Justia California Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeal affirming the judgment of the probate court denying Petitioner's petition to issue the predicate findings he needed to support an application to the federal government for special immigrant juvenile (SIJ) status, holding that the probate court applied an incorrect legal framework in ruling on Petitioner's petition.Petitioner, who left his native El Salvador at the age of sixteen to escape gang violence, filed an SIJ petition the day after he turned eighteen. The probate court denied the petition, and the court of appeal affirmed. The Supreme Court reversed and remanded with direction that the case be remanded to the probate court for issuance of SIJ predicate findings, holding that returning Petitioner to live in El Salvador would be detrimental to his best interest under California law. View "In re Guardianship of Saul H." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court affirming the findings of the Commission on State Mandates rejecting the claims brought by Plaintiffs, several community college districts seeking reimbursement for regulations they must satisfy to avoid the possibility of having their state aid withheld, holding that the court of appeals erred.Plaintiffs filed a claim arguing that reimbursement was required under Cal. Const. art. XIII B because (1) the regulations imposed a legal duty to satisfy the conditions described (legal compulsion), or (2) the regulations compelled compliance as a practical matter (practical compulsion). The Commission rejected the claims, and the trial court affirmed. The court of appeals reversed. The Supreme Court reversed, holding that because the court of appeal chose not to address whether the districts established practical compulsion, remand was required to allow the court to evaluate that issue. View "Coast Community College District v. Commission on State Mandates" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal in this dispute , holding that Oakland did not show on demurrer that its challenged fees at issue in this case were exempt from the voter approval requirements set forth in article XIII C of the California Constitution.In 2012, the City of Oakland approved two contract granting private waste haulers the right to operate a public utility for waste collection services. As consideration for the "special franchise right," the waste haulers agreed to pay certain fees to Oakland. In question was how such fees should be treated under article XIII C, which sets forth voter approval requirements that apply to taxes imposed by local government. The court of appeals concluded that the fees were not exempt from the requirements of section XIII C. The Supreme Court affirmed, holding that Oakland failed to show, as a matter of law, that article XIII C applied to the franchise fees at issue in this case. View "Zolly v. City of Oakland" on Justia Law

The Supreme Court affirmed the determination of the trial court finding Defendant guilty of first-degree murder, except as modified to strike an enhancement under former Cal. Penal Code 667.5, subdivision (b), and affirmed the judgment of death but vacated the prison sentence, holding that remand was required.After a guilt phase of the bench trial held in this case Defendant was convicted of first degree murder. The trial court found true two prior serious felony enhancements and two prior prison term enhancements. After a penalty phase, the trial court returned a verdict of death and imposed a consecutive prison term of fifteen years. The Supreme Court (1) vacated the one-year prior prison term enhancement imposed under former section 667.5, subdivision (b) and remanded for resentencing, holding that the enhancement was unauthorized; and (2) affirmed the judgment in all other respects. View "People v. Morelos" on Justia Law