Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeal ruling that Proposition 47's revision to Cal. Penal Code 496, making the offense of receiving stolen property a misdemeanor when the value of the property is $950 or less, does not extend to convictions for receiving a stolen vehicle under section 496d, holding that Proposition 47's amendment to section 496(a) did not affect convictions for receiving stolen property under section 496d.Proposition 47 amended section 496, the general statute criminalizing receipt of stolen property, by making the offense a misdemeanor if the value of the property does not exceed $950. Proposition 47, however, did not amend 496d. Defendant pleaded guilty to unlawfully buying, receiving, concealing, selling or withholding a stolen vehicle in violation of section 496d. Defendant filed a motion under Proposition 47 to reduce his convictions to misdemeanors. The trial court denied the motion, and the court of appeal affirmed. The Supreme Court affirmed, holding that Proposition 47's revision to section 496 does not extend to convictions under section 496d. View "People v. Orozco" on Justia Law

In this case involving whether Proposition 47 requires a court to draw a distinction under Cal. Veh. Code 10851 between permanent and temporary vehicle takings, the Supreme Court held that a person who has unlawfully taken a vehicle in violation of section 10851 is not disqualified from Proposition 47 relief because the person cannot prove he or she intended to keep the vehicle away from the owner indefinitely.Proposition 47 reduced felony offenses consisting of theft of property worth $950 or less to misdemeanors. While liability for theft generally requires that the defendant have an intent permanently to deprive the owner of possession, section 10581 does not distinguish between temporary takings and permanent ones. At issue in this case was whether Proposition 47 grant sentencing relief to people who take vehicles permanently but denies relief to people who take vehicles temporarily. The Supreme Court answered the question in the negative and reversed the superior court's denial of resentencing for Defendant's 10851 conviction, holding that Proposition is neither categorically inapplicable to section 10851 convictions nor is a defendant not entitled to resentencing because he lacked the intent permanently to deprive the vehicle's owner of its possession. View "People v. Bullard" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that a felony for misuse of personal identifying information under Cal. Penal Code 530.5, subdivision (a) can be reduced to misdemeanor shoplifting under Proposition 47, holding that a conviction for misuse of identifying information is not subject to reclassification as misdemeanor shoplifting.Defendant was convicted of two felony counts of misusing personal identifying information in violation of section 530.5, subdivision (a). Defendant later moved to reclassify his felony convictions to misdemeanors under Proposition 47. The trial court granted Defendant's motion. The court of appeals affirmed. The Supreme Court reversed, holding that misuse of personal identifying information is not a "theft" offense under Cal. Penal Code 459.5, subdivision (b). View "People v. Jimenez" on Justia Law

The Supreme Court affirmed the court of appeal's judgment ordering four of Defendant's sentence enhancements stricken, holding that a convicted defendant who is placed on probation after imposition of sentence is suspended, and who does not timely appeal from the order granting probation, may take advantage of ameliorative statutory amendments that take effect during a later appeal from a judgment revoking probation and imposing sentence.In three separate cases, Defendant pleaded guilty to drug-related offenses and admitting having sustained four prior felony drug-related convictions for purposes of sentence enhancement under Cal. Health & Safety Code former 11370.2. The trial court later revoked probation and imposed a prison sentence that included four three-year prior drug conviction enhancements under former section 11370.2(c). Thereafter, the governor signed Senate Bill No. 180, which revised section 11370.2 so that Defendant's prior drug-related convictions no longer qualified Defendant for sentence enhancement. The Supreme Court remanded the case for reconsideration in light of the revised statute. On remand, the court of appeal concluded that Defendant could take advantage of the revisions to the statute that rendered the sentence enhancements inapplicable to Defendant's prior drug-related convictions. The Supreme Court affirmed, holding that the Legislature must have intended section 11370.2's ameliorative changes to operate in cases like this one. View "People v. McKenzie" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that the admission of expert testimony did not violate the prohibition against communication of case-specific hearsay set forth in People v. Sanchez, 63 Cal.4th 665 (2016) and that sufficient evidence supported Defendant's conviction for possession of alprazolam, holding that the court of appeal did not err.Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for his or her opinion unless the facts are independently proven or fall within a hearsay exception. In the instant case, an expert told the jury that he identified the controlled substance Defendant was charged with possessing by comparing the visual characteristics of the pills seized against a database containing descriptions of pharmaceuticals. On appeal, Defendant argued that the expert related inadmissible case-specific hearsay. The court of appeal affirmed. The Supreme Court affirmed, holding (1) the expert related no inadmissible case-specific hearsay in testifying to the contents of a drug identification database; and (2) substantial evidence supported Defendant's conviction. View "People v. Veamatahau" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that a defense counsel's failure to object at trial, before People v. Sanchez, 63 Cal.4th 665 (2016), was decided, forfeited a claim that a gang expert's testimony related case-specific hearsay in violation of the confrontation clause, holding that a defense counsel's failure to object under such circumstances does not forfeit a claim based on Sanchez.Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for her opinion unless the facts are independently proven or fall within a hearsay exception. Defendants in the instant case were each convicted of two counts of first degree special circumstance murder and other crimes. Before Defendants' appeals were resolved, the Supreme Court issued its opinion in Sanchez. On appeal, one of the defendants argued that a gang expert testified to case-specific hearsay in violation of the confrontation clause. The court of appeal held that the defendant's failure to object to case-specific hearsay in expert testimony at trial forfeited any Sanchez claim on appeal. The Supreme Court reversed, holding that the court of appeal erred in finding that the defendant forfeited his claim on appeal based on Sanchez by failing to object at a trial that occurred before Sanchez was decided. View "People v. Perez" on Justia Law

The Supreme Court granted Petitioner habeas corpus relief, holding that Petitioner was denied his constitutional right to the assistance of competent counsel at the guilt phase of his criminal trial, and trial counsel's deficient performance undermined the reliability of the jury's guilty verdict.Petitioner was convicted of the first degree murder of a police officer and sentenced to death. While his appeal was pending, Petitioner filed his first petition for a writ of habeas corpus, arguing that the judgment should be vacated because he had received constitutionally ineffective assistance of counsel. During the habeas proceedings, the Supreme Court found that Petitioner's trial counsel had defrauded Petitioner in order to induce Petitioner to retain him instead of the public defender. Counsel went on to commit serious errors during the penalty phase undermining the reliability of the death verdict. The Supreme Court granted the petition and ordered a new penalty phase trial. Petitioner later filed this petition for a writ of habeas corpus challenging his convictions. The Supreme Court granted the writ and vacated Defendant's conviction for first degree murder, holding that Petitioner was denied the effective assistance of counsel at the guilt phase of his trial. View "In re Gay" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree murder, finding Defendant was sane at the time of the crimes, and sentencing Defendant to death, but struck an improperly imposed restitution fine, holding that the restitution fine should be stricken from the abstract of judgment and that any other error was not prejudicial.The trial court imposed a $10,000 restitution fine but did not impose the fine at the sentencing hearing. Rather, the fine was later added to the abstract of judgment. The Supreme Court ordered the restitution fine stricken from the record and the minutes because the trial court never imposed the fine in open court in Defendant's presence. The Court assumed other errors during the trial proceedings but found no prejudice. Further, the Court held that the error regarding the restitution fine and any assumed error were not cumulatively prejudicial. View "People v. Frederickson" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and kidnapping and sentence of death, holding that Defendant was not entitled to relief.Specifically, the Court held (1) the superior court did not err in exercising its jurisdiction in this matter; (2) the trial court did not err in the voir dire proceedings; (3) Defendant's argument that there was a material variance between the kidnap alleged in the indictment and the prosecutor's argument regarding his actual offense was unavailing; (4) the trial court did not err in admitting Defendant's custodial confession; (5) the trial court did not err by compelling Defendant to testify as a foundation for testimony by Defendant's expert that his confession was false; (6) the trial court did not err by limiting expert witness testimony; (7) the trial court did not err by compelling Defendant to undergo a prosecution-conducted psychiatric examination; (8) the prosecutor did not commit misconduct during the guilt phase closing argument; (9) there was no instructional error; (10) there was sufficient evidence to support the kidnap-murder special circumstance; (11) Defendant's claims of prosecutorial misconduct during the penalty phase closing argument lacked merit; and (12) Defendant's remaining penalty phase claims were unavailing. View "People v. Hoyt" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of murder and one count of attempted murder and sentence of death for one murder and life imprisonment without the possibility of parole for the other murder, holding that there was no prejudicial error in the proceedings below.Specifically, the Court held (1) the trial court did not err in admitting Defendant's convictions because there was no basis to conclude Defendant's Miranda waiver was anything other than knowing, intelligent, and voluntary; (2) any error in instructing the jury was harmless; (3) Defendant's challenges to the constitutionality of California's death penalty scheme were unavailing; and (4) the potential errors in the instructions were harmless, and even considered together, the errors did not warrant reversal. View "People v. Leon" on Justia Law