Justia California Supreme Court Opinion Summaries

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

This case stemmed from a lawsuit filed in 2007 by the Retired Employees Association of Orange County, Inc. against the County of Orange contesting the validity of certain changes the county had made to health benefits for retired employees. At the request of the Ninth Circuit, the court addressed the following question: "Whether, as a matter of California law, a California county and its employees can form an implied contract that confers vested rights to health benefits on retired county employees." In response, the court concluded that, under California law, a vested right to health benefits for retired county employees could be implied under certain circumstances from a county ordinance or resolution. Whether those circumstances existed in this case was beyond the scope of the question posed to the court by the Ninth Circuit. View "Retired Employees Assoc. v. Co. of Orange" on Justia Law

This case arose from litigation challenging the validity, under the United States Constitution, of the initiative measure (Proposition 8) that added a section to the California Constitution providing that "[o]nly marriage between a man and a woman is valid or recognized in California" (Cal. Const., art. I, section 7.5). The Ninth Circuit posed the following procedural issue to the court, "[w]hether under article II, section 8 of the California Constitution, or otherwise under California law, the official proponents of an initiative measure possess either a particularized interest in the initiative's validity or the authority to assert the State's interest in the initiative's validity, which would enable them to defend the constitutionality of the initiative upon its adoption or appeal a judgment invalidating the initiative, when the public officials charged with that duty refused to do so." In response, the court concluded that when the public officials who ordinarily defended a challenged state law or appealed a judgment invalidating the law declined to do so, under article II, section 8 of the California Constitution and the relevant provisions of the Election Code, the official proponents of a voter-approved initiative measure were authorized to assert the state's interest in the initiative's validity, enabling the proponents to defend the constitutionality of the initiative and to appeal a judgment invalidating the initiative. View "Perry v. Brown" on Justia Law

This case stemmed from the taking of property in downtown Los Angeles to comply with a federal court order to improve the quality of bus services and involved California's "quick-take" eminent domain procedure, Code of Civil Procedure 1255.010, 1244.410, where a public entity filing a condemnation action could seek immediate possession of the condemned property upon depositing with the court the probable compensation for the property. At issue was Section 1255.260's proper interpretation. The court of appeals in this case held that, under the statute, if a lender holding a lien on condemned property applied to withdraw a portion of the deposit, and the property owner did not object to the application, the lender's withdrawal of a portion of the deposit constituted a waiver of the property owner's claims and defenses, except a claim for greater compensation. The court found the court of appeal's conclusion was inconsistent with the relevant statutory language and framework. Therefore, the court reversed the judgment of the court of appeals. View "L.A. Cty. Metro. Trans. v. Alameda Produce Market, LLC, et al." 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

Plaintiffs objected to paying an extra fee for an expedited transcript of a deposition noticed by defendant. Plaintiffs won an appeal establishing that trial courts have the authority to determine the reasonableness of fees charged by deposition reports to nonnoticing parties. On remand, the trial court found that the fee charged to plaintiffs was unreasonable, but denied their motion for an award of attorney fees under Code of Civil Procedure section 1021.5. Relying on Adoption of Joshua S., that court concluded that plaintiffs had acted in their own interest and only incidentally conferred a benefit on other litigants. The Court of Appeal affirmed. The court concluded, however, that Joshua S had no application here where deposition reporters were officers of the court, regulated by statute, who perform a public service of considerable importance to litigants and members of the public. The reporting service here did not merely seek to vindicate its private rights. It defended its institutional interest in controlling the fees it charged and sought to shield itself from judicial review of its conduct as a ministerial officer of the court. Moreover, it was found to have charged plaintiffs an unreasonable fee. Therefore, the courts erred by concluding that the service did nothing adverse to the public interest and that plaintiffs' appeal did not involve an important right affecting the public interest. Because neither the Court of Appeal nor the trial court considered whether plaintiffs satisfied the other elements required for a fee award under section 1021.5, the court reversed and remanded for further proceedings. View "Serrano, et al. v. Stefan Merli Plastering" on Justia Law