Justia California Supreme Court Opinion Summaries

Petitioner was found not guilty by reason of insanity of killing his father in 1981. Petitioner was committed to state hospital for a period reflecting the maximum term for voluntary manslaughter. In 2012, the district attorney petitioned to extend Petitioner’s commitment under Cal. Pen. Code 1026.5, which allows the commitment of a person found not guilty of a felony by reason of insanity to be extended for longer than the maximum prison sentence for the offense if, because of a mental disorder, the person represents a substantial danger to others. Petitioner filed a motion in limine to preclude his compelled testimony as a witness for the People. The trial court denied the motion. The Court of Appeal granted Petitioner’s petition for writ of mandate, concluding that section 1026.5(b)(7) unambiguously provided commitment extension respondents the right not to testify. The Supreme Court affirmed, holding that a person facing extended commitment has the right to testify at his or her not guilty by reason of insanity commitment extension hearing. View "Hudec v. Superior Court" on Justia Law

After a jury trial, Appellant was convicted of one count of murder with burglary and robbery special circumstances and other offenses. The trial court sentenced Defendant to death for the murder. The Supreme Court affirmed, holding that no prejudicial error occurred during the pretrial phase, the guilt phase, or the penalty phase. The dissent disagreed, remarking that the trial court abused its discretion in excluding certain out-of-court hearsay statements on the basis that any error was harmless beyond a reasonable doubt as to the guilt and penalty verdicts where the Attorney General did not argue that any error in the exclusion of the hearsay statements was harmless. View "People v. Grimes" on Justia Law

Petitioner was charged with three counts of first degree murder and related charges. Petitioner filed a motion to recuse the lead prosecutor on the case on grounds that the prosecutor allegedly knew one of the victims in the case, that two of the prosecutor’s adult children knew Petitioner and would be called as witnesses by the defense at the penalty phase if Petitioner was found guilty, and that the prosecutor’s daughter dated Petitioner’s friend, a proposed prosecution and defense penalty phase witness. The trial court denied Petitioner’s request for an evidentiary hearing and denied his motion to recuse the prosecutor. The Supreme Court reversed, holding that the trial court abused its discretion by denying Petitioner’s request for an evidentiary hearing on the ground that Petitioner had failed to make a prima facie showing that recusal was warranted, as a hearing was necessary to determine whether the conflict in this case would render it unlikely that Petitioner would receive a fair trial if the prosecutor was not recused as lead prosecutor in the case. View "Packer v. Superior Court" on Justia Law

After a jury trial, Defendants were convicted of kidnapping, first degree murder, and torture. Defendants filed a motion for new trial, asserting that that the jurors improperly discussed and considered during their deliberations Defendants’ decisions not to testify. The Court of Appeal reversed the convictions and ordered a new trial, concluding that the discussion of Defendants’ decisions not to testify constituted misconduct and the misconduct was categorically prejudicial, even assuming the foreperson had promptly and correctly reminded the jury of the court’s instructions to disregard Defendants’ decisions not to testify. The Supreme Court reversed, holding that the Court of Appeal erred in finding the presumption of prejudice could not be rebutted even if the jurors had been reminded of the court’s instructions not to consider that issue and no objective evidence indicted the reminder would have been ineffective. Remanded to the trial court to determine the nature and scope of the misconduct and the existence and timing of any reminder of the court’s instructions to disregard Defendants’ decisions not to testify. View "People v. Lavender" on Justia Law

After a jury trial, Defendant was convicted of two counts of committing lewd acts on a child under the age of fourteen and one misdemeanor count of annoying or molesting a child under the age of eighteen. During trial, the prosecutor used a diagram showing the boundaries of California to illustrate the standard of proof and urged the jury to convict based on a “reasonable” view of the evidence. Defense counsel did not object to the prosecutor’s argument. The Supreme Court reversed, holding (1) there was a reasonable probability that the prosecutor’s argument caused one or more jurors to convict Defendant based on a lesser standard than proof beyond a reasonable doubt; and (2) defense counsel’s failure to object to the alleged prosecutorial misconduct violated Defendant’s constitutional right to the effective assistance of counsel. View "People v. Centeno" on Justia Law

After a jury trial, Defendant, a member of a violent criminal street gang, was convicted of the murders of two of his fellow gang members even though he neither personally killed them nor desired their deaths. Defendant was convicted of the murders on the theory that he aided and abetted the persons who actually shot the victims in committing the target crimes of disturbing the peace and assault or battery and that the murders were “a natural and probable consequence” of the target crimes. The court of appeal affirmed the murder convictions. The Supreme Court affirmed, holding that, under the peculiar circumstances of this case, a reasonable jury could find that Defendant aided and abetted the target offenses and that defendant was guilty of the nontarget murders because they were the natural and probable consequence of the target offenses. View "People v. Smith" on Justia Law

In 1996, Petitioner was convicted of making a criminal threat and sentenced to a total term of twenty-five years to life pursuant to the Three Strikes Law. In 2012, Petitioner filed a petition for recall of his sentence, arguing that he was eligible for resentencing because his current offense of making a criminal threat had not been categorized as a serious felony at the time of his original conviction. The trial court denied the petition, finding that Petitioner was ineligible because his current offense was now defined as a serious felony. Petitioner appealed. The Court of Appeal treated Petitioner’s appeal as a petition for writ of mandate and denied the petition, concluding that the trial court’s denial of the petition for recall was not appealable because the trial court’s threshold eligibility determination was not a postjudgment order affecting Petitioner’s substantial rights. The Supreme Court reversed, holding that the trial court’s denial of the petition for recall was an appealable order, and the court of appeal erred in holding otherwise. View "Teal v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of two counts of conspiracy. Based on the insufficiency of the evidence, the trial court granted Defendant’s motion for a new trial and dismissed the two conspiracy counts. The court of appeal reversed, reinstated the jury’s verdict, and ordered that the trial court, upon remittitur issuance, could consider Defendant’s remaining grounds for a new trial but that double jeopardy protections prevented Defendant from being retried. The Supreme Court reversed the judgment of the court of appeal to the extent that it barred Defendant from being retried, holding that, if the trial court grants Defendant a new trial on any of his remaining claims, he may be retried. View "People v. Eroshevich" on Justia Law

After a jury trial, Defendant was convicted of three counts of first-degree murder, attempted murder, and carjacking. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no prosecutorial misconduct during the guilt phase, and any improper conduct by the prosecutor during the penalty phase was not prejudicial; (2) there was no error in the jury instructions; (3) the admission of Defendant’s uncharged violent criminal conduct was relevant to the jury’s penalty determination and did not render Defendant’s trial constitutionally unfair; (4) there was no cumulative effect of error requiring reversal of the judgment; and (5) Defendant’s challenges to the death penalty failed. View "People v. Adams" on Justia Law

Defendant was charged with oral copulation of an unconscious person (count 1) and oral copulation of an intoxicated person (count 2), based on the same act. A jury convicted Defendant of both charges. The court of appeal vacated the conviction on count 2 upon its understanding that the Supreme Court’s decision in People v. Craig precluded multiple convictions under these circumstances. The Supreme Court reversed, holding (1) Craig is distinguishable; and (2) Defendant may properly be convicted of, although not punished for, both oral copulation of an unconscious person and oral copulation of an intoxicated person. View "People v. Gonzalez" on Justia Law