Justia California Supreme Court Opinion Summaries

In this case regarding conservatorships authorized by the Lanterman-Petris-Short (LPS) Act for persons gravely disabled by a mental disorder or chronic alcoholism the Supreme Court held that, for purposes of the right against compelled testimony, those facing an LPS conservatorship due to an inability to care for themselves are sufficiently similar to persons found not guilty of crimes by reason of insanity (NGIs) that equal protection principles require the government to justify its disparate treatment of these proposed conservatees.The Contra Costa County Public Guardian petitioned for an LPS conservatorship on the ground that Appellant was gravely disabled. Appellant requested a jury trial and objected to giving compelled testimony.The court overruled the petition. Appellant was called to testify during trial. The jury found Appellant gravely disabled, and the court appointed the Public Guardian as conservator. On appeal, Appellant challenged the order compelling his testimony. The court of appeals held that LPS conservatives and similarly situated with NGIs for the purposes of NGI extension proceedings but that the error in compelling Appellant's testimony was harmless. The Supreme Court affirmed, holding (1) traditional LPS conservatees are similarly situated with NGI’s for purposes of the right against compelled testimony; but (2) a remand was not appropriate in this case. View "In re Conservatorship of Eric B." on Justia Law

The Supreme Court affirmed the judgment of the juvenile court, holding that the juvenile court committed serious errors by proceeding with a hearing to determine its jurisdiction over a child and disposition of a wardship petition without an incarcerated parent's presence and without appointing counsel for the parent, but the rule of automatic reversal was unwarranted in this case.The Los Angeles Department of Children and Family Services filed a dependency petition alleging that two children were at risk due to Mother's ongoing substance abuse and Father's criminal history. Neither Father, who was incarcerated, nor counsel for Father appeared at the ensuing combined jurisdiction and disposition hearing. The court sustained the petition as to both Father and Mother. Thereafter, the court terminated Father's parental rights. The court of appeal affirmed. The Supreme Court affirmed, holding that it was not structural error for the juvenile court to proceed with the jurisdiction and disposition hearing without Father's presence and without appointing Father an attorney. View "In re Christopher L." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of the first-degree murder of his father and the second-degree murders of his stepmother and stepsister and sentencing him to death, holding that Defendant's second-degree murder convictions must be reversed.A federal court vacated Defendant's initial conviction and sentence. After a retrial, Defendant was convicted of first- and second-degree murder, and the jury found true a multiple-murder special-circumstance finding and various firearm- and weapon-use findings. Defendant was sentenced to death. At trial, Defendant's counsel conceded his responsibility for the deaths of all three victims, but Defendant was willing to accept responsibility only for the killing of his father and objected to admitting responsibility for the other two deaths. The Supreme Court held (1) defense counsel violated Defendant's Sixth Amendment rights to choose the fundamental objectives of his defense; and (2) while the error did not affect Defendant's first-degree murder conviction or the associated firearm-use finding, the error requires reversal of the remainder of the judgment and the judgment of death. View "People v. Bloom" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and death sentence, holding that there was no prejudicial error.After a jury trial, Defendant was convicted of the first-degree murder of a nine-year-old girl, with special circumstances for committing the murder while engaged in kidnapping, lewd act on a child under fourteen, and oral copulation. A death sentence was imposed. The Supreme Court affirmed, holding (1) there was no prejudicial prefiling delay; (2) Defendant was not prejudiced by the trial court's order that he wear leg chains during trial; (3) the trial court did not err in excluding third party culpability evidence; (4) the trial court did not improperly allow certain victim impact testimony; and (5) Defendant's challenges to the constitutionality of the death penalty were unavailing. View "People v. Bracamontes" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming Defendant's life sentence for his conviction of conspiracy to commit home invasion robbery under Cal. Penal Code 186.22(b)(4), holding that the superior court erred in sentencing Defendant to an indeterminate life term under that provision.Section 186.22(b)(4) prescribes indeterminate life terms for specified felonies, including home invasion robbery. At issue was whether Defendant was properly sentenced to an indeterminate life term even though he was convicted of the crime of conspiracy and not yet completed home invasion robbery. The Supreme Court answered the question in the negative, holding that section 186.22(b)(4) does not apply to conspiracy convictions. View "People v. Lopez" on Justia Law

The Supreme Court reversed the judgment of the appellate court granting a writ of mandate directing the trial court to issue a new order denying Ford Motor Company's motion to exclude all of Plaintiff's proffered deposition testimony, holding that the court of appeal erroneously construed Wahlgren as establishing a categorical bar to admitted deposition testimony under Cal. Evid. Code 1291(a)(2).Plaintiff, a putative member of a federal multidistrict class action suit against Ford arising from the diesel engine used in some of Ford's vehicles, opted out of a federal suit in order to pursue his own lawsuit. Plaintiff filed ten designations of deposition testimony listing the depositions of nine out-of-state Ford employees or former employees had given deposition testimony in the federal action or in subsequent related California opt-out litigation that Plaintiff proposed to introduce at trial. Ford moved to exclude the proffered testimony, which the trial court granted. The Supreme Court reversed, holding that the appellate court’s analysis was incompatible with (1) the established principle that the party proposing to introduce evidence under section 1291(a)(2)’s former testimony exception to the hearsay rule bears the burden of establishing the requirements for admission; and (2) the Legislature’s official comment reflecting its understanding when it enacted the provision at issue as part of the Evidence Code in 1965. View "Berroteran v. Superior Court" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the trial court sustaining Well Fargo Bank, N.A.'s demurrer to Plaintiff's negligence claim, holding that Plaintiff was not entitled to relief on his claims of error.At issue on appeal was whether a lender owes the borrower a tort duty sounding in general negligence principles to process and respond carefully to a borrower's loan modification application such that, upon a breach of this duty, the lender may be liable for the borrower's pecuniary losses unaccompanied by property damage or personal injury. The Supreme Court held that there was no such duty, holding that neither Plaintiff's assertion of a "special relationship" between himself and Wells Fargo nor his invocation of the factors articulated in Biakanja v. Irving, 49 Cal.2d 647 (1958), provided a compelling basis to recognize such a duty. View "Sheen v. Wells Fargo Bank, N.A." on Justia Law

The Supreme Court held that Cal. Civ. Code 3333.2 applies to a physician assistant who has a legally enforceable agency relationship with a supervising physician and provides services within the scope of that agency relationship, even if the physician violates his obligation to provide adequate supervision.Under a provision of the Medical Injury Compensation Reform Act (MICRA), damages for noneconomic losses shall not exceed $250,000 in any action for injury against a healthcare provider based on "professional negligence." At issue before the Supreme Court was whether section 3333.2 applies to actions against physician assistants who are nominally supervised by a doctor but receive minimal or no supervision when performing medical services. The Supreme Court held that a physician assistant practices within the scope of her license for purposes of MICRA’s cap on noneconomic damages when the physician assistant acts as the agent of a licensed physician, performs the type of services authorized by that agency relationship, and does not engage in an area of practice prohibited by the Physician Assistant's Practice Act. See Cal. Bus. & Prof. Code, former 3502, subd. (d). View "Lopez v. Ledesma" on Justia Law

The Supreme Court affirmed the judgment of the the trial court convicting defendants Karl Holmes, Herbert McClain, and Lorenzo Newborn of three counts of murder, five counts of attempted murder, and one count of conspiracy to commit murder and sentencing each defendant to death, holding that no prejudicial error occurred at either stage of the proceedings.After the jury failed to reach a penalty verdict, a new penalty phase was held, and death verdicts were returned against all defendants. On appeal, Defendants asserted several allegations of error argued that the cumulative prejudicial errors in both the guilt and penalty phases of the trials required the reversal of their convictions and sentences. The Supreme Court affirmed, holding (1) in the few instances in which this Court found or assumed error, no prejudice resulted; and (2) whether the claims are considered separately or cumulatively, no prejudicial error occurred. View "People v. Holmes" on Justia Law

The Supreme Court held that Cal. Labor Code 1102.6 governs whistleblower retaliation claims brought pursuant to Cal. Labor Code 1102.5.Since 2003, section 1102.6 has prescribed a framework for presenting and evaluating retaliation claims brought under section 1102.5. Since 2003, some courts continued to apply the burden-shifting framework borrowed from the decision in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). The trial court granted summary judgment for Defendant on Plaintiff's whistleblower retaliation claim in this case, concluding that Plaintiff could not satisfy the third step of the McDonnell Douglas test. The Ninth Circuit Court of Appeal certified a question regarding the correct standard to the Supreme Court. The Supreme Court answered that section 1102.6 provides the governing framework for the presentation and evaluation of whistleblower retaliation claims brought under section 1102.5. View "Lawson v. PPG Architectural Finishes, Inc." on Justia Law