Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first degree murder, kidnapping during the commission of a carjacking, carjacking, and being a felon in possession of a firearm. After the penalty phase, the trial court sentenced Defendant to death. The Supreme Court reversed the carjacking conviction and stayed the sentence of kidnapping during the commission of a carjacking but affirmed the judgment in all other respects, including the death sentence, holding (1) because carjacking is a necessarily lesser included offense of kidnapping during a carjacking, Defendant’s conviction and sentence for carjacking could not stand; and (2) Cal. Penal Code 654 required staying of the kidnapping during a carjacking conviction. View "People v. Montes" on Justia Law

In 2006, Culver City installed a red light camera at a certain intersection. In 2008, that camera photographed a car registered to Defendant driving through a red traffic light. Defendant was subsequently convicted of violating the red light traffic law. On appeal, Defendant argued that the City had failed to comply with Cal. Veh. Code 21455.5(b)’s requirements of a public announcement and a thirty-day period of warning notices with respect to the camera that recorded his traffic violation. At issue was whether the statutory requirements pertained only to the City’s first installation of an automated traffic enforcement device or also to each later installation of such devices at different intersections within the City.The Supreme Court affirmed, holding (1) the public announcement and warning requirements apply to each installation of such a device; but (2) compliance with the statute’s requirement of a thirty-day period of warning notices is not a precondition to issuing a valid citation for a red light traffic law violation, and therefore, the court of appeals correctly upheld Defendant’s conviction. View "People v. Gray" on Justia Law

After a jury trial, Defendant was convicted of the first degree murder of her husband under the special circumstances of murder by administering poison and murder for financial gain. At the penalty trial, the prosecution presented evidence that Defendant had murdered her infant daughter several years previously. The jury returned a verdict of death, and the trial court imposed that sentence. On appeal, Defendant raised allegations of error regarding primarily pretrial events, guilt trial issues, and penalty issues. The Supreme Court affirmed the judgment, holding that the circuit court did not reversibly err in its rulings and that Defendant was not deprived of a fair trial in this case. View "People v. Rodriguez" on Justia Law

Under California law, unlawfully carrying a concealed firearm and unlawfully carrying a loaded firearm in public are generally misdemeanors but become felonies when committed by an active participant in a criminal street gang, as defined in Cal. Penal Code 186.22(a). At issue in this case was whether possession of a firearm by a felon, a felony, constitutes “felonious criminal conduct” within the meaning of Cal. Pen. Code 186.22 so as to elevate to felonies the misdemeanor offenses of carrying that concealed firearm and carrying that loaded firearm in public. Defendant in this case was indicted on multiple firearm charges. Defendant argued that a violation of former Cal. Penal Code 12021(a)(1) may not be used to elevate the misdemeanor gun offenses charged in this case to felonies because “the same act of gun possession” cannot be used “to both establish the substantive gang charge and elevate the two otherwise misdemeanor gun offenses to felony gun offenses.” The Supreme Court affirmed the court of appeal, holding that possession of a firearm by a felon does qualify as “felonious criminal conduct.” View "People v. Infante" on Justia Law

Defendant was a life inmate. In 2005, the Board of Parole Hearings denied Defendant parole for the ninth time. The superior court ordered a new parole hearing, and in 2008, the Board found Defendant suitable for parole. In 2009, the Governor reversed the grant of parole. Defendant filed a petition for writ of habeas corpus, challenging the reversal. While the petition was pending, the Board again found Defendant suitable for parole. The Governor did not review the second decision. Defendant was released from prison subject to a maximum five-year parole term under the relevant statute. The superior court subsequently found that the Board and Governor had acted unlawfully in denying Defendant parole and ordered that he receive credit against his parole term for the period he spent in prison following the Board’s deficient 2005 suitability finding. The court of appeal modified the order to provide credit only for the year-long period between the Governor’s 2009 reversal and Defendant’s release on parole. The Supreme Court affirmed, holding that Defendant was not entitled to credit against his parole term for the time he spent in prison between the Governor’s erroneous reversal and his eventual release. View "In re Lira" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder with robbery and multiple-murder special circumstances and sentenced to death. On appeal, the Supreme Court affirmed the judgment in its entirety, holding (1) no error occurred during the selection of the jury; (2) the trial court did not err in its evidentiary rulings; (3) changes in the composition of the jury did not violate Defendants rights to trial by an impartial jury; (4) the trial court did not err in instructing the jury; (5) no error occurred during the penalty phase of the trial; and (6) the aspects of California’s death penalty Defendant challenged did not render it unconstitutional. View "People v. Duff" on Justia Law

After a jury trial, Defendant was convicted of lewd conduct. Defendant appealed, arguing that the trial court had a sua sponte duty to instruct the jury on battery as a lesser and necessarily included offense of lewd conduct. The court of appeal affirmed the judgment. The Supreme Court affirmed the court of appeal, holding (1) battery is not a lesser included offense of lewd conduct; (2) accordingly, if only lewd conduct is charged, the trial court has no duty to instruct on battery as a lesser included offense; and (3) therefore, the trial court in this case did not err in its judgment. View "People v. Shockley" on Justia Law

Jeffrey Burum and James Erwin were charged with aiding and abetting the receipt of bribes by members of a County Board of Supervisors and with conspiring with the supervisors to have them accept the bribes. The People's theory was that Burum, the payor of the bribes, and Erwin, who acted as Burum's agent, used threats and coercion to encourage the Supervisors to accept the illegal payments. Defendants demurred to all of the counts against them. The trial court sustained the demurrers in part. The court of appeals affirmed in part, concluding (1) the payor of a bribe, as a matter of law, cannot aid and abet the receipt of the same bribe or conspire to commit that offense; and (2) the payor's agent stood in the payor's shoes. The Supreme Court reversed, holding (1) the status of being the offeror or payor of a bribe does not disqualify that person, as a matter of law, from complicity in the offense of receiving the bribe; and (2) being the offeror or payor of a bribe does not disqualify that person, as a matter of law, from culpability for participating in a conspiracy to accept that same bribe. View "People v. Biane" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder and related crimes. Following a penalty phase trial, the jury returned a verdict of death. The Supreme Court affirmed the judgment, holding, among other things, that (1) Defendant's rights to a speedy trial were not violated; (2) Defendant's Sixth Amendment rights of self-representation and to the assistance conflict-free counsel were not violated during trial; (3) the prosecution did not violate Defendant's due process rights under Brady v. Maryland; (4) the trial court did not improperly admit "inflammatory and damning evidence" that compromised Defendant's ability to receive a fair trial; (5) the prosecutor did not engage in improper misconduct; and (6) the trial court did not prejudicially err in its penalty phase rulings. View "People v. Williams" on Justia Law

Michael Garcia received special education services during his school years. Before Garcia turned sixteen, he was arrested on felony charges and transferred to the Los Angeles County Jail to await trial. At that point, Garcia stopped receiving special education services. The issue of whether Garcia was entitled to special education services in the county jail was raised in several proceedings, including an action before the Office of Administrative Hearings, Special Education Division (OAH). The OAH concluded that Cal. Educ. Code 56041 applied, and because Garcia's mother resided within the boundaries of the Los Angeles Unified School District (L.A. Unified), L.A. Unified was responsible for Garcia's special education while he was incarcerated in county jail. L.A. Unified sought relief from the OAH's decision with the federal district court, which affirmed. On appeal, the court of appeals asked the California Supreme Court to decide a question of state law. The Supreme Court answered that Cal. Educ. Code 56041 - which provides generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for special education services - affixes responsibility for providing special education to a qualifying individual who is incarcerated in a county jail. View "Los Angeles Unified Sch. Dist. v. Garcia" on Justia Law