Justia California Supreme Court Opinion Summaries

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

The Supreme Court affirmed in part and reversed in part the judgment of the appellate court concerning whether a party in default has standing to file a motion for a new trial asserting legal error relating to calculation of damages and whether a court may award treble damages and attorney's fees under Cal. Penal Code 496 in a case involving fraudulent diversion of a partnership's cash distributions, holding the court erred in part.Plaintiff sued Defendants for underpaying him and improperly diverting a partnership's rental income. The trial court entered a default judgment against Defendants, awarding Plaintiff treble damages and attorney's fees. The court of appeal reversed in part, concluding that Defendants had standing and that the trial court improperly awarded treble damages under section 496(c) under the circumstances of this case. The Supreme Court reversed in part, holding that the court of appeal (1) correctly recognized and confirmed Defendants' standing to move for a new trial on the ground that the trial court erred in awarding and calculating damages; and (2) erred in construing section 496(c) to withhold, rather than afford, treble damages and attorney's fees when property "has been obtained in any manner constituting theft." View "Siry Investment, L.P. v. Farkhondehpour" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the trial court against a hospital based on violations of the Labor Code and the Unfair Competition Law, holding that the lower court correctly found that claim preclusion did not bar this suit.A nurse sued the staffing agency that arranged for her to work at at a hospital based on violations of the Labor Code and the Unfair Competition Law. The parties settled. Thereafter, the nurse sued the hospital based on the same alleged violations. The hospital argued that the first judgment precluded the nurse from bringing the second suit. The trial court concluded that the hospital was not in privity with the staffing agency for claim preclusion purposes. The Supreme Court affirmed, holding that the hospital was not entitled to benefit from claim preclusion. View "Grande v. Eisenhower Medical Center" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two murders and finding true the special circumstances that one murder occurred during the commission of a robbery, that the other murder involved the killing of a witness and that Defendant had been convicted of multiple murders, and sentencing Defendant to death, holding that no errors required reversal of the judgment.Specifically, the Supreme Court held (1) substantial evidence supported the excusal of juror J.W. for cause; (2) assuming that the trial court erred when it allowed the prosecution to introduce "other acts" evidence at the guilt phase of trial, any error was harmless; (3) assuming that the trial court erred in introducing evidence at the penalty phase regarding Defendant's participation in mutual combat was harmless; and (4) there was no cumulative error requiring reversal of the judgment below. View "People v. Pineda" on Justia Law

The Supreme Court affirmed the order of the trial court entering judgment upon the jury's verdict that Defendant committed first degree murder, robbery, burglary, and firearm possession by a felon and sentencing him to death, holding that while the court committed statutory error, there were no additional errors or rulings that caused Defendant undue prejudice.On appeal, Defendant asserted that several errors in the guilt and penalty phases occurred, resulting in cumulative prejudice warranting reversal of his convictions. The Supreme Court disagreed and affirmed, holding (1) the trial court erred by allowing Defendant to be absent from trial without a written waiver, but the error was not prejudicial; and (2) Defendant failed to identify any other reversible error on appeal. View "People v. Poore" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the trial court granting Plaintiff's postural motion seeking attorney's fees in the amount of $169,602 under the Song-Beverly Consumer Warranty Act, Cal. Civ. Code 1795, subd. (d), after awarding her $21,957.25 in damages on her claim for breach of the implied warranty of merchantability, holding that there was no error.Plaintiff purchased a used vehicle from a dealership pursuant to an installment sales contract that was later assigned to TD Auto Finance (TDAF). Plaintiff filed suit against the dealership and TDAF, alleging misconduct in the sale of the car. A jury found that Defendants breached the implied warranty of merchantability under the Song-Beverly Act and awarded damages and attorney's fees under the Song-Beverly Act. The court of appeal affirmed. The Supreme Court affirmed, holding that recovery under the Federal Trade Commission's Holder Rule does not limit the award of attorney's fees where, as a here, a buyer seeks fees from a holder under a state prevailing party statute. View "Pulliam v. HNL Automotive, Inc." on Justia Law

The Supreme Court held that Proposition 57, a measure that amended the law governing the punishment of juvenile offenses in adult criminal court by requiring hearings to determine whether the offenses should instead by hearing in juvenile court, applied during resentencing where the criminal court sentence imposed on Defendant, a juvenile offender, was issued before the initiative's passage but was since vacated.Defendant was originally sentenced before Proposition 57 was enacted, but his sentence was later vacated on habeas corpus, and the case was returned to the trial court for imposition of a new sentence. At issue was whether Proposition 57 applied to Defendant's resentencing. The Supreme Court affirmed the judgment of the court of appeal, holding that Proposition 57 applied to Defendant's resentencing because the judgment in his case became nonfinal when his sentence was vacated on habeas corpus. View "People v. Padilla" on Justia Law

The Supreme Court held that the additional hour of pay an employer must pay an employee if the employer unlawfully makes the employee work during all or part of a meal or rest period constitutes "wages" that must be reported on statutorily-required wage statements during employment and paid within statutory deadlines when an employee leaves the job.Plaintiff, who was suspended from his job as a guard after leaving his post to take a meal break. Plaintiff filed a putative class action on behalf of employees of Defendant seeking an additional hour of pay, so-called "premium pay," for each day on which Defendant failed to provide employees a legally-compliant meal break. The trial court determined that Defendant had violated the meal break laws for a certain period and that a failure to pay meal break premiums could support claims under the wage statement and timely payment statutes. The court of appeal reversed in part. The Supreme Court remanded the case, holding (1) the court of appeal erred in concluding that extra pay for missed breaks does not constitute "wages" to be reported on wage statements during employment; and (2) the seven percent default rate of prejudgment interest set by the state Constitution applies to amounts due for failure to provide meal and rest breaks. View "Naranjo v. Spectrum Security Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of first degree murder and the jury's findings of the lying-in-wait special circumstance and the special circumstance allegations that Defendant intentionally killed the victim for financial gain while engaged in the commission or attempted commission of rape, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion by failing to initiate competency proceedings; (2) there was no error in the trial court's evidentiary rulings; (3) sufficient evidence supported the jury's true findings of the special circumstances, and the special circumstances, as applied, are not unconstitutional; (4) there was no instructional error; (5) Defendant's claims of prosecutorial misconduct were without merit; and (6) Defendant's remaining claims of error were unavailing. View "People v. Parker" on Justia Law