Justia California Supreme Court Opinion Summaries

Two men attacked a couple as they entered their condominium, robbing them and sexually assaulting the woman. During the incident, the male victim was fatally shot. Decades later, DNA evidence linked one of the assailants, Morris, to the crime. In 2013, Morris was convicted by a jury of first degree murder, with special circumstances for rape, robbery, and murder for financial gain. The jury found that Morris acted with intent to kill, and the trial court sentenced him to life without parole. The conviction was affirmed on appeal.After changes to California’s felony-murder rule under Senate Bill 1437, Morris filed a petition for resentencing under Penal Code section 1172.6, arguing he was ineligible for murder liability as a nonkiller under the amended law. The Superior Court summarily denied the petition at the prima facie stage, reasoning that the jury’s findings established Morris’s intent to kill, making him ineligible for relief. The California Court of Appeal, in a split decision, affirmed the denial. The majority held that, under the amended law, it was sufficient that Morris acted with intent to kill and aided the underlying felony, even if he was not the actual killer. The dissenting judge argued that the law requires a nonkiller to have aided the actual killer in the lethal act itself, not just in the underlying felony.The Supreme Court of California reviewed the case to resolve a conflict among appellate courts regarding the actus reus requirement for nonkiller aiders and abettors under section 189, subdivision (e)(2). The Supreme Court held that, for a nonkiller to be liable for felony murder under this provision, the prosecution must prove that the nonkiller, with intent to kill, aided or abetted the actual killer in the commission of the lethal act itself—not merely in the commission of the underlying felony. The Court reversed the Court of Appeal and remanded for further proceedings. View "P. v. Morris" on Justia Law

The defendant used a false pretense to enter the motel room of Carole Sund, her daughter Juli Sund, and family friend Silvina Pelosso. Once inside, he brandished a gun, used duct tape to bind the three, and murdered Carole and Silvina by strangulation and suffocation. Over several hours, he sexually assaulted Juli, then kidnapped her, assaulted her again, and ultimately killed her by slitting her throat. Months later, he also kidnapped, murdered, and decapitated Joie Armstrong. The defendant confessed to these crimes in detail. Physical evidence and testimony corroborated his confession. Evidence related to the Armstrong murder, prosecuted federally, was introduced during the penalty phase.A jury in the Santa Clara County Superior Court convicted the defendant of three counts of first-degree murder and one count of kidnapping. The jury found true multiple enhancement allegations, including use of a deadly weapon and firearm, and five special circumstances: multiple murders, kidnapping murder, attempted rape murder, forcible oral copulation murder, and burglary murder. The jury found not true the alleged robbery-murder special circumstance. In a separate sanity phase, the jury found the defendant sane at the time of the offenses, and in the penalty phase, recommended the death penalty. The trial court denied motions for a new trial and sentence modification, imposing death plus a consecutive prison term.On automatic appeal, the Supreme Court of California reviewed numerous claims, including challenges to the admission of the defendant’s confession, claims of evidentiary and procedural error, allegations of juror misconduct, and arguments regarding the constitutionality of California’s death penalty scheme. The Court held that the confession was properly admitted, the evidentiary and procedural rulings were within the trial court’s discretion, and that there was no prejudicial juror misconduct or judicial bias. The Court also rejected constitutional challenges to the death penalty statute. The Supreme Court of California affirmed the judgment in its entirety. View "People v. Stayner" on Justia Law

A man was arrested after attempting to purchase food at a restaurant using several credit cards, three of which were lost cards belonging to other individuals. When the first five cards were declined, he discarded them; the sixth card worked, but after a dispute with the manager over a refund, he left without the food and was later taken into custody. He was charged with multiple counts, including felony vandalism, identity theft, and petty theft. At arraignment, the trial court denied his motion for release on his own recognizance and set bail at $75,000, citing his extensive criminal history and past failures to appear. After further hearings, the trial court ultimately denied bail altogether.The defendant filed a petition for writ of habeas corpus in the California Court of Appeal, First Appellate District, Division Three, challenging the denial of bail. While the petition was pending, he entered a plea agreement, resulting in his release. The appellate court dismissed the petition as moot, but the Supreme Court of California directed the Court of Appeal to address unresolved constitutional questions regarding bail. The Court of Appeal issued a published opinion addressing the relationship between two California constitutional provisions on bail and whether a trial court may set bail above a defendant’s ability to pay. The appellate court's reasoning conflicted with another appellate decision, In re Brown.The Supreme Court of California reviewed the case to resolve these issues. It held that Article I, section 12, subdivisions (b) and (c), defines the exclusive circumstances under which bail may be denied in noncapital cases, and Article I, section 28(f)(3), can be harmonized with, but does not expand, these exceptions. The court further held that, except where pretrial detention is authorized, bail must be set in an amount reasonably attainable given the defendant’s circumstances; courts may not set bail at an amount that is objectively unattainable based solely on indigency. The Supreme Court affirmed the judgment of the Court of Appeal. View "In re Kowalczyk" on Justia Law

A 16-year-old defendant and several adult associates, all affiliated with a street gang, confronted perceived rivals outside a taco truck in Modesto. During the confrontation, one of the group’s members fatally shot a rival gang member. The defendant was convicted by a jury of murder, assault with a deadly weapon, and participation in a criminal street gang. Jury enhancements were applied for crimes committed for the benefit of a gang and for personal firearm use causing death. The prosecution’s theory at trial shifted, with arguments that either the defendant was the shooter or he aided and abetted the shooting. The jury was instructed on both perpetrator and accomplice liability, using standard instructions that later case law found potentially ambiguous as to whether malice could be imputed to an accomplice.Following the passage of Senate Bill 1437 and related legislation, which restricted murder liability and created a resentencing process for those convicted under prior, broader legal theories, the defendant petitioned for resentencing under Penal Code section 1172.6. The Stanislaus County Superior Court acknowledged a prima facie case for relief, but, after an evidentiary hearing, denied the petition, finding the defendant could be convicted as either the actual killer or a direct aider and abettor. The defendant appealed, arguing the instructions allowed conviction on an impermissible imputed malice theory. The California Court of Appeal affirmed the denial, holding the defendant’s claim was not cognizable in a section 1172.6 petition because he could have raised it on direct appeal and had therefore forfeited it.The Supreme Court of California reversed. It held that Penal Code section 1172.6, subdivision (a)(3), does not categorically bar resentencing relief for petitioners who could have raised instructional challenges to imputed malice on direct appeal but did not. The court remanded the case to the Court of Appeal for consideration of the merits of the defendant’s claims. View "People v. Lopez" on Justia Law

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