank engaged in unfair competition by failing to make the disclosures mandated by section 1748.9. MBNA argued that the National Bank Act of 1864 (NBA) preempted the state disclosure law. The trial court granted judgment on the pleadings on MBNA's motion, concluding that the bank's failure to attach the statutorily mandated disclosures to its convenience checks was not unlawful. The court of appeal reversed. The Supreme Court reversed the court of appeal, holding that NBA preempts section 1748.9 because the state law standards act as an obstacle to the broad grant of power given by the NBA to national banks to conduct the business of banking. Remanded. View "Parks v. MBNA Am. Bank, N.A." on Justia Law

Penal Code section 4019 has offered prisoners in local custody the opportunity to earn conduct credit against their sentences for good behavior. For eight months during 2010, a now-superseded version of section 4019 that was enacted during a state fiscal emergency temporarily increased the rate at which local prisoners could earn conduct credits. At issue was whether this former statute retroactively benefited prisoners who served time in local custody before January 25, 2010, the date on which it became operative. The court held that former section 4019 applied prospectively, meaning that qualified persons in local custody first became eligible to earn credit for good behavior at the increased rate beginning on the statute's operative date. The court also held that the equal protection clauses of the federal and state constitutions did not require retroactive application. View "People v. Brown" on Justia Law

This case arose when petitioner filed a petition for writ of mandate in the Lassen Superior Court, seeking to require the prison to process four administrative appeals of grievances that he had filed. At issue was whether a court commissioner had the authority to summarily deny a petition for writ of mandamus or habeas corpus under Code of Civil Procedure section 259, subdivision (a), which authorized commissioners to hear and determine ex parte motions for orders and alternative writs and writs of habeas corpus. The court concluded that section 259(a) did grant this authority to commissioners and that, at least when the petition sought to enforce a prisoner's rights while in confinement - but did not seek to collaterally attack the criminal conviction that provided the basis for that confinement - the summary denial of a writ petition constituted a subordinate judicial duty properly undertaken by a commissioner within the meaning of article VI, section 22 of the California Constitution. View "Gomez v. Super. Ct." on Justia Law

A jury convicted defendant of first degree murder and found true the special circumstance allegations of lying in wait and the intentional infliction of torture. At the second penalty retrial, defendant was sentenced to death. On automatic appeal, the court considered jury selection issues; pretrial issues regarding the penalty phase; guilt phase issues; and penalty phase issues. The court rejected nearly all of defendant's claims of error and where it found no error, it determined that defendant was not prejudiced. Accordingly, the court affirmed the judgment. View "People v. Streeter" on Justia Law

Defendant was charged in a felony complaint with attempted first degree burglary of an inhabited dwelling and second degree burglary of an automobile. At issue was whether a person standing in the driveway of a residence who used a remote control to open a motorized garage door had entered the residence within the meaning of the burglary statute. The court held that using a remote control to open a garage door did not constitute an entry into the residence. On these facts, defendant could be charged with attempted burglary but he could not be charged with a completed burglary. View "Magness v. Super. Ct." on Justia Law