Justia California Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeal affirming the judgment of the trial court denying Appellant's petition for resentencing under Senate Bill No. 1437, holding that certain special circumstance findings did not preclude him from making out a prima facie case for resentencing.In 2014, Appellant was convicted of felony murder. The jury found true felony-murder special-circumstance allegations that Appellant was a "major participant" who acted with "reckless indifference to human life" under Cal. Penal Code 190.2, subdivision (d). Thereafter, the Supreme Court decided People v. Banks, 61 Cal. 4th 788 (2015) and People v. Clark, 63 Cal.4th 522 (2016), which provided guidance on the meaning of the statutory phrases "major participant" and "with reckless indifference to human life." In 2018, the Legislature adopted Senate Bill 1437. Appellant then petitioned for resentencing. The trial court denied the petition. The Supreme Court reversed, holding (1) findings issued by a jury before Banks and Clark do not preclude a defendant from making out a prima facie case for relief under Senate Bill 1437; and (2) because Appellant's case was tried before both Banks and Clerk, the special circumstance findings did not preclude him from making out a prima facie case for resentencing under section 1172.6. View "People v. Strong" on Justia Law

The Supreme Court held that liability under the Unruh Civil Rights Act, Cal. Civ. Code 51, was not available in this case, where Plaintiff alleged that he was sexually assaulted by fellow students and a school district staff member at his high school.Plaintiff, through his guardian, sued the West Contra Costa Unified School District asserting various claims arising out of his high school experiences, including allegations that the District had violated the Act. The District demurred to the Act cause of action on the ground that the District was not a "business establishment" within the meaning of the Act. The trial court sustained the demurrer. Thereafter, Plaintiff filed an original petition for writ of mandate, which the court of appeal denied. The Supreme Court affirmed, holding that the Act, as currently written, cannot reasonably be interpreted to encompass public school districts in situations such as the one this case presented. View "Brennon B. v. Superior Court" on Justia Law

In this lawsuit challenging the sufficiency of an environmental impact report (EIR) prepared by California's Department of Water Resources (DWR) the Supreme Court affirmed in part and reversed in part the decision of the court of appeal finding that the claims brought by Butte and Plumas Counties under the California Environmental Quality Act (CEQA), Cal. Pub. Res. Code 21000 et seq., were preempted, holding that the court of appeal erred in part.The Counties brought a challenge to the environmental sufficiency of a settlement DWR prepared as part of the Federal Energy Regulatory Commission (FERC) proceedings, 16 U.S.C. 817(1), and to the sufficiency of the EIR more generally. The court of appeals found that the action was preempted by the Federal Power Act, 16 U.S.C. 791a et seq. The Supreme Court reversed in part, holding (1) the Counties' claims were preempted to the extent they attempted to unwind the terms of a settlement agreement reached through a federal process and sought to enjoin DWR from operating certain facilities; but (2) the court of appeals erred in finding the Counties' CEQA claims entirely preempted. View "County of Butte v. Dep't of Water Resources" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal reversing the trial court's order dismissing counts one through four of the combined information in this criminal case, holding that Cal. Penal Code 954's joinder clause permits a district attorney to file a single information in the circumstances presented in this case.At issue before the Supreme Court was whether, and under which circumstances, a trial court may consider more than one preliminary hearing record in its ruling on a motion brought under Cal. Penal Code 995 to set aside the information for lack of probable cause. Specifically at issue was the correct interpretation of section 954. The court of appeals ruled that section 954's consolidation clause provided the district court with the authority to file a single information combining related offenses that were the subject of separate preliminary injunctions. The Supreme Court affirmed, holding (1) the statute permits a history attorney to file a single information when the applicable time constraints are satisfied; and (2) when related offenses are properly joined by the district attorney and in ruling on a section 995 motion, a trial court is permitted to consider more than one preliminary hearing record. View "People v. Henson" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant, following a jury trial, of eleven counts of first-degree murder and sentencing him to death, holding that Defendant was not entitled to reversal of his convictions.Specifically, the Supreme Court held (1) Defendant was not entitled to reversal on his claims regarding his right to representation; (2) the trial court did not err on engage in misconduct during venue-related proceedings in both Calaveras County and Orange County, and the trial court did not err in failing to transfer six counts from Orange County to the City and County of San Francisco; (3) the trial court did not deprive Defendant of due process by its adjudication of competency proceedings or by subjecting him to physical constraints; (4) even if there was error in the admission of certain evidence, the error was harmless; (5) the trial court did not abuse its discretion in denying Defendant's motion for a mistrial based on lack of evidence; and (6) there was no prejudicial error during the penalty phase. View "People v. Ng" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, attempted murder, and conspiracy to commit murder and sentencing Defendant to death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the trial court properly excluded two prospective jurors for cause; (2) the "substantial impairment" standard used for determining jury bias in capital cases did not violate Defendant's Sixth Amendment right to an impartial jury; (3) there was no constitutional violation in the denial of Defendant's motion to dismiss the charges against him; (4) there was no error in the court's evidentiary rulings; (5) the trial court erred by failing to provide the jury with a cautionary instructions defining confessions, but the error was harmless; (6) Defendant did not demonstrate any basis for the Court to find error in California's death penalty laws; and (7) a limited remand was appropriate for the sole purpose of allowing the trial court to consider whether to exercise its discretion to strike the prior serious felony enhancement and the firearm enhancements. View "People v. Mataele" on Justia Law