Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder under the special circumstance of murder in the commission of robbery, attempted premeditated murder, and first degree residential robbery. The jury found true personal firearm-use allegations. The jury returned a verdict of death after a penalty trial, and the trial court imposed a judgment of death. The Supreme Court affirmed, holding (1) substantial evidence supported the trial court’s determination that the prosecutor’s stated reasons as to the exercise of peremptory challenges against three African-American prospective jurors were genuine and race neutral; (2) the trial court did not abuse its discretion in its evidentiary rulings; and (3) there was no reason to reconsider previous holdings regarding challenges to California’s death penalty law. View "People v. Melendez" on Justia Law

Financial Casualty & Surety, Inc. posted a bail bond on behalf of Oscar Grijalva. The bail was subsequently forfeited. Under Cal. Penal Code 1305, the bond would be exonerated if Grijalva appeared in court by the 185th day after the notice was mailed. Five days after the appearance period ended, Financial Casualty moved to extend the period under section 1305.4. The trial court granted an extension for fewer than 180 days. At the end of the extension period, Financial Casualty filed a second extension motion. The trial court denied the second extension motion and entered summary judgment on the bond. The court of appeal affirmed. The Supreme Court affirmed, holding (1) a trial court may weigh the likelihood of apprehension in deciding whether the surety has shown good cause for an extension; (2) because at the time Financial Casualty’s second extension motion was heard fewer than 180 days had passed since the first extension was ordered, the trial court had discretion to grant a further extension; and (3) the trial court did not abuse its discretion in considering, as grounds for denying the extension of the period for exonerating the bail bond, that Financial Casualty had not shown the requests extension was likely to produce Grijalva’s appearance in court. View "People v. Financial Casualty & Surety, Inc." on Justia Law

Defendant filed a motion to suppress the evidence found on his phone, arguing that the search of his phone resulted from an unduly prolonged and unjustified detention. The trial court denied the motion, concluding that the phone search was justified under the existing authority of People v. Diaz. The court of appeals affirmed, acknowledging that Diaz’s reasoning was repudiated in Riley v. California but determining that the good faith exception applied because Diaz was controlling law at the time. The Supreme Court reversed, holding (1) the phone search was conducted without a warrant and was improper; and (2) the good faith exception did not apply in this case because the search was not authorized by Diaz. View "People v. Macabeo" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. The jury returned a verdict of death, and the trial court entered the death judgment. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in denying Defendant’s motion for mistrial for discovery violations; (2) the prosecutor did not engage in prejudicial misconduct; (3) the trial court’s rulings regarding Defendant’s proffered third party culpability evidence were not in error; (4) the trial court did not abuse its discretion when it failed to exclude evidence of Defendant’s past uncharged incidents of sexual misconduct; (5) the trial court did not violate Defendant’s due process right to a fair trial in refusing to allow into evidence videotaped interviews of defense witnesses; (6) the trial court did not err in sustaining the prosecution’s objection to testimony that Defendant was alcohol dependent; (7) the trial court did not err in instructing the jury during the penalty phase; and (8) there was no constitutional violation of the state’s death penalty law. View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of both conspiracy to murder and the first-degree murder of her husband. The jury set the penalty at death after weighing aggravating and mitigating evidence presented by the parties. The Supreme Court affirmed the guilt and penalty judgments in their entirety, holding (1) the trial court’s determinations that seven jurors were all substantially impaired and subsequent exclusion of the jurors due to their views on the death penalty was adequately supported by the record; (2) the trial court did not err by denying Defendant’s motions to sever her trial from that of her codefendant; (3) the trial court did not commit reversible error in its rulings regarding several discovery issues; (4) the trial court did not err in its evidentiary rulings; (4) the jury instructions were proper; and (5) no prejudicial error occurred during the penalty phase of trial. View "People v. Thompson" on Justia Law

Petitioner was charged with robbery. Pursuant to a plea agreement, Petitioner pleaded guilty to grand theft from the person, a felony, and admitted a prior robbery conviction on condition that he receive a six-year prison sentence. The People, in return, dismissed the robbery charge. The electorate later enacted Proposition 47, which reduced the grand theft offense to a misdemeanor. Defendant filed a petition for recall of sentence, asking the trial court to resentence him as a misdemeanant. The trial court denied relief, concluding that reducing the sentence would deprive the People of the benefit of their plea bargain, and thus they should be permitted to rescind the plea and reinstate the original robbery charge. The Court of Appeal affirmed. The Supreme Court reversed, holding that the People were not entitled to set aside the plea agreement when Defendant sought to have his sentence recalled under Proposition 47. View "Harris v. Superior Court of Los Angeles County" on Justia Law

Petitioner, an inmate, filed a petition for writ of habeas corpus, alleging that he received ineffective assistance of counsel in his criminal proceedings. One week later, Petitioner asked the court clerk for the name of the judge assigned to his petition. Superior Court Judge John M. Thompson subsequently summarily denied Petitioner’s habeas corpus petition. Petitioner then filed a new petition for writ of habeas corpus, and, in addition, Petitioner alleged that he was denied his statutory right to peremptorily challenge Judge Thompson. The Court of Appeal issued a writ of mandate directing the superior court to reassign the assessment of Maas’s petition for writ of habeas corpus to a judge other than Judge Thompson. The Supreme Court affirmed, holding that a petitioner who requests the name of the judge assigned to examine his habeas corpus petition is entitled to notice of that assignment and is entitled to peremptorily challenge the assigned judge, so long as all of the procedural requirements of Cal. Civ. Proc. Code 170.6 have been satisfied. View "Maas v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder and related crimes. After the penalty phase of the trial, the jury returned a verdict of death. The Supreme Court reversed the judgment of death, remanded the matter for a new penalty determination and reconsideration of the question of a restitution fine under the currently applicable statute, and affirmed the judgment in all other respects, holding (1) no prejudicial error occurred during the guilt phase of trial; (2) the trial court erred in excusing a prospective juror for cause under Witt based solely on written questionnaire responses regarding his views on capital punishment, and therefore, the penalty judgment must be reversed for error under Wainwright v. Witt and Witherspoon v. Illinois; and (3) the question of Defendant’s restitution fine must be remanded for reconsideration because Defendant’s restitution fine was imposed pursuant to a statute that was subsequently repealed in its entirety and replaced by a statute lessening punishment. View "People v. Covarrubias" on Justia Law

Defendant was charged with criminal offenses. Defendant filed a renewed motion to suppress pursuant to Cal. Penal Code 1538.5(i). Judge Vincent Chiarello granted the renewed motion, and the case was dismissed at the People’s request. Thereafter, the People filed a new complaint alleging the same offenses. Defendant filed a motion to suppress, asserting that the proper venue for the motion was before Judge Chiarello pursuant to section 1538.5(p). The matter came before Judge Vanessa Zecher after Judge Jerome Nadler concluded that Judge Chiarello was not available. Judge Zecher denied Defendant’s motion. Defendant filed a renewed motion to suppress, arguing that Judge Chiarello should have heard the relitigated motion to suppress. The trial court concluded that a renewed motion to suppress under section 1538.5(i) was not the proper vehicle for setting aside Judge Zecher’s order. Defendant was found guilty of child pornography. The Court of Appeal affirmed. The Supreme Court reversed, holding (1) a trial court’s discretion to make determinations concerning the availability of judges must be exercised in a manner consistent with constraints imposed by section 1538.5(p); and (2) in this case, the trial court abused its discretion by not taking reasonable measures to ensure compliance with section 1538.5(p), and the error was prejudicial. View "People v. Rodriguez" on Justia Law

Defendant was charged by criminal complaint with unpermitted use of a suction dredge. Suction dredging is a technique used by miners to remove matter from the bottom of waterways, extract minerals, and return the residue to the water. Defendant demurred, arguing (1) state law aimed at environmental conservation effectively banned suction dredging in California, thereby preventing him from using the only commercially practicable method of extracting gold from his mining claim; and (2) because federal law promoted mining on federal land, the state’s contrary legislation should be preempted. The trial court overruled the demurrer. The Court of Appeal reversed and remanded for consideration of additional evidence and argument. The Supreme Court reversed, holding that Congress did not guarantee miners a right to mine immunized from exercises of the states’ police powers. View "People v. Rinehart" on Justia Law