Justia California Supreme Court Opinion Summaries

A private citizen called a 911 operator to report an incident of suspected child abuse during the child’s visit with his father. A deputy sheriff, who was dispatched to investigate the report, determined that the child was not a victim of child abuse. Neither the officer nor the Sheriff’s Department cross-reported the initial 911 report to the child welfare agency. Less than four weeks later, the child suffered extensive head injuries during a visit with his father. The child, through a guardian ad litem, sued the county and the deputy sheriff for failing to cross-report the initial child abuse allegations to the county child welfare agency, in violation of the Child Abuse and Neglect Reporting Act. The trial court granted summary judgment for Defendants. The Court of Appeal affirmed. The Supreme Court reversed in part and affirmed in part, holding (1) the Sheriff’s Department had a mandatory and ministerial duty to cross-report the child abuse allegations made to the 911 operator to the child welfare agency, and the failure to cross-report can support a finding of breach of a mandatory duty; but (2) the officer had no duty to report the child abuse allegations and her investigative findings to the child welfare agency. View "B.H. v. County of San Bernardino" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the delay in bringing charges against Defendant did not violate his due process rights; (2) the trial court did not commit prejudicial error in its evidentiary rulings during the guilt phase of trial; (3) the prosecutor did not commit misconduct during the guilt phase closing argument; (4) the trial court did not commit prejudicial error in its evidentiary rulings during the penalty phase of trial; (5) the trial court properly instructed the jury during the penalty phase; and (6) the remainder of Defendant’s claims have already been rejected by the Court. View "People v. Cordova" on Justia Law

After a jury trial, Defendant was convicted of violating Cal. Penal Code 451(b), which forbids arson of “an inhabited structure or inhabited property.” Specifically, the jury found Defendant guilty of “arson of an inhabited structure as charged.” The prosecution did not charge Defendant with arson of property, but the court instructed the jury on it. In accordance with the trial court’s instructions, the jury did not return a verdict on the lesser crimes, including arson of property. The Court of Appeal reversed, finding the evidence insufficient to sustain the conviction, which precludes retrial of that charge. The Supreme Court reversed, holding that, under the circumstances, the lesser offense of arson of property was prosecuted in a single proceeding along with the section 451(b) charge, and therefore, Cal. Penal Code 654, as interpreted in Kellett v. Superior Court, does not prohibit retrying Defendant for that lesser offense. View "People v. Goolsby" on Justia Law

Defendant was charged with attempted murder and assault with a firearm. The prosecution alleged that these offenses were committed for the benefit of a criminal street gang and were thus subject to a sentence enhancement under Cal. Penal Code 186.22(f). The jury convicted Defendant of the lesser included offense of attempted voluntary manslaughter and of assault with a firearm. The jury found true that Defendant committed the offenses for the benefit of a criminal street gang. The Court of Appeal sustained Defendant’s sentence enhancement under section 186.22. The Supreme Court reversed the judgment as to Defendant’s sentence, holding (1) section 186.22(f)’s definition of a “criminal street gang” - and, in particular, its requirement of an “ongoing organization, association, or group” - calls for evidence that an organizational or associational connection unites the group members; (2) where, as in this instance, the prosecution’s case positing the existence of a single criminal street gang turns on the existence of gang subsets, the prosecution must show some associational or organizational connection uniting those subsets and also that the gang those subsets comprise is the same gang the defendant sought to benefit; and (3) the decision below was not consistent with this standard. Remanded. View "People v. Prunty" on Justia Law

Defendants Orlando Gene Romero and Christopher Self were convicted of three counts of first-degree murder, four counts of premeditated attempted murder, and numerous other crimes. The trial court entered judgments of death. The Supreme Court (1) reversed Self’s conviction for the robbery of Albert Knoefler on the basis that the testimony of an accomplice that Self robbed Knoefler was not corroborated; (2) vacated five multiple-murder special-circumstance findings for each defendant, holding that the trial court erred in instructing the jury to make two multiple-murder special-circumstance findings as to each count of murder; and (3) otherwise affirmed the judgments, holding that no other prejudicial error occurred. View "People v. Romero" on Justia Law

After a jury trial, Defendant was convicted of attempted robbery and first degree murder, among other charges. The jury returned a verdict of death for the murder, and the trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion when it ordered the use of leg restraints during trial; (2) the trial court did not abuse its discretion in dismissing one juror during trial and another juror during deliberations; (3) the trial court did not err in instructing the jury; (4) the trial court’s responses to the jury’s requests for clarification regarding the law of conspiracy was not in error; (5) Defendant’s claim that the jury was coerced into reaching a verdict was without merit; (6) no prejudicial error occurred during the penalty phase; (7) Defendant’s challenge to California’s death penalty statute failed; and (8) Defendant’s claim that the trial court improperly imposed restitution without considering his ability to pay failed. View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. Defendant was sentenced to death for the murder. While this appeal was pending, the United States District Court for the Central District of California issued its opinion in Jones v. Chappell, which held that systemic delays in implementing the California death penalty law rendered it unconstitutional under the Eighth Amendment. The Supreme Court affirmed the guilt and penalty phase judgments in their entirety, holding (1) any evidentiary errors did not require reversal under either state law or federal law; (2) Defendant’s claim of judicial misconduct was forfeited for appeal; (3) certain of Defendant’s claims of prosecutorial misconduct during the guilt phase were forfeited, other prosecutorial misconduct claims were without merit, and while the prosecutor committed misconduct in other instances, the misconduct was harmless; (4) the jury instructions were not in error; (5) no prejudicial misconduct occurred during the penalty phase; (6) a Jones claim has not been proved here; and (7) Defendant’s constitutional challenges to California’s death penalty statute failed. View "People v. Seumanu" on Justia Law

In 1998, Defendant pleaded not guilty by reason of insanity (NGI) to one count of lewd and lascivious conduct with a child and was committed to Napa State Hospital. In 2011, the Santa Clara County District Attorney petitioned to extend Defendant’s commitment a fourth time. Defendant opposed an extension of his commitment, and defense counsel requested a bench trial. After a bench trial, the trial court entered an order extending Defendant’s commitment. The Supreme Court reversed, holding (1) the trial court must advise an NGI defendant personally of his or her right to a jury trial and, before holding a bench trial, must obtain a personal waiver of that right from the defendant unless the court finds that the defendant lacks the capacity to make a knowing and voluntary waiver, in which case defense counsel controls the waiver decision; and (2) the trial court in this case erred in conducting a bench trial that extended Defendant’s commitment because the court did not advise Defendant of his right to a jury trial, did not obtain Defendant’s personal waiver of that right, and did not find substantial evidence that Defendant lacked the capacity to make a knowing and voluntary waiver. Remanded. View "People v. Tran" on Justia Law

In 2006, Defendant was declared a mentally disordered offender and committed to Atascadero State Hospital as a condition of parole. In 2011, the Santa Clara County District Attorney filed a third petition to extend Defendant’s commitment. Defendant opposed an extension of his commitment, and defense counsel requested a bench trial. After a bench trial, the trial court extended Defendant’s commitment. Defendant appealed, arguing that the trial court committed prejudicial error by failing to advise him of the right to a jury trial and by conducting a bench trial without first obtaining his personal waiver of that right. The Supreme Court reversed, holding that the trial court erred in conducting a bench trial that extended Defendant’s commitment, as (1) the statutory scheme that governs mentally disordered offender commitment proceedings expressly provides for advisement and waiver of the right to a jury trial; and (2) the trial court did not advise Defendant of his right to a jury trial in this case, did not obtain Defendant’s personal waiver of that right, and did not find that Defendant lacked the capacity to make a knowing and voluntary waiver. Remanded. View "People v. Blackburn" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder and related charges. Defendant was sentenced to death for the murders. The Supreme Court struck the sentence enhancements under Cal. Penal Code 186.22(b)(1) from the sentences imposed for actively participating in a gang in counts 3, 5, 7, 10, and 14, and affirmed the judgment in all other respects, holding (1) no prejudicial error occurred with regard to Defendant’s convictions arising out of the murder of either victim; (2) no prejudicial error occurred with regard to Defendant’s conviction arising out of the shootings of two other individuals and the related charge of active participation in a gang on an aiding and abetting theory; (3) it was improper to add to each of Defendant’s convictions for the crime of gang participation a sentence enhancement for committing the crime for the benefit of a gang under section 186.22(b)(1); (4) no prejudicial error occurred during the guilt phase or penalty phase; (5) Defendant’s challenges to California’s death penalty law were without merit; and (6) no reversal was warranted due to the cumulative effect of nonprejudicial errors during guilt and penalty phase. View "People v. Nguyen" on Justia Law