Justia California Supreme Court Opinion Summaries

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

In January 1992, J. Sacramento Benitez was killed during a residential burglary and attempted robbery. Luis Ramon Manzano Arellano and two co-defendants were charged with murder, attempted robbery, and first-degree burglary, with firearm use enhancements. Arellano pled guilty to second-degree murder under conditions that included striking the firearm enhancement and dismissing the robbery and burglary charges. He was sentenced to 15 years to life.The Santa Clara County Superior Court received Arellano's petition for resentencing under Penal Code section 1172.6 in October 2020. The district attorney initially opposed but later stipulated to resentencing. The court vacated Arellano's murder conviction and set a hearing to redesignate the charge. The trial court agreed to redesignate the conviction as attempted robbery with a firearm enhancement, despite defense objections that the enhancement was neither admitted nor found true by a jury.The California Court of Appeal reversed the trial court's decision, ruling that the firearm enhancement could not be imposed because it was not proven or admitted. The court held that section 1172.6 does not allow for the imposition of uncharged and unproven enhancements during resentencing.The Supreme Court of California affirmed the Court of Appeal's judgment, holding that section 1172.6, subdivision (e) does not permit a court to impose a sentencing enhancement unless it was pled and proven or admitted by the defendant. The court emphasized that the resentencing procedure is limited to the target offense or underlying felony and does not include uncharged and unproven enhancements. The Supreme Court also reversed the Court of Appeal's order for a remand to reconsider the redesignated conviction, as the trial court had already considered and chosen not to redesignate the underlying felony as burglary. View "People v. Arellano" on Justia Law

The case involves Nicholas Needham, who was referred for evaluation as a possible Sexually Violent Predator (SVP) under the Sexually Violent Predator Act (SVPA) after serving his prison term for certain sex offenses. Two evaluators initially determined that Needham had a mental disorder making him likely to engage in sexual violence unless civilly committed. However, before the probable cause hearing, one evaluator changed his opinion, leading to the appointment of two other evaluators. One of these evaluators concluded that Needham qualified as an SVP, while the other did not. The trial court found probable cause to believe Needham was an SVP and ordered a trial.The People retained Dr. Craig King as an expert and sought discovery of Needham's evaluations and records. The trial court granted the request and ruled that Dr. King could interview and test Needham. Needham filed motions to preclude Dr. King from testifying at trial, which were denied. Needham sought a writ of mandate/prohibition to prevent Dr. King from conducting any further interviewing or testing and from testifying at trial. The Court of Appeal granted Needham's writ petition and directed the trial court to exclude Dr. King's testimony. The People petitioned for review from that ruling.The Supreme Court of California held that, under the SVPA, the People may call their retained expert to testify at trial, both to contest the testimony of other witnesses and to offer an independent opinion as to whether the defendant qualifies as an SVP. However, the People's retained expert may not compel a defendant to be interviewed or participate in testing before trial. The court reversed the Court of Appeal's contrary judgment and remanded the case for trial. View "Needham v. Superior Court" on Justia Law

The case involves John Harris, Jr., who was charged with attempted first degree murder and aggravated mayhem related to a violent rape committed over 30 years ago. The charges were based on a DNA match between Harris and evidence from the crime scene. The prosecution sought to detain Harris without bail under a provision of the California Constitution (article I, section 12(b)) that allows for pretrial detention without bail for certain violent felonies, if there is clear and convincing evidence that the person's release would result in great bodily harm to others.The trial court denied Harris's bail, relying on a proffer by the prosecution that included hearsay evidence and documents without the full evidentiary foundation required at trial. Harris challenged this decision, arguing that only evidence admissible at a criminal trial could support pretrial detention without bail.The Court of Appeal rejected Harris's argument but conditionally vacated the order denying bail and remanded the matter to the trial court for further findings, because the trial court failed to consider less restrictive alternatives to detention.The Supreme Court of California held that a trial court may consider reliable proffered evidence in making factual findings under article I, section 12(b) without violating due process principles. However, the court remanded the case to the trial court to apply the standards discussed in its opinion and to consider less restrictive alternatives to detention. View "In re Harris" on Justia Law

In the case of The People v. Giles Albert Nadey, Jr., the defendant was convicted of one count of unlawful sodomy and one count of first-degree murder for the killing of Terena Fermenick. The jury found that both offenses were committed with the use of a knife and the murder occurred during the commission of unlawful sodomy. After the first jury deadlocked on penalty, a second jury returned a verdict of death. The Supreme Court of California affirmed the judgment.The case revolved around the murder of Terena Fermenick, who was sexually assaulted and killed. The defendant, Giles Albert Nadey, Jr., was a carpet cleaner who had been assigned to clean the carpets at the Fermenick's new home on the day of the murder. The prosecution's evidence included DNA evidence linking Nadey to the crime, as well as testimony from various witnesses.In the lower courts, Nadey was convicted of the charges and sentenced to death. His appeal to the Supreme Court of California was automatic due to the death sentence.In the Supreme Court of California, Nadey's conviction and sentence were affirmed. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also rejected Nadey's claims of legal error and prosecutorial misconduct. The court held that the prosecutor's comments during closing arguments were not improper and did not prejudice Nadey's right to a fair trial. The court also found that the trial court did not err in admitting certain evidence or in its handling of jury instructions. View "P. v. Nadey" on Justia Law