Justia California Supreme Court Opinion Summaries
People v. Abel
A jury convicted defendant of the first degree murder of the victim, also finding that he had personally used a firearm in the commission of the offense and finding true the circumstance that defendant had committed the murder during the course of a robbery. The jury imposed the death sentence. On appeal, the court addressed pretrial and guilt phase issues, as well as penalty phase issues. The court concluded that the outcome of the trial was unaffected by any errors that occurred and affirmed the judgment of the district. View "People v. Abel" on Justia Law
Quarry v. Doe I
Plaintiffs brought an action against the Roman Catholic Bishop of Oakland, alleging that defendant bore responsibility for sexual abuse committed during the 1970's by a priest then assigned to the Oakland diocese. Plaintiffs alleged that they discovered for the first time that the cause of their adult psychological injuries was the sexual abuse inflicted by this priest when they were children. At issue was whether their claims were within the limitations period established by Code of Civil Procedure section 340.1. The court held that the revival of any lapsed claims against the subcategory of defendants identified in the 2002 amendments was governed by subdivision (c) of section 340.1. The court also established that as of 1998, plaintiffs' claims necessarily had lapsed and plaintiffs' claims were not revived by the 1999 amendments, but for one year only. Because they did not file their claims within that year, their claims were barred under the applicable statute of limitations. Accordingly, the court reversed and remanded for further proceedings. View "Quarry v. Doe I" on Justia Law
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California Supreme Court, Injury Law
People v. Thomas
Defendant was convicted of second degree murder of one victim and two first degree murders of officers. The jury found true special circumstances allegations that the officers were killed while engaged in the performance of their duties and that defendant was convicted of more than one murder. On automatic appeal, the court modified the judgment to correct the sentence imposed on count 1 for second degree murder where the trial court made an error in imposing a sentence of death for count 1, an offense that was not punishable by death. The court affirmed defendant's convictions and death sentence in all other respects. View "People v. Thomas" on Justia Law
People v. Fuiava
Defendant was convicted of the first degree murder of a Los Angeles County Deputy Sheriff and the premeditated attempted murder of the deputy sheriff's partner. The jury found true the special circumstance allegations that the murder of the deputy sheriff was committed for the purpose of avoiding and preventing a lawful arrest and that the deputy sheriff was a peace officer engaged in the performance of his duties when defendant knowingly and intentionally killed him. The jury also found true the allegations that defendant personally used a firearm in the murder and attempted murder, previously had been convicted of a serious felony, and had served two prior prison terms. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues related to the denial of a motion for discovery of law enforcement officers' personnel files; the denial of a motion to continue the trial; asserted errors during voir dire; guilt phase challenges; penalty phase challenges; assertedly improper denial of motion for new trial based upon insufficiency of the evidence; assertedly improper role of race in the proceedings; asserted denial of an impartial judge; challenges to the constitutionality of California's death penalty statutes; and cumulative prejudicial effects of asserted errors. View "People v. Fuiava" on Justia Law
People v. Enraca
Defendant was convicted of first degree murder of two victims, with a multiple-murder special circumstance finding. Defendant was also convicted of assault with a deadly weapon on another victim, with a a great bodily injury finding. Firearm use and criminal street gang findings were made as to all three counts. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues involving the admissibility of defendant's confession; the trial court's refusal to instruct on heat of passion; instructions on perfect and imperfect self-defense; defendant's waiver of his right to testify; victim impact evidence; asserted improper prosecutorial argument; lack of remorse; refusal to instruct on lingering doubt; and challenges to the death penalty law and instructions. View "People v. Enraca" on Justia Law
People v. Elliott
Defendant was convicted of murder in the first degree with the special circumstance of murder during the commission of a robbery and sentenced to death. Defendant was also convicted of robbery and assault with a deadly weapon, using a handgun to commit both the robbery and assault. On automatic appeal, the court addressed pretrial and jury selection issues; issues relating to guilt; issues relating to penalty; and the adequacy of the appellate record. The court ultimately affirmed the judgment. View "People v. Elliott" on Justia Law
People v. Brents
Defendant was sentenced to death on a first degree murder conviction by trying to suffocate the victim, putting her in the trunk of a car and driving to a remote location, pouring gasoline on her and the outside of the trunk, and lighting the gasoline on fire. The victim burned to death trapped inside of the trunk. On automatic appeal, the court affirmed the convictions of first degree murder and the other charged felonies, but the court reversed as to the penalty of death and set aside the kidnapping special circumstances finding because the trial court erroneously instructed the jury. View "People v. Brents" on Justia Law
People v. Cravens
Defendant was convicted of various crimes against a number of victims. At issue was whether there was sufficient evidence to support defendant's conviction of second degree murder under a theory of implied malice when defendant cracked the victim's skull by punching him during a fight. The Court of Appeal reduced the conviction to voluntary manslaughter because of insufficient evidence of implied malice, focusing solely on the subjective component of implied malice. The court held, however, that the evidence was sufficient to satisfy both the physical and mental components of implied malice. Accordingly, the court held that the Court of Appeal erred in finding otherwise. View "People v. Cravens" on Justia Law
People v. Johnson
Defendant was convicted of crimes arising out of two separate assaults. At issue was whether California courts could apply a higher standard of mental competence for self-representation than for competency to stand trial in light of the Supreme Court's holding under Indiana v. Edwards. Because California law has long been that criminal defendants have no right of self-representation, the court concluded that California courts could deny self-representation when the U.S. Constitution permitted such denial. The court also concluded that the trial court acted within its discretion in revoking defendant's self-representation status. View "People v. Johnson" on Justia Law
Vandermost v. Bowen
A proposed referendum in this case would require the electorate to decide at the November 2012 general election whether to accept or reject the California state Senate district map certified by the Citizens Redistricting Commission. If the referendum qualifies, the state Senate map certified by the Commission would automatically be stayed, presenting the question of what Senate districts should be used for the 2012 primary and general elections of the State. The Supreme Court held (1) if the proposed referendum qualifies for the November 2012 general election ballot and triggers a stay of the Commission's certified Senate district map, the Commission's state Senate map should be used on an interim basis for the June and November 2012 elections, pending the outcome of the referendum; and (2) if the proposed referendum does not qualify for the ballot, the Commission's state Senate map will continue to be used for the 2012 election and future elections until replaced pursuant to Cal. Const. art. XXI by new maps drawn by a future newly constituted Commission following the 2020 census.
View "Vandermost v. Bowen" on Justia Law