Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of one count of willful, deliberate, and premeditated attempted murder and three counts of threatening to commit a crime resulting in death or great bodily injury. During trial, the court admitted certain out-of-court statements made by Defendant that formed the basis of the prosecution for making criminal threats. Defendant appealed, arguing that the trial court erred by not instructing the jury to consider Defendant’s out-of-court statements with caution, despite Defendant’s failure to request such an instruction. The Court of Appeal affirmed, concluding that any error in omitting the instruction was harmless in light of other instructions the jury received and the evidence presented. The Supreme Court affirmed, holding (1) the cautionary instruction is applicable when the out-of-court statements at issue are criminal threats, and the trial court is not required to give such an instruction sua sponte; and (2) the omission of the cautionary instruction in this case was harmless. View "People v. Diaz" on Justia Law

After four chemical tests were administered to Plaintiff revealing her blood-alcohol concentration to be between 0.08 to 0.096 percent, Plaintiff’s license was suspended, and she was charged with drunk driving. Plaintiff requested an administrative hearing. During the hearing, Plaintiff’s expert witness suggested her BAC was below the 0.08 percent threshold at the time Plaintiff was driving. The Department of Motor Vehicles, and later the trial court, discounted the expert testimony in part by relying on arrest reports, which described other circumstantial evidence of intoxication. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in rejecting the expert’s testimony and placing primary emphasis on the chemical tests showing that Plaintiff’s BAC met or exceeded the statutory threshold at the time she was driving; and (2) both the trial court and the DMV hearing officer reasonably relied on circumstantial evidence of Plaintiff’s intoxication to support the accuracy of the chemical tests and to reject the expert’s view of the evidence as unduly speculative. View "Coffey v. Shiomoto" on Justia Law

Defendant pleaded guilty to violating Cal. Ins. Code 11880(a) and admitted various enhancements. Defendant was sentenced to six years imprisonment. Approximately one and a half years into the sentence, the Secretary of the California Department of Corrections and Rehabilitation (CDCR) recommended that Defendant’s sentence be recalled pursuant to Cal. Penal Code 1170(e) and that he be granted compassionate release due to his medical condition. The trial court ultimately denied the CDCR’s recommendation to recall Defendant’s sentence, finding an insufficient basis for compassionate release under section 1170(e). The Court of Appeal dismissed Defendant’s appeal, finding that the trial court’s denial of the CDCR’s recommendation for compassionate release was a nonappealable order. The Supreme Court reversed, holding that Defendant’s appeal was authorized by Cal. Penal Code 1237(b). View "People v. Loper" on Justia Law

Defendant engaged in conduct that led to a charge of committing a lewd act on a child. The jury convicted Defendant of the lesser misdemeanor offense of simple assault. The sentencing court exercised its discretion to order Defendant to register as a sex offender. The order included registered sex offender residency restrictions imposed by Jessica’s Law. The Court of Appeal struck the order from Defendant’s conviction, concluding that the registration order was invalid under Apprendi v. New Jersey because the trial judge and not a jury made the predicate factual findings. The Supreme Court reversed, holding that Apprendi did not invalidate Defendant’s registration order, as (1) the post-Apprendi decision, Oregon v. Ice, stated that Apprendi has no application to sentencing decisions in which juries played no fact-finding role at common law; (2) the residency restrictions do not constitute a penalty for purposes of Apprendi; and (3) even if the residency restrictions of Jessica’s Law did require jury findings under Apprendi, there is no reason why the nonpunitive registration order should not survive in this case. View "People v. Mosley" on Justia Law

Petitioners in this consolidated habeas corpus proceeding were registered sex offenders on active parole in San Diego County against whom Cal. Pen. Code 3003.5(b) was applied. Section 3003.5(b) imposed mandatory residency restrictions against paroled registered sex offenders. The trial court concluded that the mandatory residency restrictions were unconstitutional as applied to all registered sex offenders on parole in San Diego County and enjoined enforcement of the statute in the county. The Court of Appeal affirmed. The Supreme Court affirmed, holding (1) section 3003.5(b)’s residency restrictions are unconstitutional as applied to petitioners and similarly situated registered sex offenders on parole in San Diego County; but (2) as the lower courts made clear, the California Department of Corrections and Rehabilitation retains the statutory authority to impose special restrictions on registered sex offenders, including residency restrictions, so long as they are based on the specific circumstances of each individual parolee. View "In re Taylor" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, first degree burglary, first degree robbery, and carjacking. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial judge’s failure to disqualify himself because of his relationship with the prosecutor did not violate Defendant’s constitutional rights; (2) the trial judge did not prejudicially err in denying Defendant’s motion to change venue; (3) the evidence was sufficient to support the carjacking conviction; (4) the trial court adequately instructed the jury regarding victim impact evidence; (5) the trial court did not err in its treatment of one of Defendant’s prior crimes; and (6) Defendant’s challenges to California’s death penalty law were without merit. View "People v. Johnson" on Justia Law

Defendant was convicted of three counts of gross vehicular manslaughter, one count each for the three persons who died in the incident. The trial court enhanced Defendant’s sentence for “personally inflicting great bodily injury” on a fourth victim, who was injured in the accident but survived. The Court of Appeal upheld the enhancement as to the surviving victim but reversed the enhancements as to the manslaughter victims, concluding generally that Defendant’s manslaughter conviction was subject to any great bodily injury enhancement. The Supreme Court reversed, holding that the sentence for manslaughter may not be enhanced for the infliction of great bodily injury as to anyone. View "People v. Cook" on Justia Law

Plaintiff was convicted of nonforcible oral copulation by an adult over twenty-one years with a person under sixteen years of age in violation of Cal. Penal Code 288a(b)(2). Plaintiff’s conviction resulted in mandatory sex offender registration under Cal. Penal Code 290. The Supreme Court subsequently issued its decision in People v. Hofsheier, which found an equal protection violation in section 290’s mandatory registration provision for a different subdivision of section 288a. Citing Hofsheier and its progeny, Plaintiff filed a petition for a writ of mandate in the superior court seeking his removal from the sex offender registry and relief from future registration obligations. The superior court denied the petition in reliance on People v. Manchel, a case that had rejected a Hofsheier claim by a defendant convicted of the same felony oral copulation offense at issue in this case. The Court of Appeal reversed, concluding that section 290’s registration requirement violated Plaintiff’s equal protection rights. The Supreme Court reversed, holding that Hofsheier’s constitutional analysis was faulty and therefore, Hofsheier is overruled. View "Johnson v. Dep’t of Justice" on Justia Law

After a jury trial, Defendant was convicted of one count of corporal injury on a spouse. The trial court placed Defendant on probation and, without objection, imposed various fees, including probation-related costs and an order for reimbursement of the fees paid to appointed trial counsel. On appeal, Defendant challenged the fees on the grounds that the trial court imposed the fees without making a finding of his ability to pay and that he was not advised of and did not waive his right to a court hearing on the probation supervision fee. The Supreme Court affirmed, holding (1) as established in the companion case of People v. Trujillo, the appellate forfeiture rule applies to challenges to fees imposed at sentencing; and (2) Defendant’s failure to object to the fees in the trial court precluded him from challenging the fees on appeal. View "People v. Aguilar" on Justia Law

After a jury trial, Defendant was found guilty of buying, receiving, concealing, or withholding stolen property. The trial court placed Defendant on probation and imposed probation supervision and presentence investigation fees. At trial, Defendant neither objected to the fees nor asserted an inability to pay them. The Court of Appeal reversed the order of payment and remanded with directions that the trial court follow the procedure prescribed in Cal. Penal Code 1203.1(b), which prescribes specific procedures for imposition of such fees. The Supreme Court reversed, holding (1) the appellate forfeiture rule applies in the context of an order that a defendant pay probation supervision and presentence investigation fees imposed under section 1203.1(b); and (2) Defendant, by her failure to object, was precluded from raising on appeal the issue of ability to pay the probation-related fees. View "People v. Trujillo" on Justia Law