Justia California Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction for three counts of first degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request.Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless. View "People v. Waldon" on Justia Law

The Supreme Court reversed the judgment of the court of appeal dismissing Father's appeal of the determination of the juvenile court that it had jurisdiction over D.P. under former Cal. Welf. & Inst. Code 300(b)(1), holding that the court of appeals erred in dismissing the appeal.The Los Angeles County Department of Children and Family Services filed a dependency petition claiming that D.P. and his sister were at risk of neglect. The juvenile court dismissed all but one of the counts and found that it had jurisdiction over D.P. under former Cal. Welf. & Inst. Code 300(b)(1). Parents challenged this jurisdictional finding on appeal. While Parents' appeal of the jurisdictional finding was pending, the juvenile court terminated its jurisdiction, finding that D.P. was no longer at risk. The court of appeals then dismissed Parents' case as moot. The Supreme Court reversed, holding (1) Father's appeal was moot; and (2) the court of appeals had discretion to review Father's case even though it was moot. View "In re D.P." on Justia Law

The Supreme Court held that a law enforcement officer's act of shining a spotlight for illumination does not ipso facto constitute a detention under the Fourth Amendment, but rather, the proper inquiry requires consideration of the totality of the circumstances, including the use of the spotlight.Defendant was charged with drug offenses after a law enforcement officer conducted a search of the car he was driving. At issue was whether the officer engaged in a consensual encounter when he pulled behind Defendant's car and turned on his spotlight. The court of appeal concluded that spotlight illumination and approach on foot did not "manifest a sufficient show of police authority to constitute a detention." The Supreme Court agreed, holding (1) under the totality of the circumstances, Defendant was not detained by the officer's use of a spotlight; and (2) remand was appropriate for a new factual finding as to whether the officer's detention of the vehicle's female passenger effectuated a detention of Defendant. View "People v. Tacardon" on Justia Law

The Supreme Court affirmed the decision of the court of appeal finding that it had no duty to independently review an order denying a petition for postconviction relief under Cal. Penal Code former section 1170.95, which Defendant filed in this case, when appointed counsel submits notice that the appeal lacks arguable merit, holding that Defendant was not entitled to relief.The court of appeal in this case provided notice to Defendant that counsel was unable to find any arguable issues, but the notice was "suboptimal" because it indicated that the procedures set forth in People v. Wende, 25 Cal.3d 436 (Cal. 1979), would apply when they actually did not. The court further failed to inform Defendant that the appeal would be dismissed as abandoned if he did not file a supplemental brief or letter. The Supreme Court nevertheless affirmed the denial of Defendant's petition for postconviction relief, holding that, based on an independent review of the record, Defendant was not entitled to relief under Cal. Penal Code 1172.6. View "People v. Delgadillo" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the juvenile court finding true that Minor had committed one count of violating Cal. Penal Code 288.5 and order probation, thus rejecting Minor's claims that a community service provision of the disposition violated separation of powers principles and infringed his due process rights, holding that there was no error.In affirming, the appellate court acknowledged that a juvenile court may not delegate to a probation officer the authority to determine that a minor is in violation of probation but held that, in this case, the juvenile court's order permitting the probation officer to offer Minor the option of community service for an alleged violation did not permit the probation department to decide if and when a violation of probation had occurred. The Supreme Court affirmed, holding that the juvenile court order authorizing the probation officer to offer Minor on probation the option of performing community service, in an amount chosen by the probation officer up to a maximum set by the court, in the event Minor was alleged to have violated a term of probation, did not violate due process or separation of powers principles. View "In re D.N." on Justia Law

The Supreme Court affirmed the decision of the court of appeal upholding the trial court's finding that trial may continue in Defendant's absence under Cal. Penal Code 1043(b)(2) because the absence was voluntary, holding that the trial court did not violate Defendant's constitutional rights by finding him to be voluntarily absent without conducting an evidentiary hearing regarding the circumstances of his absence.On appeal, the court of appeal concluded that substantial evidence supported the trial court's finding that Defendant voluntarily absented himself from trial and that the court's decision to proceed with trial rather than grant defense counsel's motion for a one-day continuance constituted harmless error. The Supreme Court affirmed, holding that substantial evidence supported the trial court's finding of voluntary absence under the circumstances of this case. View "People v. Ramirez" on Justia Law

The Supreme Court reversed Defendant's conviction for conspiracy to commit murder, holding that there was insufficient evidence to support the conviction.After a jury trial, Defendant and his codefendants were found guilty of conspiracy to commit murder and other offenses. As to all three defendants, the jury found that the conspiracy was for the benefit of a criminal street gang. Defendant appealed, challenging the sufficiency of the evidence. The court of appeal affirmed. The Supreme Court reversed, holding that, after considering the record in its entirety, the evidence presented at trial was insufficient to show that Defendant had the requisite intent to enter into an agreement to commit murder. View "People v. Ware" on Justia Law

The Supreme Court affirmed the judgment of the superior convicting Defendant, following a jury trial, of first degree murder and sentencing him to death, holding that Defendant failed to demonstrate that alleged errors occurring at the guilt phase of trial cumulated in his not having received a "fair trial on the issue of his mental state at the time of the shooting."Specifically, the Supreme Court held (1) the trial court committed error under state law by ordering that Defendant submit to an examination by the prosecution expert and allowing the jury to learn of Defendant's refusal to be examined, but these errors were not prejudicial; (2) the prosecutor's comments regarding the ethics of forensic psychiatry did not infect the trial with unfairness that rose to the level of prejudicial error; (3) the trial court erred in admitting a law enforcement officer's statement under People v. Sanchez, 63 Cal.4th 665 (2016), but the error did not contribute to the jury's verdict; (4) the guilt phase errors were not cumulatively prejudicial; (5) the trial court did not err in excusing a prospective juror for cause because of her views on the death penalty; and (6) no other prejudicial error occurred during the penalty phase of the trial. View "People v. Camacho" on Justia Law

The Supreme Court reversed the judgment of the court of appeal ruling that Proposition 36, the Three Strikes Reform Act of 2012, stripped sentencing courts of the discretion to impose concurrent terms for felonies that were committed on the same occasion or arose from the same set of operative facts, even if the felonies qualified as serious or violent, holding that the lower court erred.At issue was whether the Act abrogated the rule set forth in People v. Hendrix, 16 Cal. 4th 508 (1997), that a trial court retains discretion to impose concurrent terms for felonies that were "committed on the same occasion" or did not "aris[e] from the same set of operative facts" while requiring consecutive sentences for multiple current felonies that were not "committed on the same occasion" or did not "aris[e] from the same set of operative facts." The Court of Appeal concluded that, after passage of the Act, a trial court lacks discretion to impose concurrent terms on multiple serious or violent felonies. The Supreme Court reversed, holding that, following Proposition 36, a trial court retains its Hendrix concurrent sentencing discretion and that the total sentence imposed for multiple current counts of serious or violent felonies must be ordered to run consecutively to the term imposed for offenses that do not qualify as serious or violent felonies. View "People v. Henderson" on Justia Law

The Supreme Court held that the language in the insurance policy at issue in this case provided liability coverage for right-of-seclusion violations litigated under the Telephone Consumer Protection Act of 1991 (TCPA), 47 U.S.C. 227, assuming such coverage is consistent with the insured's reasonable expectations.Privacy injuries involving the right of seclusion are sometimes actionable under the TCPA provided that the violation involves the use of telephonic equipment. The insurance policy in this case provided liability coverage for injuries "arising out of...[o]ral or written publication...of material that violates a person's right of privacy." At issue before the Supreme Court was whether this language provided liability coverage for right-of-seclusion violations brought under the TCPA. The Court held that a commercial general liability insurance policy that provides coverage for "personal injury" defined in part as injury arising out of oral or written publication of material that violates a person's right of privacy can cover liability for violations of the right of seclusion if that coverage is consistent with the insured's reasonable expectations. View "Yahoo Inc. v. National Union Fire Insurance Co. of Pittsburgh, PA" on Justia Law