Justia California Supreme Court Opinion Summaries

Penal Code section 4019 has offered prisoners in local custody the opportunity to earn conduct credit against their sentences for good behavior. For eight months during 2010, a now-superseded version of section 4019 that was enacted during a state fiscal emergency temporarily increased the rate at which local prisoners could earn conduct credits. At issue was whether this former statute retroactively benefited prisoners who served time in local custody before January 25, 2010, the date on which it became operative. The court held that former section 4019 applied prospectively, meaning that qualified persons in local custody first became eligible to earn credit for good behavior at the increased rate beginning on the statute's operative date. The court also held that the equal protection clauses of the federal and state constitutions did not require retroactive application. View "People v. Brown" on Justia Law

This case arose when petitioner filed a petition for writ of mandate in the Lassen Superior Court, seeking to require the prison to process four administrative appeals of grievances that he had filed. At issue was whether a court commissioner had the authority to summarily deny a petition for writ of mandamus or habeas corpus under Code of Civil Procedure section 259, subdivision (a), which authorized commissioners to hear and determine ex parte motions for orders and alternative writs and writs of habeas corpus. The court concluded that section 259(a) did grant this authority to commissioners and that, at least when the petition sought to enforce a prisoner's rights while in confinement - but did not seek to collaterally attack the criminal conviction that provided the basis for that confinement - the summary denial of a writ petition constituted a subordinate judicial duty properly undertaken by a commissioner within the meaning of article VI, section 22 of the California Constitution. View "Gomez v. Super. Ct." on Justia Law

A jury convicted defendant of first degree murder and found true the special circumstance allegations of lying in wait and the intentional infliction of torture. At the second penalty retrial, defendant was sentenced to death. On automatic appeal, the court considered jury selection issues; pretrial issues regarding the penalty phase; guilt phase issues; and penalty phase issues. The court rejected nearly all of defendant's claims of error and where it found no error, it determined that defendant was not prejudiced. Accordingly, the court affirmed the judgment. View "People v. Streeter" on Justia Law

Defendant was charged in a felony complaint with attempted first degree burglary of an inhabited dwelling and second degree burglary of an automobile. At issue was whether a person standing in the driveway of a residence who used a remote control to open a motorized garage door had entered the residence within the meaning of the burglary statute. The court held that using a remote control to open a garage door did not constitute an entry into the residence. On these facts, defendant could be charged with attempted burglary but he could not be charged with a completed burglary. View "Magness v. Super. Ct." on Justia Law

Defendant pleaded no contest to attempted murder with a street-gang enhancement and to second degree robbery in exchange for a 17-year prison term and dismissal of other allegations. At issue was whether the imposition of a mandatory restitution fine violated a defendant's plea agreement where the parties failed to make the fine an express term of the agreement and where the trial court failed to mention the fine during the colloquy. Because the amount of defendant's restitution fine was either made a part of his plea nor otherwise specified in the plea colloquy, the court concluded that it was left to the trial court's discretion. Accordingly, the court affirmed the court of appeal's judgment because it reached the same conclusion. View "People v. Villalobos" on Justia Law

Defendant, a gang member and convicted felon, shot a victim and was convicted of and punished for assault with a firearm, possession of a firearm by a felon, and actively participating in a criminal street gang. The court held that Penal Code 654 did not permit punishment for defendant's gang crimes in addition to his punishments for assault with a firearm and possession of a firearm by a felon. Accordingly, defendant's two eight-month sentences for his two convictions for committing the assault for the benefit of the gang, section 186.22, must be stayed. In all other respects, the judgment of the court of appeal was affirmed. View "People v. Mesa" on Justia Law

Petitioner was charged with several felonies, including murder with special circumstances. At issue was whether Penal Code 1054.3(b)(1) extended to a defendant who had pleaded not guilty by reason of insanity (NGI) and proposed to call a mental health expert on the issue of sanity. The court concluded that section 1054.3(b)(1) did not apply in these circumstances. By its terms, the statute authorized an order compelling examination by a prosecution-retained expert "whenever... at any phase of the criminal action" the defense has proposed its own expert testimony on mental state, "[u]nless otherwise specifically addressed by an existing provision of law." Penal Code 1027, which governed the adjudication of an NGI plea, specifically addressed defendant's examination by court-appointed experts, but not by prosecution-retained experts, the subject of section 1054(b)(1). Therefore, the exception in section 1054(b)(1) did not pertain, and that statute as a whole applied. View "Sharp v. Super. Ct. of Ventura Cty" on Justia Law

Defendant was sentenced to death after being convicted of the first degree murders of three victims and the attempted premeditated murders of two other victims. Defendant's appeal was automatic and the court addressed issues related to the guilt phase and the penalty phase of trial. The court held that the $10,000 restitution fine was stricken and the amounts awarded to the victim/witness compensation program were stricken. The restitution orders were modified to award Alice Arnold $3,440.67 in victim restitution and to award the victim/witness compensation program $8,678.73 in victim restitution. As so modified, the judgment was affirmed. View "People v. Souza" on Justia Law

Defendant was convicted of two counts of assault with a deadly weapon and of carrying a concealed dirk or dagger. At issue was when a trial court denied a defendant's motion for a physical lineup and the defendant did not seek review of that ruling, was the defendant barred from the issue on postjudgment appeal. The court of appeal said yes, reasoning that a failure to challenge the ruling by writ undermined the purpose of the lineup right conferred under Evans v. Superior Court. In the alternative, the court of appeals assumed the issue was preserved and that the trial court erred, but that any error was harmless. The court held that the court of appeal erred in holding that defendant forfeited his right to appeal the denial of his lineup motion by failing to pursue writ relief. However, that court correctly concluded that the trial court's error, if any, was harmless. Accordingly, the court affirmed the judgment. View "People v. Mena" on Justia Law

Defendant was convicted of first degree murder of his elderly neighbor and the jury found true the three special circumstance allegations that the murder took place during the commission of rape, sodomy, and burglary. Defendant was additionally convicted of arson and the jury found true various sentencing enhancements. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment in its entirety. With respect to the abstract of judgment, however, the court ordered that it be corrected to conform to the trial court's oral judgment pronounced as to count II (arson) of an indeterminate term of 25 years of life, with an additional determinate term of five years. View "People v. Jones" on Justia Law