Justia California Supreme Court Opinion Summaries

The Supreme Court remanded this case to the court of appeal to determine in the first instance whether Sarah Plott Key was entitled to equitable relief from the 100-day deadline prescribed by Cal. Code Civ. P. 1288.2, holding that the section 1288.2 deadline is not jurisdictional and does not otherwise prelude equitable tolling or estoppel.Plaintiff prevailed in an arbitration against Defendant and petitioned to confirm the award. Defendant moved to vacate the award. The trial court vacated the award despite the fact that Defendant filed her motion to vacate outside the 100-day deadline. The court of appeal reversed, concluding that the 100-day deadline was jurisdictional and that the parties could not extend the deadline by agreement. The Supreme Court reversed, holding (1) Plaintiff's requests were filed outside the applicable statutory period; and (2) section 1288.2's deadline for seeking vacatur of an arbitral award is a nonjurisdictional statute of limitations that is subject to equitable tolling and equitable estoppel. View "Law Finance Group, LLC v. Key" on Justia Law

The Supreme Court reversed the court of the court of appeal reversing Defendant's conviction of rape and kidnapping to commit rape, holding that the court of appeals incorrectly found prejudicial instructional error.On appeal, the court of appeal concluded that the trial court erred in instructing the jury that Defendant could be convicted of kidnapping to commit rape based on the theory that he accomplished the kidnapping by deception rather than by force or fear. The Supreme Court reversed, holding that because any rational juror who made the findings reflected in the verdict would necessarily have found that Defendant used some quantum of physical force to move the victim in this case, any error did not contribute to the verdict. View "People v. Lewis" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the trial court's judgment in favor of the County of Riverside in this action asserting negligent distress, holding that a provision of the Government Claims Act, Cal. Gov. Code 821.6, does not immunize public employees from claims based on certain injuries inflicted in the course of law enforcement investigations.Plaintiff's husband was shot and killed. When deputies with the Riverside County Sheriff office dragged his body in an attempt to revive him, the movement exposed his naked body. Plaintiff brought this action alleging that the officers and County failed to exercise reasonable care when they left her husband's body exposed for several hours in view of both Plaintiff and the general public. The trial court granted judgment for the County, concluding that Defendants were immune under section 821.6 for "all conduct related to the investigation and filing of charges." The court of appeal affirmed. The Supreme Court reversed, holding that the court of appeals erred in upholding the application of section 321.6 to confer absolute immunity on the County for negligent infliction of emotional distress arising out of the alleged mishandling of Plaintiff's husband's body because the claims did not concern alleged harms from the institution or prosecution of judicial or administrative proceedings. View "Leon v. County of Riverside" on Justia Law

The Supreme Court affirmed Defendant's sentence of death, following resentencing, in connection with his convictions of first degree murder, two counts of forcible rape, and enhancements for personal use of a firearm, holding that any error in the resentencing was harmless beyond a reasonable doubt.When Defendant was convicted in 2000 the jury found true special circumstances for committing murder during a kidnapping and intentional infliction of torture and set the penalty at death. The Supreme Court upheld the guilt judgment but reversed the penalty verdict on the grounds that the trial court erroneously dismissed a juror during penalty phase deliberations. After a retrial, Defendant was again sentenced to death. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar Defendant's penalty retrial; (2) the penalty retrial did not violate due process; (3) Defendant's challenges to the constitutionality of California's death penalty statute were unavailing; and (4) any error brought about by retroactive application of Senate Bill 1437 was harmless beyond a reasonable doubt. View "People v. Wilson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the trial court's denial of Defendant's request for a pretrial diversion made for the first time after the jury returned its verdict, holding that a defendant must request a pretrial diversion under Cal. Penal Code 1001.36 before attachment of jeopardy at trial or the entry of a guilty or no contest plea, whichever occurs first.After a trial at which Defendant represented himself, a jury found Defendant guilty of resisting an executive officer with force or violence and having two prior qualifying felony convictions under the "Three Strikes" law. Before sentencing, Defendant's newly-appointed counsel moved to have Defendant considered for mental health diversion under section 1001.36. The trial court denied the motion as both untimely and moot, and the appellate court affirmed. The Supreme Court affirmed, holding that the Legislature intended to require that a defendant request pretrial mental health diversion before attachment of jeopardy at trial or the entry of a guilty or not contest plea, whichever occurs first. View "People v. Braden" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal determining that Cal. Gov. Code 818, a provision within the Government Claims Act, shields public entities from liability for enhanced damages under Cal. Code Civ. Proc. 340.1(b)(1), holding that the court of appeal did not err.At issue was whether enhanced damages could be awarded under section 340.1(b)(1) against a public entity named as a defendant in a lawsuit for childhood sexual assault or whether such awards were prohibited under section 818, which specifies that a public entity may not be held liable in tort for "damages imposed primarily for the sake of example and by way of punishing the defendant." The court of appeal concluded that the treble damages provision in section 340.1 does not have a compensatory function and that its primary purpose is to punish past childhood sexual abuse coverups and deter future abuse. The Supreme Court affirmed, holding that section 818 prohibits an award of enhanced damages under section 340.1(b)(1) against a public entity. View "L.A. Unified School District v. Superior Court" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming Defendant's gang enhancement and firearm enhancement and remanded this case to the superior court for a retrial, holding that a retrial was required.After a trial, Defendant was convicted of first-degree murder with gang and firearm enhancements and a prior strike conviction. At issue on appeal was whether any of Defendant's sentencing enhancements must be vacated due to the legislature's amendment to the substantive offense of active participation in a criminal street gang as well as the sentencing enhancement available for a felony committed for the benefit of or with specific intent to promote criminal conduct by gang members because the jury in his case was instructed under the prior law. The Supreme Court remanded the case, holding that the failure to instruct that the alleged predicate offenses must have "commonly benefited" the gang in a "more than reputation" manner was not harmless beyond a reasonable doubt. View "People v. Cooper" on Justia Law

The Supreme Court held that Cal. Penal Code 667.6(d), which requires that a sentencing court impose "full, separate, and consecutive" terms for certain sex crimes if it finds certain facts, complies with the Sixth Amendment to the United States Constitution.Defendant was convicted of six counts of forcible lewd acts on a child under the age of fourteen and one lesser-included offense of attempt and sentenced to full, consecutive terms for each of his convictions. On appeal, Defendant argued that the trial court violated his Sixth Amendment right to a jury trial by sentencing him under section 667.6(d) without submitting to the jury the question of whether each of his offenses was committed on a separate occasion. The court of appeal denied relief. The Supreme Court affirmed, holding that the operation of section 667.6(d) does not violate the rule of Apprendi v. New Jersey, 530 U.S. 466 (2000), and Alleyne v. United States, 570 U.S. 99 (2013). View "People v. Catarino" on Justia Law

The Supreme Court held that a report of unlawful activities made to an employer or agency that already knew about the violation is a protected "disclosure" within the meaning of Cal. Labor Code 1102.5(b).Employer fired Employee after Employee complained about unpaid wages she was owed, threatened to report her to immigration authorities, and told her never to return to the establishment. The Labor Commissioner sued Employer for violations of section 1102.5, but the trial court ruled against Labor Commissioner on the claim because Employee reported her complaints to Employer rather than a government agency. The court of appeal affirmed. The Supreme Court reversed, holding that Employee made a disclosure protected by section 1102.5(b). View "People ex rel. Garcia-Brower v. Kolla's, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeal declining to remand this matter to the juvenile court, holding that because the trial court did not comply with the "mandatory express declaration" set forth in Cal. Welf. & Inst. Code 702 and was not "aware of" wobbler offenses, the court of appeals erred in failing to remand the case for further proceedings.Under section 702, when a minor is found to have committed a wobbler, which is punishable either as a misdemeanor or as a felony at the discretion of the sentencing court, "the court shall declare the offense to be a misdemeanor or a felony." In the instant case, the trial court did not comply with section 702's express declaration mandate. The court of appeal concluded that remand was unnecessary because the record established that the juvenile court "was both aware of and exercised its discretion to treat the sustained allegations as felonies." The Supreme Court reversed, holding that, applying In re Manzy W., 14 Cal.4th 1199 (1997), a remand was required on the record. View "In re F.M." on Justia Law