Justia California Supreme Court Opinion Summaries

In 2018, Richard Allen Mitchell was charged with one felony count of resisting an executive officer and one misdemeanor count of possessing a controlled substance. The prosecution also alleged that Mitchell had a prior "strike" conviction. Five years later, just before the trial was to begin, the trial court reduced the felony charge to a misdemeanor and referred Mitchell to a veterans court program.The Ventura County District Attorney sought review of the trial court's order by filing both an appeal and a petition for writ of mandate in the Court of Appeal. The district attorney argued that the trial court lacked statutory authority to reduce the felony charge to a misdemeanor before sentencing. The Court of Appeal stayed the trial court proceedings and issued an order to show cause. After briefing, the Court of Appeal held that the trial court's order was unauthorized and granted the requested relief, determining that the order was appealable under certain statutory provisions.The Supreme Court of California reviewed the case and disagreed with the Court of Appeal's finding on appealability. The Supreme Court held that the trial court's order was not appealable under the cited statutory provisions because it did not set aside or terminate any portion of the action but merely modified the charges. However, the Supreme Court concluded that the trial court's order was unauthorized and in excess of its jurisdiction, making it subject to writ review. The Supreme Court affirmed the judgment of the Court of Appeal but noted that the trial court's subsequent actions, taken while a temporary stay was in effect, were void. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "People v. Superior Court (Mitchell)" on Justia Law

Giles Albert Nadey, Jr. was convicted of unlawful sodomy and first-degree murder for the killing of Terena Fermenick. The jury found that both offenses involved the use of a knife and that the murder occurred during the commission of unlawful sodomy. After the first jury deadlocked on the penalty, a second jury sentenced Nadey to death. The case involved significant DNA evidence linking Nadey to the crime, and the prosecution theorized that Nadey killed Fermenick shortly after she signed a work order for carpet cleaning services he provided.The Alameda County Superior Court handled the initial trial, where Nadey was convicted and sentenced to death. During the trial, the defense challenged the DNA evidence and the credibility of the state's expert, but did not call their own DNA expert, Dr. Edward Blake, to testify. The defense's failure to present Blake as a witness became a point of contention, with the prosecution arguing that this indicated the defense had no evidence to contradict the state's findings.The Supreme Court of California reviewed the case and affirmed the judgment. The court held that the evidence of Blake's involvement was properly admitted and that the prosecutor's comments on the defense's failure to call Blake did not constitute misconduct. The court also found that any error in the trial court's handling of a juror's note regarding the defense's access to a DNA expert was harmless. Additionally, the court concluded that the admission of testimony from a pathologist who did not conduct the autopsy did not violate Nadey's confrontation rights, as much of the testimony was proper and any error was harmless beyond a reasonable doubt. View "People v. Nadey" on Justia Law

The case involves Jeremiah Ira Williams, who was sentenced to an indeterminate prison term of 100 years to life plus 86 years and two months for committing multiple forcible sexual offenses under California's One Strike law when he was 24 years old. Williams argued that the exclusion of One Strike offenders from early parole eligibility under California’s youth offender parole statute (Pen. Code, § 3051) violated his equal protection rights under the Fourteenth Amendment. He contended that it was irrational to exclude young adults convicted of One Strike offenses from early parole while not excluding young adults convicted of murder without special circumstances.The San Diego County Superior Court convicted Williams on multiple counts, including robbery, forcible rape, and sodomy by use of force, among others. The jury found him guilty on most counts and found true several aggravating factors, including personal use of a firearm and infliction of great bodily injury. The trial court imposed the lengthy sentence based on these findings. Williams appealed to the Fourth Appellate District, Division One, arguing that the exclusion of One Strike offenders from early parole eligibility violated equal protection. The Court of Appeal rejected his claim, finding a rational basis for the differential treatment based on the threat of recidivism by violent sexual offenders.The Supreme Court of California reviewed the case and affirmed the Court of Appeal’s judgment. The court held that the Legislature could rationally exclude One Strike offenders from early parole eligibility under section 3051 based on concerns about the high risk of recidivism and the aggravated nature of their offenses. The court concluded that these concerns provided a rational basis for the differential treatment, thus rejecting Williams' equal protection challenge. The court remanded the matter to the Court of Appeal to consider any briefing on Williams' entitlement to the benefit of any ameliorative legislation enacted during the pendency of his appeal. View "People v. Williams" on Justia Law

Victor Raul Tellez was charged with three counts of lewd or lascivious acts upon a child and faced a maximum prison term of 12 years. On the advice of his attorney, he accepted a plea deal, pleading guilty to one count and receiving a three-year prison sentence. Tellez was not informed that his conviction would make him eligible for civil commitment as a sexually violent predator (SVP) under the Sexually Violent Predator Act (SVPA). After completing his prison term, the District Attorney initiated SVPA proceedings for his involuntary commitment to a state hospital.Tellez filed a petition for writ of habeas corpus in the San Diego County Superior Court, claiming ineffective assistance of counsel for not being advised of the SVPA consequences. The superior court denied his petition, and the Court of Appeal also denied it, stating that prevailing norms did not require such advisement and that Tellez had not demonstrated prejudice. Tellez then petitioned the California Supreme Court for review.The California Supreme Court held that Tellez did not sufficiently demonstrate he was prejudiced by his counsel’s failure to advise him of the SVPA consequences. The court noted that Tellez provided insufficient evidence that he would not have accepted the plea deal had he been informed of the SVPA consequences. Therefore, the court did not address whether his counsel’s performance was constitutionally deficient. However, recognizing the significant liberty deprivation involved in SVPA commitments, the court exercised its supervisory powers to require trial courts to inform defendants of potential SVPA consequences when pleading guilty or no contest to a qualifying offense. The judgment of the Court of Appeal was affirmed on the ground that Tellez had not demonstrated prejudice. View "In re Tellez" on Justia Law

In June 2012, Maurice Walker assaulted a woman and a 78-year-old man in Los Angeles. Walker was convicted of assault with a deadly weapon, elder abuse, and misdemeanor battery. The jury found true the enhancement allegations that he used a deadly weapon and inflicted great bodily injury on an elderly person. Walker admitted to having prior strike convictions and a prior serious felony conviction. Initially, he was sentenced to 20 years in prison, which was later reduced to 19 years after one enhancement was struck in a habeas proceeding. Another habeas proceeding in 2018 led to the removal of his remaining prior prison term enhancement, and the case was remanded for potential resentencing.The Los Angeles County Superior Court conducted a full resentencing hearing in April 2022. Despite the new provisions of Penal Code section 1385, subdivision (c)(2), which favor dismissing enhancements under certain mitigating circumstances, the trial court declined to dismiss Walker’s enhancements. The court did not find it in the interest of justice to dismiss the enhancements, even though multiple enhancements were present. Walker appealed, arguing that the trial court misapplied section 1385.The California Supreme Court reviewed the case to resolve a conflict between appellate courts on the interpretation of section 1385, subdivision (c)(2). The court concluded that the statute does not create a rebuttable presumption in favor of dismissing an enhancement unless it endangers public safety. Instead, it requires trial courts to give significant weight to mitigating circumstances but allows them to consider other factors. The court affirmed the judgment of the Court of Appeal, finding that Walker was not entitled to relief under the clarified interpretation of the statute. View "P. v. Walker" on Justia Law

In June 2017, Scotlane McCune crashed a vehicle into a tree while driving without a license, injuring his passenger, Miguel Villa. McCune fled the scene, leading to charges of felony hit and run with injury and misdemeanor driving without a license. He pleaded no contest to the felony charge, and the misdemeanor was dismissed. In June 2018, McCune was placed on five years’ probation and ordered to pay restitution to Villa, with the amount to be determined later. In December 2020, Villa sought $30,166.23 in restitution. However, new legislation effective January 1, 2021, capped felony probation at two years, leading to the termination of McCune’s probation on January 14, 2021. The trial court later set the restitution amount at $21,365.94.McCune objected, arguing that the court lacked authority to set the restitution amount after his probation ended. The trial court disagreed, citing Penal Code sections 1202.4 and 1202.46, which allow the court to retain jurisdiction to determine restitution amounts until the victim’s losses are ascertainable. The Court of Appeal upheld this decision, stating that the court’s authority to fix restitution amounts persists even after probation ends, as per sections 1202.4 and 1202.46.The Supreme Court of California affirmed the Court of Appeal’s judgment. The court held that section 1202.46 applies to both probation and nonprobation cases, allowing the court to retain jurisdiction to set restitution amounts once the victim’s losses become ascertainable. The court rejected McCune’s argument that section 1203.3 limits this authority to the probation term, clarifying that section 1202.46 provides additional authority to ensure full victim restitution, consistent with the constitutional mandate. The court disapproved of contrary interpretations in Hilton v. Superior Court and People v. Waters. View "P. v. McCune" on Justia Law

Robert Ward Frazier was convicted by a jury of the murder, forcible rape, and forcible sodomy of Kathleen Loreck. The jury also found true two felony-murder special-circumstance allegations. At the penalty phase, the jury returned a death verdict, which the trial court upheld, sentencing Frazier to death. Frazier's appeal is automatic.The trial court excused a prospective juror for cause due to his views on the death penalty, denied Frazier's request for individually sequestered voir dire, and gave a jury instruction on flight from the scene of a crime. The court also denied Frazier's requests to represent himself during the penalty phase and post-verdict proceedings, including the hearing on his automatic motion to modify the death verdict and sentencing.The California Supreme Court affirmed the trial court's decisions. The court held that the trial court did not err in excusing the prospective juror, as substantial evidence supported the finding that the juror's views would substantially impair his performance. The court also found no error in denying individually sequestered voir dire, as there is no federal constitutional requirement for such in capital cases, and the trial court did not abuse its discretion under state law.The court upheld the flight instruction, finding sufficient evidence to support it and rejecting Frazier's additional arguments against the instruction. The court also ruled that Frazier's requests for self-representation were untimely and that the trial court did not abuse its discretion in denying them. Finally, the court rejected Frazier's claim that his Sixth Amendment right to choose the objective of his defense was violated by the presentation of certain mitigating evidence over his objection. View "P. v. Frazier" on Justia Law

Wilson next argues that the trial court erred in admitting statements he made to detectives after the break when he was outside smoking with Detective Hagen. As Wilson notes, Detective Hagen agreed to end the interview in response to Wilson’s statement that he was not going to discuss the case further and request to be taken back to the holding cell. These circumstances reflect Wilson’s unambiguous invocation of his right to remain silent. (People v. Krebs, supra, 8 Cal.5th at p. 313 [defendant’s invocation was unambiguous when he asked to be returned to his cell and told officers he had nothing to say].) Despite recognizing that Wilson no longer wished to speak, Detective Hagen made additional comments that were reasonably likely to prompt Wilson to continue speaking: He encouraged Wilson to cooperate “right now” to get beneficial treatment before his “partner” did, and he stated that he had “[n]o doubt [Wilson] did it.”However, the trial court found that Wilson reinitiated the conversation during the cigarette break, and substantial evidence supports this finding. Detective Hagen testified that Wilson began discussing the case again during the break, expressing concerns about his family’s safety and asking questions about the investigation. This testimony indicates that Wilson voluntarily chose to resume the conversation, thereby waiving his previously invoked right to remain silent. The trial court’s credibility determinations and factual findings are supported by substantial evidence, and we defer to those findings.Given these circumstances, the trial court did not err in admitting the statements Wilson made to the California detectives after the cigarette break. Wilson’s reinitiation of the conversation and his voluntary engagement in the subsequent interview indicate that his statements were not the product of coercion or improper interrogation tactics. Therefore, the admission of these statements did not violate Wilson’s Fifth Amendment rights. View "P. v. Wilson" on Justia Law

Deandre Lynch was convicted of three counts of domestic violence resulting in a traumatic condition and one count of simple assault. The trial court imposed an upper term sentence based on eight aggravating circumstances, including Lynch's use of a weapon and his prior convictions. The court cited Lynch's criminal history and the severity of his actions as reasons for the upper term sentence.The Court of Appeal affirmed the upper term sentence, finding that two of the aggravating circumstances were proven in compliance with the current law, but the remaining six were not. The court applied a "reasonably probable" standard to determine that the failure to satisfy the current statute was harmless error.The California Supreme Court reviewed the case to determine the appropriate standard for remanding cases for resentencing under the amended Penal Code section 1170(b). The court held that a sentence imposed under the former version of section 1170(b) must be reversed and remanded unless the reviewing court concludes beyond a reasonable doubt that a jury would have found true all of the aggravating facts upon which the trial court relied to justify the upper term sentence, or that those facts were otherwise proven in compliance with the current statute.The court concluded that Lynch's sentence must be reversed and remanded for resentencing because the trial court relied on aggravating facts that were not proven beyond a reasonable doubt by a jury. The court also applied the Gutierrez standard, which requires a remand unless the record clearly indicates that the trial court would have imposed the same sentence even if it had been aware of its more limited discretion under the current law. The court found that the record did not clearly indicate that the trial court would have imposed the same sentence under the new law. View "P. v. Lynch" on Justia Law

Michael Allan Lamb was convicted of first-degree murder, attempted murder of a peace officer, conspiracy to commit murder, unlawfully carrying a loaded firearm in public as a gang member, possession of a firearm by a felon, and street terrorism. The jury found true the gang-murder special-circumstance allegation and other gang-related enhancements. Lamb was sentenced to death after a penalty phase retrial.The Orange County Superior Court initially reviewed the case, where the jury convicted Lamb on all counts but failed to reach a penalty verdict. A different jury at the penalty phase retrial fixed the penalty at death, and the court entered a judgment of death. Lamb's appeal to the California Supreme Court was automatic.The California Supreme Court reviewed the case and reversed Lamb’s convictions for street terrorism and unlawfully carrying a loaded firearm in public due to recent amendments to section 186.22 from Assembly Bill No. 333. The court also reversed the true findings on the gang enhancements and the gang-murder special circumstance. The death judgment was vacated, and the case was remanded to the trial court for any retrial of the reversed convictions, enhancements, and special circumstance. In all other respects, the court affirmed the judgment. View "People v. Lamb" on Justia Law