Justia California Supreme Court Opinion Summaries

Defendant was convicted of first degree murder of a prison inmate where the jury found that defendant used a deadly weapon in the commission of the murder and found true the special circumstance of allegations of prior convictions of first degree murder and lying in wait. The jury further convicted defendant of assault with a deadly weapon by a life prisoner and found he had been convicted in 1988 of three counts of first degree murder. Defendant was sentenced to death and this appeal was automatic. The court addressed claims regarding the denial of defendant's motion for separate juries for the guilty phase and the special circumstance and penalty phase; excusal for cause of prospective Juror No. 3; refusal to excuse for cause of Prospective Juror No. 8; introduction of evidence that defendant was a white supremacist; instructional error; whether defendant's death sentence was cruel and unusual punishment because it was based primarily on prior murders committed when he was a juvenile; and California's death penalty statute. The court subsequently affirmed the judgment of the superior court. View "People v. Bivert" on Justia Law

Defendant was convicted of first degree murder under the special circumstance that the murder was committed while defendant was engaged in kidnapping and in the commission or attempted commission of sodomy and defendant was sentenced to death. On automatic appeal, defendant raised issues related to motions for change of venue; failure to conduct individual sequestered jury selection; the claim of instructional error concerning concealment of evidence; the claim of instructional errors related to the standard of proof; the claim of improper instructions on first degree premeditated murder; admission of victim impact evidence; the trial court's refusal to admit allegedly mitigating evidence; instruction on the credibility of a single witness; admission of unadjudicated conduct; instruction on aggravating and mitigating factors; instruction on scope of sentencing discretion; miscellaneous issues concerning California's death penalty law; and cumulative error. The court discussed each issue and held that the judgment was affirmed. View "People v. Famalaro" on Justia Law

Defendant was convicted of first degree murder under the special circumstance of a murder engaged in the commission of a lewd and lascivious act on a child under the age of 14 and sentenced to death. On automatic appeal, defendant raised issues related to comments to prospective jurors during jury selection; admission of other crimes evidence; admission of the victim's statement; admission of expert testimony; instructions regarding the other crimes evidence; cumulative prejudice; validity of the lewd-and-lascivious-act special circumstance; and challenges to California's death penalty law and instructions. The court discussed each issue and held that the judgment was affirmed. View "People v. Loy" on Justia Law

Defendant submitted a false report to a deputy sheriff, stating that her vehicle had been stolen. At issue was whether defendant's felony conviction under a general statute governing the offering of a false instrument for filing in a public office was precluded by special statutes in the Vehicle Code that made it a misdemeanor to make or file a false report of vehicle theft or to file a false statement with the Department of Motor Vehicles. The court held that the Legislature intended that defendant's conduct be prosecuted as a misdemeanor under Vehicle Code section 10501 and not under the more general statute. Thus, the court reversed the district court's judgment. View "People v. Murphy" on Justia Law

Defendant was convicted of murdering a 22-year-old Soy Sun Lao during a doughnut shop robbery and convicted of two other robberies, both committed with a knife and one accompanied by an assault with force likely to produce great bodily injury. Defendant was sentenced to death and the court subsequently reviewed defendant's case on automatic appeal. The court reviewed guilt phase issues, penalty phase issues, and defendant's other claims of error. The court concluded that defendant's claim that the cumulative effect of guilt and penalty phase errors required reversal of his sentence failed because defendant had not established that any prejudicial error had occurred at either phase of his trial. Accordingly, the court affirmed the judgment. View "People v. Virgil" on Justia Law

Defendant was convicted of crimes related to the murder of Colleen Mary Kennedy and sentenced to death. On automatic appeal, defendant argued, among other things, that the trial court provided an erroneous instruction concerning the element of asportation for the offense of kidnapping and thereby violated his rights to due process and a fair trial under the Fifth, Sixth, Eighth, and Fourteenth Amendments of the U.S. Constitution and article I, sections 7 and 17 of the California Constitution. The court held, and the Attorney General conceded, that the totality of the circumstances standards set forth in People v. Martinez could not be applied to defendant's actions where defendant moved the victim from one room to another room. The court also held, and the Attorney General conceded, that "it is reasonably probable that a result more favorable to [defendant] would have been reached in the absence of the error." Therefore, the court reversed the judgment of conviction for kidnapping, vacated the findings related to kidnapping, and otherwise affirmed the judgment.View "People v. Castaneda" on Justia Law

Plaintiffs, former workers for defendant, a large software company headquartered in California, sued defendant claiming overtime compensation under the Labor Code for days longer than eight hours, and weeks longer than 40 hours, worked entirely in California; claiming that defendant's failure to pay overtime for work performed in California was an "unlawful [or] unfair... business act or practice" for purposes of California's unfair competition law (UCL), Bus. & Prof. Code, 17200 et seq.; and claiming restitution under the UCL in the amount of overtime compensation due under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 207(a), for weeks longer than 40 hours worked entirely in states other than California. The court held that the Labor Code's overtime provision did apply to plaintiffs' claims for compensation for work performed in California and that the same claims could serve as predicates for claims under the UCL. The court also held that plaintiffs' claims for overtime compensation under the FLSA for work performed in other states could not serve as predicates for the UCL. View "Sullivan, et al. v. Oracle Corp., et al." on Justia Law

Defendant was convicted of residential burglary and receiving stolen property. The trial court held a trial to determine whether defendant had suffered a prior Alabama felony conviction that qualified as a serious felony conviction under the Three Strikes Law, Pen. Code, 667. At issue was whether faxed copies of certified court records were admissible to establish that a prior conviction qualified as a serious or violent felony under the Three Strikes law. The court affirmed the Court of Appeal judgment upholding the trial court's admission of the faxed copy of the certified court record because there was sufficient evidence to sustain a finding that the faxed document was an accurate copy of an authentic court record from the Circuit Court of Lauderdale County, Alabama. View "People v. Skiles" on Justia Law

Defendant had twice been convicted and sentenced to death for robbing and murdering the two managers of an apartment where he had lived. On his automatic appeal, the court addressed defendant's numerous claims of error. The court rejected defendant's claims and held that in those few instances in which the court found error or assumed the existence of error, the court concluded that any error was harmless. The court also held that, in combination, these errors did not compel the conclusion that defendant was denied a fair trial. Accordingly, the court affirmed the convictions and sentence of death. View "People v. Moore" on Justia Law

Plaintiff sued a truck driver, the truck driver's employer, and a second driver after plaintiff sustained severe, permanent injuries from an automobile accident. At issue was whether plaintiff, who asserted both theories of respondeat superior and negligent entrustment against the employer and the employer admitted vicarious liability for any negligent driving by its employee, could still pursue the negligent entrustment claim. The court affirmed its holding in Armenta v. Churchill that an employer's admission of vicarious liability for an employee's negligent driving in the course of employment barred a plaintiff from pursuing a claim for negligent entrustment. Therefore, the trial court erred in not applying that holding to this case. The court held that, had the trial court not made the error, it was reasonably probable that the jury would have reached a result more favorable to defendants. Accordingly, the court reversed the judgment of the Court of Appeals and directed that court to reverse the trial court's judgment and remand the case for a complete retrial. View "Diaz v. Carcamo, et al." on Justia Law