Justia California Supreme Court Opinion Summaries

Articles Posted in Criminal Law

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The Supreme Court held that when a law enforcement agency creates a so-called internal Brady list, and a peace officer on that list is a potential witness in a pending criminal prosecution, the agency may disclose to the prosecution the name and identifying number of the officer and that the officer may have relevant exonerating or impeaching material in that officer's confidential personnel file. The "Pitchess statutes" restrict a prosecutor's ability to learn of and disclose certain information regarding law enforcement officers. Some law enforcement agencies created Brady lists enumerating officers that the agencies identified as having potential exculpatory or impeachment information in their personnel filed - i.e., evidence that may need to be disclosed to the defense under Brady and its progeny. Petitioner in this case obtained a preliminary injunction preventing the Los Angeles County Sheriff's Department from disclosing the identity of deputies on the Department's Brady list, but the injunction included and exception permitting disclosure to prosecutors when a deputy is a potential witness in a pending prosecution. The court of appeal concluded that the exception was impermissible under the Pitchess statutes. The Supreme Court reversed, holding that the Pitchess statutes merit such disclosure. View "Association for Los Angeles Deputy Sheriffs v. Superior Court" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the decision of the court of appeal affirming Defendant's conviction of attempted kidnapping where Defendant was charged with completed kidnapping, holding that reversal was not warranted by the mere fact that Defendant was charged with completed kidnapping but convicted of attempted kidnapping. In affirming the conviction, the court of appeal cited the Supreme Court's decision in People v. Martinez, 20 Cal.4th 225 (1999), which treated attempted kidnapping as a lesser included offense of completed kidnapping. On appeal, Defendant asked the Court to overrule Martinez and rule that he could not constitutionally be convicted of attempted kidnapping because that offense includes an element that completed kidnapping lacks. The Supreme Court affirmed, holding (1) because attempted kidnapping requires an additional intent element, attempted kidnapping is not a lesser included offense of completed kidnapping; but (2) reversal was not warranted in this case because Cal. Penal Code 1159 states that a defendant may be convicted of an attempt despite being charged only with the completed crime. View "People v. Fontenot" on Justia Law

Posted in: Criminal Law

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The Supreme Court reversed the judgment of the court of appeal finding that the trial court's error in permitting the jury to consider a box cutter an inherently deadly weapon was prejudicial, holding that the error was harmless beyond a reasonable doubt. A jury convicted Defendant of assault with a deadly weapon and found true that Defendant personally used a deadly and dangerous weapon. The court of appeal reversed the conviction of assault with a deadly weapon and the true finding on the weapon allegation, finding that the trial court erred in permitting the jury to find the box cutter to be an inherently deadly weapon, and the error required reversal of the conviction. The Supreme Court reversed, holding that the error was harmless beyond a reasonable doubt. View "People v. Aledamat" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the decision of the court of appeal affirming the judgment of the trial court denying Defendant's motion to dismiss his recommitment as a mentally disordered offender (MDO) on the basis that the redesignation of his theft offense meant he no longer had a qualifying offense for his MDO recommitment, holding that the applicable statutes did not afford Defendant the relief he sought. Defendant pleaded guilty to one count of felony grand theft. After Defendant had completed his sentence he was admitted to a state hospital as an MDO as a parole condition. Since his initial commitment, Defendant was recommitted as an MDO annually. In 2016, after voters approved Proposition 47, Defendant successfully petitioned to have his felony conviction redesignated as a misdemeanor. Thereafter, Defendant moved to dismiss his recommitment as an MDO, arguing that the redesignation of his theft offense meant he no longer had a qualifying offense for his MDO recommitment. The trial court denied the motion, and the court of appeal affirmed. The Supreme Court affirmed, holding that the redesignation of Defendant's theft offense as a misdemeanor did not undermine the continued validity of his initial commitment or preclude Defendant's continued recommitment as an MDO. View "People v. Foster" on Justia Law

Posted in: Criminal Law

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In this appeal concerning a condition of probation requiring Ricardo P. to submit to warrantless searches of his electronics devices the Supreme Court held that the electronics search condition was not reasonably related to future criminality and was therefore invalid under People v. Lent, 15 Cal.3d 481 (1975). In Lent, the Supreme Court held that "a condition of probation which requires or forbids conduct which is not itself criminal is valid if that conduct is reasonably related to the crime of which the defendant was convicted or to future criminality." Ricardo, a juvenile, was placed on probation after admitting two counts of felony burglary. As a condition of his probation, the juvenile court imposed the electronics search. Although there was no indication Defendant used an electronic device in connection with the burglaries, the court imposed the condition in order to monitor Ricardo's compliance with separate conditions. The court of appeals concluded that the condition was unconstitutionally overbroad and should be narrowed but held that the condition was permissible under Lent because it served to prevent future criminality. The Supreme Court disagreed, holding that the electronics search condition was not reasonably related to future criminality. View "In re Ricardo P." on Justia Law

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The Supreme Court discharged an order to show cause filed by Petitioner in connection with his petition seeking a writ of habeas corpus, holding that Petitioner failed to meet the applicable standard for relief under any claim raised in his habeas petition and referenced in the Court's order to show cause. Petitioner was convicted of first degree murder and conspiracy to commit murder and to commit assault on correctional staff. The Supreme Court affirmed. While Petitioner's appeal was pending, Petitioner filed a petition seeking a writ of habeas corpus. The Supreme Court found the petition stated a prima facie cause for relief on several claims and issued an order to show cause why relief should not be granted on a subset of the claims raised. The Court then appointed a referee to take evidence and making certain findings of fact. After the referee filed a report, the Court accepted most of the referee's report and findings as supported by substantial evidence and discharged the order show cause, holding that Petitioner failed to meet the standards for habeas relief. View "In re Masters" on Justia Law

Posted in: Criminal Law

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The Supreme Court disapproved the lead opinion in People v. Ray, 21 Cal.4th 464 (1999), in which the Court articulated a "community caretaking" exception to the warrant requirement for government entry into a private residence, holding that such an entry for reasons short of a perceived emergency, or similar exigency, fails to satisfy the relevant constitutional standard. Defendant was charged with manufacturing a controlled substance and firearm-related charges. Defendant filed a motion to suppress the evidence found in his home. The trial court denied the motion. Defendant later pleaded guilty. The court of appeal affirmed, concluding that, even in the absence of exigency, the warrantless entry of Defendant's home was justified under the "community caretaking" exception. The Supreme Court reversed, holding that the community caretaking exception asserted in the absence of exigency is not one of the carefully delineated exceptions to the residential warrant requirement recognized by the United States Supreme Court. View "People v. Ovieda" on Justia Law

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The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and sentence of death, holding that there was no error in the proceedings below that entitled Defendant to reversal of his convictions. Specifically, the Court held (1) both prongs of Cal. Const. art. I, 28(d)'s requirement were met in this case, and allowing the jury to judge the relevant evidence did not violate Defendant's due process rights; (2) a witness's decision not to testify, upheld by the court, did not deny Defendant the right to present a defense; (3) the state and federal constitutions supported the trial court's decision to grant the witness her Fifth Amendment privilege; (4) Defendant's challenges to California's death penalty law were unavailing; and (5) Defendant failed to establish cumulative error because there were no errors to aggregate. View "People v. Capers" on Justia Law

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The Supreme Court affirmed Defendant's convictions for two counts of first degree murder and other crimes but reversed Defendant's sentence of death imposed after a penalty retrial, holding that the trial court erred by permitting the prosecution to make improper use of inflammatory character evidence for purposes unrelated to any legitimate issue in the proceeding. Defendant was convicted of two counts of first degree murder, attempted murder, and carjacking. The jury was unable to reach a verdict as to penalty, and the trial court declared a mistrial. The jury sentenced Defendant to death after a penalty retrial. The Supreme Court affirmed Defendant's convictions but reversed his sentence of death, holding (1) assuming that the trial court erred in admitting Defendant's statement "You heard it all" and admitting certain evidence of Defendant's racist tattoos, affiliations, and beliefs, neither error was prejudicial either individually or cumulatively; and (2) the trial court erred in allowing the prosecution to use evidence of Defendant's abstract beliefs when advising the jury whether to impose the death penalty, and the error was prejudicial. View "People v. Young" on Justia Law

Posted in: Criminal Law

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The Supreme Court issued a writ of mandate directing the trial court to vacate its order denying Petitioner's request to release ballistics evidence for expert testimony in preparation for filing a habeas corpus petition, holding that the trial court erred in denying the request based solely in Petitioner's failure to establish good cause. Petitioner was sentenced to death for the first degree murders of two victims. In preparation for filing a habeas corpus petition, Petitioner filed his request for the ballistics evidence. The superior court denied Petitioner's request to release ballistics evidence for expert testimony under the authority of Cal. Penal Code 1054.9, which governs discovery in habeas corpus proceedings involving certain judgments, including a sentence of death. The court found specifically that Petitioner had failed to show good cause to believe his access to the evidence was reasonably necessary to obtain relief. The Supreme Court vacated the order, holding that, under the statute, a threshold showing of good cause is not required. View "Satele v. Superior Court of Los Angeles County" on Justia Law

Posted in: Criminal Law