Justia California Supreme Court Opinion Summaries

At issue in this case was whether Cal. Penal Code 1170.1(f) precludes a trial court from imposing both a firearm enhancement under Cal. Penal Code 12022.5, former subdivision (a)(1), and a gang enhancement under Cal. Penal Code 186.22(b)(1)(B), in connection with a single offense, when the offense is a “serious felony” under section 186.22(b)(1)(B) and involved the use of a firearm. Defendants Eric Hung Le and Down George Yang were convicted for their part of a street gang’s drive-by shooting. As to Defendant Yang’s conviction for assault with a semiautomatic firearm, the jury found true that Defendant committed the assault while personally using a firearm under former section 12022.5(a)(1) and committed the assault for the benefit of a street gang under section 186.22(b)(1).The trial court stayed any sentence enhancement under section 12022.5(a), concluding that it could not impose terms for both enhancements. The Court of Appeal affirmed. The Supreme Court affirmed, holding that because both enhancements depend upon a defendant’s firearm use, section 1170.1(f) bars the imposition of both enhancements. View "People v. Le" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, rape, and sodomy. Defendant also pleaded guilty to charges arising from separate burglaries committed after the charged murder. The trial court sentenced him to death. Defendant appealed, arguing, among other things, that the prosecutor violated Batson v. Kentucky and People v. Wheeler by peremptorily excusing two African American prospective jurors. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court correctly concluded that Defendant failed to make out a prima facie case of discrimination as to either strike; (2) the trial court did not abuse its discretion in denying Defendant’s pretrial motion to sever the homicide charges from the burglary charges; and (3) any remaining errors or assumed errors were not prejudicial. View "People v. Scott" on Justia Law

After a jury trial, Defendant was convicted of one count of first degree murder and two counts of second degree murder. There were four penalty trials in this case, and the fourth penalty trial jury returned a verdict of death. The trial court denied the automatic application to modify the verdict and sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted Defendant’s jailhouse letter under the adoptive admission exception to the hearsay rule; (2) prosecutorial misconduct did not require reversal of Defendant’s convictions and sentence; (3) the jury was properly instructed regarding motive, consciousness of guilt, and adoptive admissions; (4) the trial court did not abuse its discretion by granting the prosecution’s motion for a fourth penalty trial; (5) any error in the exclusion of testimony from Defendant’s relatives that his family did not wish to have the death penalty imposed on him was harmless; and (6) Defendant’s challenges to the death penalty failed. View "People v. Charles" on Justia Law

Before Gilton Pitre was paroled from state prison the State Department of Mental Health (DMH) assessed whether he should be civilly committed under the Sexually Violent Predators Act (SVPA). The DMH ultimately did not request a petition for commitment. Four days after Pitre was paroled, he raped and murdered Plaintiff’s fifteen-year-old sister. Plaintiff sued DMH and two of its acting directors (collectively, Defendants) claiming that her sister’s death was caused by Defendants’ failure to discharge a mandatory duty imposed by the SVPA. Defendants demurred, arguing that Plaintiff failed to state a cause of action and that they were immune from liability. The demurrer was overruled, and Defendants petitioned for a writ of mandate. The Court of Appeal directed the superior court to sustain the demurrer, concluding that the SVPA imposed a mandatory duty on Defendants but that Plaintiff could not establish that the breach of that duty was the proximate cause of her sister’s death. The Supreme Court affirmed, holding that the Court of Appeal did not err in its conclusions. View "State Dep’t of State Hosps. v. Superior Court" on Justia Law

After a jury trial in 1999, Defendant was convicted of first degree murder, second degree murder, and second degree robbery. Defendant stipulated to a 1971 prior second degree murder conviction alleged as a special circumstance. As to both murder counts, the jury found true the special-circumstance allegation of multiple murder. The trial court imposed a sentence of death that was supported by the multiple murder special-circumstance finding. The Supreme Court reversed the judgment of conviction for second degree murder and reversed the penalty judgment, holding (1) Defendant’s 1971 second degree murder conviction was obtained in violation of the double jeopardy clause, and therefore, this special-circumstance finding must be set aside; (2) the trial court erred by allowing the prosecution to refile the second degree murder charge, which had previously been dismissed; (3) the multiple murder special circumstance is vacated because it was based in part on the invalid second degree murder conviction; and (4) therefore, the judgment of death must be reversed. Remanded for resentencing. View "People v. Trujeque" on Justia Law

Defendant pleaded no contested in a negotiated disposition to felony hit and run. The plea agreement provided that Defendant would pay restitution directly to any victim. Defendant was later placed on probation and directed to pay fines and restitution in the amount of $12,465 for the victim’s medical expenses. The trial court reserved jurisdiction to determine the amount of additional restitution. The restitution hearing was continued several times, and Defendant’s term of probation eventually expired. The court determined that it had jurisdiction to order the full amount of restitution and confirmed that the restitution amount was $275,017. The Court of Appeal affirmed, holding that the trial court retained jurisdiction to award additional restitution without regard to the expiration of Defendant’s probation. The Supreme Court affirmed, holding that, by agreeing to a continuance of the restitution hearing to a date after his probationary term expired, Defendant impliedly consented to the trial court’s continued exercise of jurisdiction and was therefore estopped from challenging it. View "People v. Ford" on Justia Law

Defendant was charged with felony infliction of corporal injury in violation of Cal. Penal Code 273.5(a). The information further alleged that Defendant had suffered a prior conviction under section 273.5. At trial, Defendant stipulated to the prior conviction. The trial court accepted stipulation without advising Defendant of any trial rights or eliciting his waiver of those rights. A jury subsequently convicted Defendant of violating section 273.5(a) and found true the allegation that Defendant suffered a prior conviction. In light of the prior conviction, the trial court sentenced Defendant to a maximum term of five years. Defendant appealed, arguing that his stipulation to the prior conviction was invalid because it had the direct consequence of subjecting him to a longer prison term. The Court of Appeal affirmed the sentence. The Supreme Court reversed in part, holding that Defendant’s stipulation must be set aside, as (1) Defendant was entitled to be advised of his right to a fair determination of the truth of the prior conviction allegation; and (2) because the record did not affirmatively show that Defendant was aware of his right to a fair determination of the truth of the prior conviction allegation, Defendant’s stipulation must be set aside. View "People v. Cross" on Justia Law

After a jury trial, Defendant was convicted of the first degree murders of Mary Kopatz and Carley Kopatz. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress evidence of his videotaped interview with the police; (2) the trial court did not err in admitting a deceased witness’s prior consistent statement; (3) the victim impact evidence was neither unduly prejudicial nor so inflammatory that it invited the jury to make its penalty determination on a purely irrational basis; (4) Defendant was not prejudiced by a multiple-murder special-circumstance instruction and attendant verdict forms; and (5) Defendant’s challenges to the death penalty law failed. View "People v. Kopatz" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, with the special circumstance of torture, false imprisonment by violence, and conspiracy to commit murder. The jury recommended a sentence of death, and the trial court imposed that sentence. The Supreme Court affirmed the convictions but reversed the penalty judgment, holding that, during the penalty phase, the court violated Defendant’s federal constitutional rights to due process by excluding expert testimony about prison security measures for those sentenced to life without possibility of parole because Defendant was deprived of the opportunity to counter aggravating evidence and argument suggesting that he would be a dangerous life prisoner. View "People v. Smith" on Justia Law

Defendant, a second-strike offender, was convicted of eleven offenses arising from sexual assaults on two separate victims. At issue in this appeal was the trial court’s imposition of an alternative sentence under the One Strike law. The court sentenced Defendant to twenty-five years to life for each of his two rape convictions then doubled the minimum terms for the life sentences pursuant to the Three Strikes Law and added five-year prior serious felony enhancements to both. On the remaining counts, the court imposed determinate terms of seventeen years each - the sum of the middle term of six years, doubled pursuant to the Three Strikes Law - plus a five-year prior serious felony enhancement. Defendant’s alternative sentence totaled 229 years to life, which the court stayed in light its sentence original of 495 years to life. The Supreme Court granted review to determine whether the prior serious felony enhancement may be applied to the term imposed for each offense or only once to the determinate portion of the overall sentence. The Supreme Court vacated Defendant’s stayed sentence of 229 years to life and remanded for resentencing, holding that the prior serious felony enhancement may be added only once to multiple determinate terms imposed as part of a second-strike sentence. View "People v. Sasser" on Justia Law