Justia California Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeal concluding that Petitioners' failure to present their objections to business improvement districts (BIDs) assessment schemes at appropriate public hearings meant that they had not exhausted their extrajudicial remedies, holding that Petitioners need not have raised their specific objections to the BIDs at the public hearings to later advance those arguments in court.Petitioners initiated two actions challenging arguing that two BIDs' assessment schemes violated certain provisions of Proposition 218 and seeking relief that would remove any obligation that they pay assessments for the BIDs. The superior court reached the merits of Petitioners' claims, ultimately denying them in full. The court of appeal declined to address Petitioners' claims on the merits, concluding that Petitioners had failed to exhaust their extrajudicial remedies because they did not first present their objections at the appropriate public hearing. The Supreme Court reversed, holding that Petitioners were not required to articulate their objections to the BID assessment schemes at public hearings before presenting their arguments in these proceedings. View "Hill RHF Housing Partners, L.P. v. City of Los Angeles" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first-degree murder and sentencing him to death, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not commit reversible error when it denied Defendant's request for self-representation under Faretta v. California, 422 U.S. 806 (1975) because the motion was untimely; (2) it was not reasonably probable that the jury would have reached a result more favorable to Defendant but for one improper question posed by the prosecutor to a witness; (3) the trial court did not err when it denied Defendant's motion for a mistrial; (4) admission of certain evidence did not violate Defendant's right to due process or render his trial fundamentally unfair; (5) there was no merit to Defendant's allegations of instructional error; and (6) Defendant's challenges to the death penalty law were unavailing. View "People v. Wright" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and attempted second-degree robbery and sentence of death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) sufficient evidence supported the attempted robbery conviction; (2) the trial court did not err in admitting statements obtained during an undercover operation that law enforcement performed while Defendant was being transported and held in jail; (3) there was no error in the denial of defense counsel's request for a second continuance; (4) a wiretap application at issue in this case was not facially invalid; (5) any violation of Defendant's right to confrontation was harmless; (6) Defendant failed to establish either prosecutorial or judicial misconduct; (7) the trial court did not improperly restrict cross-examination or err in its remaining challenged evidentiary rulings; (8) Defendant failed to establish harmful error as to the admission of his statements at the penalty phase of his statements referencing other crimes; and (9) Defendant's challenges to the death penalty were unavailing. View "People v. Gonzalez" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting Defendant's motion for postconviction discovery under Cal. Penal Code 1054.9 giving Defendant access to the prosecutor's jury selection notes, holding that there was no error.In 1994, Defendant was convicted of capital murder and sentenced to death. Decades later, Defendant filed a habeas corpus petition claiming that the prosecution had used peremptory strikes to discriminate against prospective jurors, in violation of Batson v. Kentucky, 476 U.S. 79 (1986) and People v. Wheeler, 22 Cal.3d 258 (1978). Defendant also filed, in connection with the petition, a motion for postconviction discovery seeking access to the prosecutor's jury selection notes. The trial court granted the motion, and the court of appeal affirmed. The Supreme Court affirmed, holding that the district attorney may not invoke the attorney work product protection to withhold information necessary to the fair adjudication of Defendant's Batson/Wheeler claim. View "People v. Superior Court" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and conspiracy to commit murder, as well as participation in a criminal street gang, and sentencing him to death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) Defendant's convictions were supported by the evidence; (2) Sanchez error did not require reversal of Defendant's gang-related conviction and special circumstance; (3) the trial court did not abuse its discretion in anticipating potentially objectionable assertions in Defendant's opening statement; (4) the trial court's discovery sanction was not prejudicial; (5) the trial court's challenged evidentiary rulings did not prejudice Defendant; (6) Defendant's claims of prosecutorial misconduct lacked merit; and (7) Defendant was not entitled to relief on his penalty phase claims. View "People v. Navarro" on Justia Law

The Supreme Court held that a company that hired the contractor that hired the injured plaintiff in this case, owned the premises, and operated the electrical equipment, was not liable for the plaintiff's injuries.Plaintiff, an electrical parts specialist, sustained burns to a substantial portion of his body after he triggered an arc flash from a circuit he did not realize was live with flowing electricity. A jury concluded that the contractor for whom Plaintiff had been working and who had removed the protective cover on that live circuit while work was underway acted negligently and was liable for Plaintiff's injuries. At issue was whether Defendant, the entity that hired the independent contractor, owed a tort duty to Plaintiff, who was working for Defendant at the time of Plaintiff's injuries. The Supreme Court held that Defendant owed no tort duty to Plaintiff because Defendant neither failed to sufficiently disclose the hazard nor affirmatively contributed to the injury. View "Sandoval v. Qualcomm Inc." on Justia Law

The Supreme Court reversed the decision of the trial court committing Petitioner as a sexually violent predator, holding that hearsay evidence in a psychological evaluation report in finding probable cause to commit a petitioner under the Sexually Violent Predator Act (SVPA), Cal. Well. & Inst. Code, 6600 set seq., is not admissible in expert evaluations.At issue was what kind of evidence a trial court may consider in making its initial SVPA probable cause determination. Petitioner argued that the trial court admitted inadmissible hearsay in two evaluations in finding probable cause, including facts underlying two offenses that he had been charged with but not convicted of and resulted in convictions that did not qualify as predicate offenses for commitment under the SVPA. The Supreme Court agreed, holding that the introduction of this hearsay evidence prejudicially affected Defendant's ability to challenge the basis of the State's petition and the sufficiency of the evidence. View "Walker v. Superior Court" on Justia Law

The Supreme Court held that Defendant, which terminated one of the life insurance policies at issue in this case because the policy owner had failed to make a payment, had no right to terminate the policies without complying with the newly codified statutory protections against termination.In 2013, protections to shield consumers from losing life insurance coverage because of a missed premium payment went into effect. The protections were codified in Cal. Ins. Code 10113.71 and 10113.72. Thereafter, Defendant terminated the subject life insurance policy. Plaintiffs brought this action arguing that Defendant had no right to terminate the policies, which predated sections 10113.71 and 10113.72, without complying with the sections. The court of appeal concluded that the newly codified statutory protections against termination did not apply because they appeared to affect only policies issued or delivered after the sections' effective date. The Supreme Court reversed, holding that sections 10113.71 and 10113.72 apply to all life insurance policies in force when these two sections went into effect, regardless of when the policies were originally issued. View "McHugh v. Protective Life Insurance Co." on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first degree murder, two counts of attempted murder, and possession of a firearm by a felon, holding that there was no reversible error.Specifically, the Supreme Court held (1) the prosecutor's use of a peremptory strike during jury selection prior to the guilt phase did not violate Batson v. Kentucky, 476 U.S. 79 (1986), or People v. Wheeler, 22 Cal. 3d 258 (1978); (2) the trial court did not err in denying Defendant's motion to suppress the gun discovered during a traffic stop; (3) the trial court did not err in admitting hearsay evidence that was the basis for the gang enhancement; (4) there was sufficient evidence to support Defendant's gang enhancement conviction; and (5) the court erred in admitting evidence of the victim's cancer diagnoses during the penalty phase, but there was no reasonable possibility that the victim impact testimony affected the verdict. View "People v. McDaniel" on Justia Law

The Supreme Court reversed Defendant's convictions of two counts of first-degree murder, holding that the district court erred in failing to initiate the competency procedures set forth in Cal. Penal Code 1368 and 1369.During pretrial proceedings and at the request of the court, a psychologist examined Defendant and issued a report finding Defendant incompetent to stand trial. The trial court rejected the psychologist's opinion without initiating the competency procedures set forth in sections 1368 and 1369. At both the guilt and penalty phases of trial, Defendant represented himself. Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court reversed the judgment in its entirety, holding that the trial court erred by failing to initiate the formal competency procedures set forth in sections 1368 and 1369. View "People v. Wycoff" on Justia Law