Justia California Supreme Court Opinion Summaries

In 2009, a defendant was sentenced to an indeterminate term of 28 years to life under California’s original Three Strikes law after his third felony conviction, which was not classified as serious or violent. He also received three one-year enhancements for prior prison terms. In 2012, California voters passed the Three Strikes Reform Act (Proposition 36), which limited indeterminate life sentences to cases where the third strike was serious or violent, and allowed those serving indeterminate sentences for nonserious, nonviolent felonies to petition for resentencing, subject to a discretionary public safety determination by the court.After the Reform Act, the defendant petitioned for resentencing under section 1170.126, but the Santa Barbara County Superior Court denied the petition, finding his release would pose an unreasonable risk to public safety. The California Court of Appeal affirmed this decision. In 2021, the Legislature enacted Senate Bill No. 483, which retroactively invalidated certain prior prison term enhancements and required courts to recall and resentence affected defendants, applying any changes in law that reduce sentences. The defendant sought resentencing under this new law, and the trial court resentenced him to a determinate eight-year term. The Santa Barbara District Attorney challenged this, arguing that the new law unconstitutionally amended the voter-enacted Reform Act by bypassing its public safety requirement. The Court of Appeal agreed and reversed the trial court’s decision.The Supreme Court of California reviewed whether Penal Code section 1172.75, as applied, unconstitutionally amended the Reform Act. The Court held that section 1172.75 must be interpreted to incorporate the Reform Act’s discretionary public safety determination for nonserious, nonviolent third strike offenders seeking resentencing. This interpretation harmonizes the statutes and avoids constitutional conflict, allowing the revised penalty provisions to apply only if the court finds resentencing does not pose an unreasonable risk to public safety. The Court reversed the Court of Appeal and remanded for further proceedings consistent with this holding. View "P. v. Guevara" on Justia Law

The case involved a defendant who was convicted by a jury of first-degree murder and two counts of attempted murder, all arising from a gang-related shooting in Visalia, California. The prosecution presented evidence that the defendant was a member of the North Side Visalia gang and that he shot individuals he believed to be rival gang members, resulting in one death and serious injury to another. The prosecution’s case relied heavily on expert testimony to establish the defendant’s gang membership and the gang-related nature of the crimes, as well as evidence of prior offenses by the defendant and other gang members. The defense argued that the shooting was not premeditated or gang-motivated, but rather stemmed from a personal dispute, and presented evidence that the defendant had renounced gang affiliation.The Tulare County Superior Court denied the defendant’s pretrial motion to recuse the entire District Attorney’s Office after his former defense attorney joined that office, finding that an effective ethical wall had been established. At trial, the jury found the defendant guilty on all counts, found true the gang enhancements and the gang-murder special circumstance, and returned a death verdict. The trial court entered judgment accordingly.On automatic appeal, the Supreme Court of California reviewed the case. The court held that, due to subsequent legal developments—specifically, its decision in People v. Sanchez and legislative amendments to Penal Code section 186.22 by Assembly Bill 333—the evidence was insufficient to support the gang enhancements and the gang-murder special circumstance. As a result, the court reversed the gang-related findings and the death judgment. The court also ordered a limited remand to allow the defendant to further develop his claim that his trial counsel violated his Sixth Amendment right of autonomy over the defense, as articulated in McCoy v. Louisiana. The convictions and death judgment were reversed and the case remanded for further proceedings. View "P. v. Cardenas" on Justia Law

A group of family members was attacked after being mistaken for rival gang members by individuals associated with the Dragon Family/Dragon Family Junior gang in Orange County. After being followed from a restaurant, their car was cornered in a cul-de-sac, and a shooter fired multiple shots into the vehicle, killing a 13-year-old and injuring two others. Several gang members were apprehended soon after, while the defendant was arrested months later in Arizona. At trial, accomplice testimony, forensic evidence, and writings attributed to the defendant were presented to establish his identity as the shooter and his gang affiliation.The Orange County Superior Court jury convicted the defendant of murder, two counts of attempted murder, and active participation in a criminal street gang, with various firearm and gang-related enhancements. The jury found true a special circumstance that the murder was committed to further gang activities and returned a death verdict. The trial court denied the defendant’s motion to modify the verdict. The defendant raised several claims on appeal, including challenges to jury selection under Batson and Wheeler, the sufficiency of accomplice corroboration, the handling of third-party culpability evidence, the admission of creative writings, the denial of a continuance, and alleged prosecutorial misconduct.The Supreme Court of California reviewed the case. It held that retroactive changes to the law under Assembly Bill 333, which heightened the requirements for proving a “pattern of criminal gang activity,” applied to the defendant’s case. The Court found that the jury had not been instructed under the new, stricter standard, and the Attorney General conceded this error was prejudicial. As a result, the conviction for active gang participation, all gang enhancements, and the gang-murder special circumstance were reversed, requiring reversal of the death judgment. The Court otherwise affirmed the judgment, finding no merit in the defendant’s other claims. The case was remanded for further proceedings. View "P. v. Aguirre" on Justia Law

Two defendants, both members of a criminal street gang, were involved in a shooting incident outside a liquor store in Hemet, California, in December 2020. They were convicted by a jury of attempted murder, active participation in a criminal street gang, unlawful possession of a firearm, assault with a semiautomatic firearm, and willful discharge of a firearm at an occupied vehicle. The jury also found true several gang and firearm enhancements. In a subsequent bench trial, the court found that both defendants had prior 2015 convictions for unlawful possession of a firearm with a gang enhancement, and one defendant had an additional prior conviction for attempted burglary. These prior convictions were used to impose enhanced sentences under California’s Three Strikes law and the five-year prior serious felony enhancement.On appeal, after the passage of Assembly Bill 333, which narrowed the definitions and requirements for gang enhancements under Penal Code section 186.22, the Attorney General conceded that the new law applied retroactively to nonfinal judgments. The California Court of Appeal reversed the convictions and enhancements related to gang participation and remanded for possible retrial under the new standards. However, the Court of Appeal held that Assembly Bill 333 did not apply to the determination of whether the defendants’ 2015 convictions qualified as prior serious felonies or strikes, reasoning that such application would improperly amend voter-approved initiatives that set the list of serious felonies as of a specific date.The Supreme Court of California reviewed the case and held that Assembly Bill 333 does apply to the determination of whether a prior conviction qualifies as a serious felony under section 1192.7(c)(28) for purposes of the Three Strikes law and prior serious felony enhancements. The Court concluded that current law governs this determination, and that such application does not unconstitutionally amend any ballot initiative. The Court vacated the true findings on the prior serious felony convictions and remanded for retrial under the amended law. View "P. v. Fletcher" on Justia Law

The case concerns a defendant who was convicted by a jury of the first degree murders of two young children, Tyler and Dylan, as well as assaulting Dylan, a child under eight, with force likely to produce great bodily injury resulting in death. The defendant was in romantic relationships with each child’s mother and lived with them at the time of the children’s deaths. Both children suffered extensive physical abuse and fatal injuries while in the defendant’s care. Medical and forensic evidence indicated repeated, severe trauma consistent with child abuse. The defendant denied responsibility, suggesting others may have caused the injuries, and presented evidence attempting to cast doubt on the mothers’ fitness as parents.After the initial trial in the Kern County Superior Court, the defendant was convicted and sentenced to death, but the trial court granted a new trial due to juror misconduct. At retrial, the jury again convicted the defendant on all counts and returned a death verdict, which the trial court entered as judgment. The defendant was also sentenced to 25 years to life for the assault charge, with that term stayed.The Supreme Court of California automatically reviewed the case. The defendant raised numerous claims, including challenges to the sufficiency of the evidence, denial of motions for change of venue and to sever charges, alleged juror misconduct, evidentiary rulings, and constitutional challenges to California’s death penalty statute. The court found the evidence sufficient to support the convictions for first degree murder, both as deliberate and premeditated and as murder by torture. The court also found no reversible error in the trial court’s evidentiary and procedural rulings, and rejected the constitutional challenges to the death penalty scheme.The Supreme Court of California’s main holding was to strike a $200 parole revocation fine imposed under Penal Code section 1202.45, as the defendant’s sentence did not include a period of parole. In all other respects, the court affirmed the judgment, including the convictions and the death sentence. View "P. v. Alvarez" on Justia Law

The defendant was convicted in 2019 of home invasion robbery, burglary, assault with a firearm, kidnapping, and false imprisonment. The jury also found that a principal in the offense was armed with a firearm. The trial court found that the defendant had two prior strikes based on 2006 and 2007 convictions for felony active participation in a criminal street gang. The defendant filed a Romero motion to dismiss the prior strikes, which the trial court initially denied, citing his criminal history and the nature of his current offenses. The defendant was sentenced to a determinate prison term of 30 years and a consecutive indeterminate term of 27 years to life.The Court of Appeal reversed the trial court’s findings regarding the prior strikes, noting that recent judicial authority had narrowed the scope of the offense. At the 2023 resentencing, the District Attorney conceded that the 2007 conviction did not qualify as a strike, and the trial court found the 2006 conviction did qualify. The defendant filed a new Romero motion, which the trial court granted, citing recent legislative changes and the remoteness of the 2006 strike. The trial court dismissed the strike and imposed a reduced sentence.The California Supreme Court reviewed the case and concluded that the Court of Appeal erred in directing the trial court to reinstate the strike and resentence the defendant under the Three Strikes law. The Supreme Court held that the proper remedy was to remand the case to the trial court to allow it to exercise its discretion based on a correct understanding of the law. The judgment of the Court of Appeal was reversed, and the case was remanded for resentencing in accordance with the Supreme Court's opinion. View "P. v. Dain" on Justia Law

In 2016, a trial court found Jerry Anthony Faial guilty of petty theft with a prior theft-related conviction, two counts of making criminal threats, and first-degree burglary. The court imposed a 12-year sentence but suspended its execution, placing Faial on four years of probation. In 2019, the court revoked and terminated Faial’s probation due to violations and ordered the execution of the suspended sentence. Faial appealed the decision.The Court of Appeal concluded that Assembly Bill 1950, which limits probation terms for most felonies to two years, did not apply to Faial because his probation had been revoked and terminated before the legislation became operative on January 1, 2021. The court reasoned that the legislation was intended to apply only to defendants whose probation had not been revoked and terminated.The Supreme Court of California reviewed the case and concluded that Assembly Bill 1950 applies retroactively to shorten Faial’s probation term to two years, as his case was not yet final. The court held that the ameliorative changes of Assembly Bill 1950 could be applied to Faial’s case, meaning his probation term expired by operation of law two years after it was imposed. Consequently, the orders revoking and terminating his probation and executing his suspended sentence were invalid. The judgment of the Court of Appeal was reversed, and the case was remanded for proceedings consistent with this opinion. View "P. v. Faial" on Justia Law

The defendant, high on methamphetamine and upset over his marriage's end, drove through Elk Grove, California, and shot bystanders with a shotgun, killing two men and injuring two others. He was convicted of two counts of murder and five counts of attempted murder, with special circumstances and firearm enhancements. The jury sentenced him to death, and the court denied his motions for a new trial and to modify the death verdict.The Sacramento County Superior Court oversaw the trial. The defense argued for a change of venue due to pretrial publicity, which was denied. The court also denied the defense's request to exclude Elk Grove residents from the jury pool. The defense's challenges to certain jurors for cause were mostly denied, and the court allowed the use of physical restraints on the defendant during the trial. The court admitted the defendant's statements made in the hospital and allowed cross-examination of the defense expert on the defendant's lack of remorse and possession of a Satanic Bible.The California Supreme Court reviewed the case. It affirmed the trial court's decisions, including the denial of the change of venue, the use of physical restraints, and the admission of the defendant's statements. The court found no abuse of discretion in the trial court's handling of jury selection, the admission of victim impact evidence, and the cross-examination of the defense expert. The court also upheld the constitutionality of California's death penalty statutes and found no cumulative error that would warrant reversing the judgment. The judgment of death was affirmed. View "People v. Dunn" on Justia Law

The defendant was convicted of three first-degree murders and several related offenses, including rape and sexual penetration with a foreign object, committed between 1988 and 1998 in Stockton and Oakland, California. The prosecution’s case relied heavily on DNA evidence linking the defendant to the victims, as well as ballistics evidence connecting the same firearm to multiple murders. The victims were found in isolated areas, often bound, and killed by gunshots to the head. The defendant was also convicted of the rape and kidnapping of another woman, Yvette R., who survived and testified. The defense presented no evidence at the guilt phase but, during the penalty phase, offered expert testimony about the defendant’s abusive childhood and mental health issues, including sexual sadism.The San Joaquin County Superior Court jury found the defendant guilty on all counts, found true the special circumstance allegations (multiple murders and murder during rape), and returned death verdicts for each murder. The court imposed a death sentence and additional terms for the noncapital offenses. The defendant’s appeal to the Supreme Court of California was automatic.The Supreme Court of California reviewed numerous claims, including alleged instructional errors, challenges to the constitutionality of special circumstances, claims of prosecutorial misconduct, and issues related to victim impact evidence and penalty phase instructions. The court held that there was no substantial evidence to support instructions on voluntary manslaughter or that the victims were dead at the time of sexual assault, and found no reversible error in the instructions given. The court also rejected challenges to the constitutionality of California’s death penalty scheme and the admission of victim impact evidence. The court found harmless any error in failing to redefine reasonable doubt at the penalty phase and in the response to a jury question about parole eligibility. The judgment was affirmed in its entirety, with a minor correction to the firearm enhancement terms. View "People v. Choyce" on Justia Law

The case involves a defendant who was convicted of five counts of first-degree murder, 20 counts of arson, and 17 counts of possession of an incendiary device. The charges stemmed from a series of wildland fires in Southern California, culminating in the Esperanza Fire, which resulted in the deaths of five firefighters. The prosecution's case was built on evidence including DNA, eyewitness testimony, and expert analysis of the incendiary devices used to start the fires. The defense argued that the evidence was insufficient to prove the defendant's guilt and challenged the credibility of the prosecution's witnesses.In the lower court, the Riverside County Superior Court, the jury found the defendant guilty on all counts and made true findings on the special-circumstance allegations. The jury returned a verdict of death in the penalty phase, and the trial court denied the defendant's motion to reduce the death verdict, sentencing him to death on the murder convictions and to 28 years on the remaining convictions. The defendant's appeal was automatic.The Supreme Court of California reviewed the case and addressed several issues raised by the defendant, including the sufficiency of the evidence, the admission of certain evidence, and alleged instructional errors. The court found that substantial evidence supported the jury's findings and that any assumed instructional errors were harmless beyond a reasonable doubt. The court also rejected the defendant's challenges to the admission of evidence and the handling of jury selection.The Supreme Court of California affirmed the judgment in its entirety, upholding the defendant's convictions and death sentence. The court concluded that the cumulative effect of any assumed errors did not warrant reversal and rejected the defendant's challenges to California's death penalty statute. View "People v. Oyler" on Justia Law