Justia California Supreme Court Opinion Summaries

Defendant was convicted by a jury of a petty theft offense, but admitted a prior felony conviction. Defendant appealed only the admission of the prior conviction. At issue was whether Penal Code section 1237.5 applied under these circumstances. The court held that People v. Fulton erroneously determined that section 1237.5 applied to appeals where the defendant had not pleaded guilty or nolo contendere. The court also held that section 1237.5's underlying purpose of promoting economy would not be advanced by extending it to convictions after pleas of not guilty. Accordingly, the court reversed the Court of Appeal and remanded for further proceedings. View "People v. Maultsby" on Justia Law

Petitioner was convicted of second degree murder committed in 1987, and was sentenced to a term of 15 years to life in prison with a two-year enhancement for firearm use. At issue was whether a majority of Division One of the Fourth District Court of Appeal properly applied the "some evidence" standard to a decision denying parole for petitioner. The court concluded that the Court of Appeal majority had again invaded the province of the parole authority, in this case the Board of Parole Hearings. The court also offered general guidance to the Courts of Appeal on inmates' lack of insight as a parole unsuitability factor. View "In re Shaputis" on Justia Law

Defendant was convicted of assault with a firearm and the jury found true two sentence enhancement allegations as to that crime: personal use of a firearm and personal infliction of great bodily injury. At issue was the relevance, if any, of Penal Code section 654. The court concluded that, in this case, the relevant specific statute, section 1170.1, permitted the court to impose both one weapon enhancement and one great-bodily-injury enhancement. Accordingly, the trial court properly imposed both enhancements. Because the specific statute provided the answer, the court did not turn to section 654. Accordingly, the court reversed the judgment of the Court of Appeal and remanded for further proceedings. View "People v. Ahmed" on Justia Law

Defendant was convicted of four counts of first degree murder when she shot and killed her four young children. A jury found true as to each murder the special circumstance allegation that defendant had committed multiple murders and defendant personally used a firearm in the commission of the murders. After a penalty trial, the jury returned a verdict of death and this appeal was automatic. The court reviewed pretrial, guilt phase, and penalty phase claims. Having found only minor harmless errors during defendant's trial, the court rejected defendant's claim of cumulative effect. The court also rejected defendant's challenges as to her sentence. Accordingly, the judgment was affirmed. View "People v. Eubanks" on Justia Law

The juvenile court committed a juvenile ward to the Department of Corrections and Rehabilitation, Division of Juvenile Facilities (DJF) based on his commission of a sex offense listed in Penal Code section 290.008(c). At issue was whether a court could commit to the DJF a juvenile who had not committed an offense described in Welf. & Inst. Code, 707(b). The court concluded that a juvenile court lacked authority to commit a ward to the DJF under Welf. & Inst. Code, 731(a)(4) if that ward had never been adjudged to have committed an offense described in section 707(b), even if his or her most recent offense alleged in a petition and admitted or found true by the juvenile court was a sex offense set forth in section 290.008(c) as referenced in Welf. & Inst. Code, 733(c). Accordingly, the court reversed the judgment of the Court of Appeal. View "In re C.H." on Justia Law

A jury charged codefendants, Michael Allen and Cleamon Johnson, of the first degree murders of two victims, with multiple-murder special-circumstance findings as to both. After Allen waived his right to a jury trial, the court found that he had previously been convicted of first degree murder. The jury returned verdicts of death for both defendants. During the guilt phase deliberations, two jurors reported their concern that another juror had made up his mind before the case was submitted to the jury. After speaking with all panel members, the trial court discharged that juror for having prejudged the case, and for having relied on evidence not presented at trial. The court held that because the record did not show to a demonstrable reality that Juror No. 11 was unable to discharge his duty, the court abused its discretion by removing him. Accordingly, both guilt and penalty phase judgments must be reversed. In view of the disposition, the court need not address defendants' remaining claims. View "People v. Allen & Johnson" on Justia Law

Pursuant to a plea bargain, defendant pleaded guilty to cultivation of marijuana and admitted to having suffered a prior conviction and having violated probation in two other cases. At issue was under what circumstances was a trial court obligated to conduct a hearing on whether to discharge counsel and appoint new counsel when a criminal defendant indicated a desire to withdraw a guilty or no contest plea on the ground that current counsel had provided ineffective assistance. The court concluded that a trial court must conduct a People v. Marsden hearing only when there was at least some clear indication by defendant, either personally or through counsel, that defendant wanted a substitute attorney. The court also held that, if a defendant requested substitute counsel and made a showing during a Marsden hearing that the right to counsel had been substantially impaired, substitute counsel must be appointed as attorney of record for all purposes. In so holding, the court specifically disapproved of the procedure of appointing substitute or "conflict" counsel solely to evaluate a defendant's complaint that his attorney acted incompetently with respect to advice regarding the entry of a guilty or no contest plea. Accordingly, the court affirmed the judgment of the Court of Appeals, which reversed the judgment of the trial court and remanded the matter to that court with instructions. View "People v. Sanchez" on Justia Law

Defendant was convicted of oral copulation in a local detention facility and of the first degree murder of a fellow inmate. The jury found true the special circumstance allegations of murder while engaged in the attempted commission of oral copulation and, in a separate proceeding, of a prior conviction of murder, returning a death verdict. On automatic appeal, the court addressed pretrial, guilt phase, and penalty phase issues. The court found no error, and where the court assumed error, it found no prejudice. Therefore, the court affirmed the judgment. View "People v. Dement" on Justia Law

A jury convicted defendant of first degree murder and found true the allegation that he personally used a firearm in commission of the murder. The jury also found true the three special-circumstance allegations that defendant intentionally killed a police officer, that he committed murder for the purpose of avoiding a lawful arrest, and that he intentionally killed the victim by lying in wait. Defendant was sentenced to death and an appeal to the court was automatic. The court held that because the trial court had no authority to strike a special circumstance found by the jury, the court reinstated the lying-in-wait special circumstance. As so modified, the court affirmed the judgment of death. View "People v. Mendoza" on Justia Law

Defendants were convicted of assault by means of force likely to produce great bodily injury and the jury also found true an enhancement allegation that defendants committed the assault for the benefit of the Tiny Oriental Crips (TOC), a criminal street gang. The Court of Appeal held that the trial court erred in permitting the expert to respond to hypothetical questions the prosecutor asked because the questions closely tracked the evidence in a manner that was only thinly disguised. The court disagreed that the trial court erred and held that it was required, not prohibited, that hypothetical questions be based on the evidence. The questioner was not required to disguise the fact the questions were based on that evidence. Although the Court of Appeal erroneously found error, it also found the error harmless. Accordingly, it reached the correct result and the court affirmed the judgment. View "People v. Vang" on Justia Law