Justia California Supreme Court Opinion Summaries

Two defendants were implicated in the 1985 kidnapping, rape, and murder of a woman in California. Evidence showed that they were previously involved in a string of armed robberies and planned to escape law enforcement by stealing a vehicle from a shopping center parking lot. They kidnapped the victim, drove her hundreds of miles, sexually assaulted her, and killed her before disposing of her body in a canal. Forensic evidence, including eyewitness testimony and DNA analysis, linked both men to the crimes. Both were arrested years later after advances in DNA technology allowed for retesting of biological evidence.The Sacramento County Superior Court tried the defendants together with separate juries. Each was found guilty of murder, rape, and kidnapping, with special circumstances for kidnapping-murder, robbery-murder, and rape-murder. One defendant was also convicted of sodomy with a sodomy-murder special circumstance. Both were sentenced to death after separate penalty phase trials. The court also imposed various prison terms and restitution fines, staying the execution of the prison sentences.The Supreme Court of California reviewed the case on automatic appeal. It affirmed the convictions of both defendants and the death sentence for one. However, it reversed the death sentence for the second defendant, finding that subsequent changes in the law—specifically regarding the competency of defendants with mental illness to represent themselves—required reversal of his sentence, including the death judgment. The court also vacated any balance of restitution fines for both defendants, pursuant to recent statutory amendments. The case was remanded for further proceedings as to the sentencing of the second defendant. View "P. v. Bertsch" on Justia Law

The case arose from the killing of Rachel Deen and Calipatria Police Chief J. Leonard Speer by Omar Richard Deen on April 10, 1998. After an argument at his mother’s equipment yard, Deen shot both victims and fled to Mexico, where he was apprehended the same day and confessed. Evidence presented at trial included testimony about Deen’s strained relationship with his mother, prior threats, disputes over his father’s estate, and his mental health history, including diagnoses of severe thought disorder and schizophrenia, as well as methamphetamine abuse. The prosecution introduced evidence of premeditation and financial motive, while the defense focused on Deen’s mental state and substance-induced impairment.The Imperial County Superior Court conducted a four-phase trial—competency, guilt, sanity, and penalty. Deen was found competent by a separate jury and judge. The main trial jury convicted him of both murders, found true special circumstances (financial gain and killing a police officer in the line of duty), and returned a death verdict. Deen raised multiple issues on appeal, including the denial of several challenges for cause during jury selection, particularly regarding Juror No. 5, who had close associations with Chief Speer and law enforcement, had heard details of the case from police sources, and expressed difficulty in being impartial.The Supreme Court of California found that the trial court erred by denying the challenge for cause as to Juror No. 5. The trial court had misunderstood its authority, relying too heavily on the juror’s assurances of impartiality instead of independently determining whether actual bias existed under the applicable statutes. The Supreme Court held that the trial court must objectively consider the totality of circumstances regarding potential juror bias and remanded for a new trial, reversing the judgment in its entirety. View "P. v. Deen" on Justia Law

During an incident in Sonoma County, the defendant aimed an unloaded firearm at police officers, racked the slide, and pulled the trigger, but the weapon did not discharge. Officers later recovered the unloaded gun from the defendant’s vehicle. The defendant was charged and convicted of knowingly resisting an executive officer by the use of force or violence, in violation of California Penal Code section 69, subdivision (a). At trial, the defendant argued that assault is a lesser included offense of resisting an officer by force or violence, and that because his firearm was unloaded, he lacked the present ability to inflict injury, precluding a conviction for assault and thus for resisting under section 69(a).The Sonoma County Superior Court denied the defendant’s motion for acquittal and declined to instruct the jury on assault as a lesser included offense. The jury convicted the defendant on one count of resisting an officer but was unable to reach a verdict on two other counts. On appeal, the California Court of Appeal, First Appellate District, Division One, affirmed the conviction. The appellate court rejected the argument that assault is a lesser included offense of resisting an officer by force or violence, reasoning that section 69 does not include the “present ability” requirement found in assault, nor does its language require force or violence to be directed “upon the person” of an officer.The Supreme Court of California reviewed the case to resolve a conflict with an earlier decision, People v. Brown. The Supreme Court held that assault is not a lesser included offense of resisting an officer by force or violence under section 69(a), because this offense does not require a present ability to cause injury. The court affirmed the judgment of the Court of Appeal and expressly disapproved People v. Brown to the extent it was inconsistent with this holding. View "P. v. Morgan" on Justia Law

During a routine traffic stop for a minor violation, Sacramento Police officers pulled over a vehicle driven by Kayla Sepulveda, with Davonyae Sellers as a passenger. The officers observed a rolling tray on the backseat and what they described as “weed crumbs” scattered on the rear floorboard behind and under the passenger seat. The occupants were cooperative, and there was no suspicion of impaired driving. After having Sepulveda and Sellers exit the vehicle, the officers searched the car and Sepulveda’s purse, finding only 0.36 grams of loose marijuana on the floor and an unregistered firearm near the front passenger seat. Sellers was charged with unlawful firearm possession and moved to suppress the gun evidence, arguing the search was unlawful.A magistrate judge denied Sellers’s suppression motion, reasoning that the presence of loose marijuana constituted “contraband” under the open container law, thus providing probable cause for the search. The Sacramento County Superior Court affirmed this decision. The Court of Appeal for the Third Appellate District also upheld the search, holding that any marijuana not in a sealed container violated the open container statute and, alternatively, that the totality of circumstances supported probable cause for the search. One justice dissented, arguing the law required the presence of an actual container and that the facts did not support a violation or probable cause.The Supreme Court of California reversed the Court of Appeal’s decision. It held that a violation of Health and Safety Code section 11362.3, subdivision (a)(4) requires marijuana in a vehicle to be of a usable quantity, in imminently usable condition, and readily accessible to an occupant. The small amount of loose marijuana on the rear floor in this case was neither imminently usable nor readily accessible. The court further held that the circumstances did not provide probable cause for a warrantless vehicle search. The case was remanded for further proceedings. View "Sellers v. Super. Ct." on Justia Law

One defendant in this case was a high-ranking member of the Varrio Fallbrook Locos gang and the Mexican Mafia, while a codefendant acted as a secretary within the gang structure. In December 2013, the defendant participated in a meeting regarding methamphetamine sales, which resulted in the violent assault of another gang member, A.C., after accusations of unpaid debts. Following the assault, the defendant attempted to prevent A.C. from testifying and conspired to arrange the murder of another gang affiliate. The defendant was convicted by a jury of multiple offenses, including assault with a deadly weapon, conspiracy to commit murder, and conspiracy to dissuade a witness, among others. The trial court imposed a lengthy prison sentence and ordered the defendant to pay various fines and ancillary costs, despite defense counsel’s request to consider the defendant’s inability to pay.The Court of Appeal for the Fourth Appellate District, Division One, reviewed the monetary orders. It held that the trial court should have considered the defendant’s ability to pay before imposing ancillary costs but rejected the argument that an ability-to-pay finding was required for punitive fines. The appellate court clarified that fines could still be challenged under the excessive fines clauses of the federal and state constitutions and remanded the case for resentencing and further proceedings regarding the fines and costs.The Supreme Court of California reviewed the case to resolve inconsistent approaches among lower courts concerning court-ordered financial obligations. The Court held that challenges to the amount of criminal fines must be reviewed under the excessive fines clauses of the United States and California Constitutions. Separately, the Court held that, upon request, a sentencing court must consider a defendant’s inability to pay before imposing court operations and facilities assessments, as failing to do so violates equal protection. The judgment was reversed in part and remanded for further proceedings consistent with these holdings. View "P. v. Kopp" on Justia Law

In December 2020, Troy Lee Shaw was found unconscious in his car by police officers and subsequently charged with felony driving under the influence of a drug, possession of a controlled substance, possession of drug paraphernalia, and possession of more than 28.5 grams of marijuana. Shaw admitted to having two prior convictions for gross vehicular manslaughter while intoxicated, stemming from a 2002 incident in which his impaired driving resulted in the deaths of a mother and her young son. These two prior convictions made him eligible for a third-strike sentence under California’s Three Strikes law.Shaw requested that the Placer County Superior Court dismiss one of his prior strikes, arguing that both convictions arose from a single criminal act and citing People v. Vargas (2014) 59 Cal.4th 635. The trial court denied his motion and imposed a third-strike sentence of 25 years to life for the driving under the influence charge, with concurrent six-month sentences for the other possession offenses. On appeal, the California Court of Appeal, Third Appellate District, affirmed the sentence, relying on People v. Rusconi (2015) 236 Cal.App.4th 273, and reasoned that because Shaw’s prior act harmed two victims, it was distinguishable from Vargas, which involved a single victim.The Supreme Court of California reviewed the case and reversed the Court of Appeal’s decision. It held that under the Three Strikes law, when two prior convictions arise from a single criminal act—even if that act harmed multiple victims—a trial court must dismiss one of the strikes for sentencing purposes. The court disapproved the contrary holding in Rusconi and directed the lower court to resentence Shaw consistent with this ruling. View "P. v. Shaw" on Justia Law

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