Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction for kidnapping to commit rape, murder, attempted carjacking, assault with intent to commit rape, and receiving stolen property, and Defendant's sentence of death, holding that Defendant was not entitled to reversal of his convictions or sentences.Specifically, the Supreme Court held (1) as to the guilt phase issues raised by Defendant on appeal, the only potential errors, including the possibility that the prosecutor strayed beyond appropriate commentary into personal commentary on defense counsel, were not so egregious that they made the trial unfair; and (2) there was no error in the penalty phase. View "People v. Miranda-Guerrero" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court ruling that the exception to landowners' negation of their statutory duty of care to keep their property safe for others who may enter or use it for recreational purposes does not apply when the landowners' live-at-home child invites someone onto the property without the owners' knowledge or permission, holding that the court of appeals erred.The trial court ruled that the exception did not apply in this case because the landowners had not issued the invitation. The court of appeals reversed, holding that the exception to the landowners' statutory negation of duty when a landowner expressly invites someone onto the property applied unless the child had been prohibited to make the invitation. The Supreme Court reversed, holding (1) a plaintiff may rely on the exception and impose liability if there is a showing that a landowner extended an express invitation to come onto the property; and (2) the plaintiff in this case did not meet her burden. View "Hoffmann v. Young" on Justia Law

The Supreme Court reversed the judgment of the court of appeal holding that a sidewalk picket purporting to protest a real estate company's business practices after the company evicted two long-term residents from their home did not constitute speech in connection with a public issue under the anti-SLAPP statute's catchall provision, holding that the sidewalk protest constituted protected activity within the meaning of Cal. Code Civ. Proc. 425.16(e)(4).The court of appeal held that the sidewalk picket at issue was beyond the scope of anti-SLAPP protection because the picket did not implicate a public issue. Rather, the court of appeal concluded that the picket concerned only a private dispute between the real estate company and the two residents. The Supreme Court reversed after applying both steps of the analysis set forth in FilmOn.com Inc v. DoubleVerify Inc., 7 Cal.5th 133 (2019), holding that the sidewalk protest furthered public discussion of the public issues it implicated. View "Geiser v. Kuhns" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death but struck the enhancement that Defendant committed the murder for the benefit of, at the direction of, or in association with a criminal street gang, holding that there was no basis for reversing Defendant's convictions or sentence.After a jury trial, Defendant was convicted of first-degree murder. The jury found true the gang enhancement and the special circumstances of robbery murder and torture murder. The jury returned a verdict of death, and the trial court denied Defendant's motions for a new trial, for reduced punishment, and to modify the verdict. The Supreme Court struck the gang enhancement and otherwise affirmed, holding (1) there was assumed or either found error regarding certain jury instructions, the failure to bifurcate, and the admission of hearsay and certain evidence, but each assumed or found error was harmless; (2) Defendant's gang enhancement was incorrectly imposed, but this error did not require reversal of the guilty verdicts or death judgment; and (3) there was no other basis for reversing Defendant's convictions or sentence. View "People v. Tran" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming Defendant's convictions and sentences, holding that the gang penalties imposed by the trial court were unsupported by the evidence.Defendant was convicted of two counts of shooting at an inhabited dwelling, an offense that is normally punishable by a maximum of seven years of imprisonment. While there was no evidence Defendant was accompanied by any gang members at the time of the shooting the jury found true that Defendant committed the crimes for the benefit of and with the specific intent to promote criminal conduct by gang members. Defendant challenged the gang penalties as unsupported by the evidence. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant was not subject to additional punishment prescribed for felonies shown to be gang-related under Cal. Penal Code 186.22(b). View "People v. Renteria" on Justia Law

The Supreme Court affirmed Defendant's convictions and life sentences for first-degree murder, robbery, kidnapping, carjacking, and drug-related offenses, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant was not entitled to relief on his claims of error during jury selection; (2) the trial judge was neither biased nor prejudiced against Defendant nor his counsel during voir dire; (3) as to Defendant's claims of error during the guilt phase of his trial, he failed to establish that the trial court committed prejudicial error in its evidentiary rulings; (4) the prosecutor did not commit misconduct rendering Defendant's trial fundamentally unfair; and (5) as to the penalty phase issues raised by Defendant, there was no prejudicial error. View "People v. Ramirez" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction of assault with a deadly weapon other than a firearm and assault by means of force likely to cause great bodily injury, holding that assault with a deadly weapon and force likely assault are different statements of the same offense.Evidence at trial showed that Defendant hit her father with a bicycle chain and lock. That evidence supported each of Defendant's aggravated assault convictions. At issue before the Supreme Court was whether "assault upon the person of another with a deadly weapon or instrument other than a firearm" and "assault upon the person of another by any means of force likely to produce great bodily injury" are separate offenses or whether they constitute different statements of the same offense. The Supreme Court vacated the convictions, holding that a defendant may not be convicted of both types of aggravated assault. View "People v. Aguayo" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that an instructional error in Defendant's criminal trial was not prejudicial and thus did not require reversal, holding that the instructional error was prejudicial and required reversal.Defendant was charged with burglary after the police found him sitting on a bench outside a house in Oxnard after attempting to open the locked door. At issue was a standard mistake of fact instruction given to inform jurors that they should not convict Defendant if they believed he lacked criminal intent because he mistakenly believed that the house belonged to his cousin and not a stranger. The instruction, however, specified that the mistake had to be a reasonable one, which was error. The Supreme Court held that the instructional error required reversal because it effectively precluded the jury from giving full consideration to a mistake of fact claim that was supported by substantial evidence and that there was a reasonable chance that Defendant's jury would have come to a different verdict had it been correctly instructed. View "People v. Hendrix" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal denying Petitioner's petition for a writ of habeas corpus seeking resentencing under People v. Gallardo (2017) 4 Cal.5th 120, holding that the Gallardo rule does not apply retroactively to final judgments.In Gallardo, the Supreme Court held that a defendant's Sixth Amendment right to a jury trial is violated when the trial court makes factual findings about the nature of a defendant's prior conviction in imposing an enhanced sentence based on that prior conviction. In the instant case, the court of appeal denied Petitioner's habeas petition on the ground that Gallardo was not retroactive to Petitioner's judgment, which was final in 2000. The Supreme Court affirmed, holding that the rule announced in Gallardo is a new procedural rule, and it is not retroactive to cases on collateral review under both state and federal tests for retroactivity. View "In re Milton" on Justia Law

In this dispute over whether Plaintiff's claims premised on the packaging and video of Michael, an album of music billed as Michael Jackson's first posthumous release, were subject to the album marketers' motion to strike under California's anti-SLAPP statute the Supreme Court held that Plaintiff sufficiently demonstrated that some of her claims had sufficient merit.In her complaint against Sony Music Entertainment, Plaintiff asserted that Michael's marketers misled her and violated two California consumer protection laws, the unfair competition law, and the Consumers Legal Remedies Act, by misrepresenting a vocalist on certain tracks through the album's packaging and in a promotional video. The court of appeal granted Defendants' motion to strike under the anti-SLAPP statute, concluding that the First Amendment required classifying the disputed statements as noncommercial speech. The Supreme Court reversed, holding that Plaintiff's claims related to Michael's packaging and promotional video had sufficient merit. View "Serova v. Sony Music Entertainment" on Justia Law