Justia California Supreme Court Opinion Summaries

The defendant, a high-ranking member of the Toonerville street gang, was convicted by a jury of three counts of first-degree murder and four counts of attempted murder. The jury found true the special circumstances of multiple murders and that two of the murders were committed for the benefit of a criminal street gang. The original jury deadlocked on the penalty phase, and a retrial resulted in a death sentence.The trial court received a note from two jurors during deliberations, alleging that Juror No. 5 was not deliberating fairly and was biased against the police and prosecution. The court conducted an inquiry, questioning all jurors individually. Several jurors expressed that Juror No. 5 was using speculation as facts, was not making sense, and had a bias against the police. Juror No. 5 denied these allegations, stating he was deliberating fairly and felt the other jurors were ganging up on him. The court ultimately removed Juror No. 5, citing a failure to deliberate and bias against the prosecution.The Supreme Court of California reviewed the case and found that the trial court erred in discharging Juror No. 5. The court concluded that the record did not manifestly support the trial court's findings that Juror No. 5 was refusing to deliberate or was biased against the police and prosecution. The Supreme Court emphasized that Juror No. 5's skepticism towards the prosecution's witnesses was based on evidence presented at trial, including issues of witness credibility and potential coaching by police. The court held that the removal of Juror No. 5 was an abuse of discretion and reversed the judgment, remanding the case for further proceedings. View "P. v. McGhee" on Justia Law

The defendant was convicted by a jury of first-degree murder for the killing of Carlos Cardona, with the special circumstance that the murder was committed during a robbery. The jury also found that the defendant personally used and discharged a firearm, causing great bodily injury or death. At the penalty phase, the jury returned a verdict of death, and the trial court sentenced the defendant to death, with additional terms for the firearm enhancements.The case was automatically appealed. The California Supreme Court reviewed several issues, including the admissibility of hearsay statements made by the defendant's accomplice, the admission of statements by another individual about the firearm used in the murder, and the prosecutor's leading questions to a witness who refused to testify. The court also considered whether the jury instructions on felony murder and accomplice liability were erroneous under current law, and whether the cumulative effect of any errors warranted reversal.The court found no reversible error in the admission of the accomplice's statements, concluding they were admissible as declarations against penal interest and were not testimonial. The court also found that any error in admitting the statements about the firearm was harmless. The prosecutor's leading questions to the uncooperative witness did not violate the defendant's confrontation rights, and the jury instructions, while potentially misleading, did not prejudice the defendant given the jury's findings.The court affirmed the death judgment but remanded the case to the trial court to consider whether to strike the firearm enhancements under the discretion conferred by Senate Bill No. 620, which became effective after the defendant's sentencing. View "P. v. Jasso" on Justia Law

Daniel Escamilla, a certified fugitive recovery agent, searched the home of Lan Ting Wu and Andy Yu Feng Yang in 2012, looking for Yang’s brother, who was wanted on felony drug trafficking charges. Yang, Wu, and their minor son sued Escamilla for assault, battery, trespass, false imprisonment, and emotional distress. Their lawyer, John Vannucci, represented them. Escamilla defended the search as supported by probable cause and cross-complained against Yang for abuse of process. In 2019, a jury found in favor of Escamilla on all claims and awarded him $20,000 in damages. On August 30, 2021, Escamilla filed a malicious prosecution action against Yang, Wu, and Vannucci.The Alameda County Superior Court granted Vannucci’s motion to strike Escamilla’s complaint as a strategic lawsuit against public participation (SLAPP), agreeing that the one-year statute of limitations for claims against attorneys under section 340.6 applied, making the suit time-barred. The Court of Appeal affirmed this decision.The Supreme Court of California reviewed the case to determine the appropriate statute of limitations for a malicious prosecution action against an attorney. The court held that section 340.6, which provides a one-year limitations period for certain suits against attorneys, does not apply to claims brought by parties who were never their clients or the intended beneficiaries of their clients. Instead, the two-year statute of limitations under section 335.1 applies to malicious prosecution claims brought by formerly adverse parties. The court reversed the judgment and remanded the case to the Court of Appeal to consider any unaddressed arguments in the anti-SLAPP motion. View "Escamilla v. Vannucci" on Justia Law

Oscar and Audrey Madrigal purchased a car from Hyundai Motor America in 2011 for $24,172.73. The car allegedly did not function as warranted, and repeated repair attempts failed. The Madrigals requested Hyundai to repurchase the car under the Song-Beverly Consumer Warranty Act, but Hyundai refused, leading the Madrigals to sue for violations of the Act. Hyundai made two settlement offers under California Code of Civil Procedure section 998, which the Madrigals did not accept. On the first day of trial, after the court tentatively ruled against the Madrigals on pretrial motions, the parties settled for $39,000, with the Madrigals retaining the right to seek costs and attorney fees by motion.The Placer County Superior Court ruled that section 998 did not apply because the case settled before trial, and awarded the Madrigals $84,742.50 in attorney fees and $17,681.05 in other costs. Hyundai appealed, arguing that the Madrigals should not recover any postoffer costs because they settled for less than the second 998 offer. The Court of Appeal reversed, holding that section 998’s cost-shifting provisions applied and remanded for further proceedings.The Supreme Court of California affirmed the Court of Appeal’s decision. The Court held that section 998’s cost-shifting provisions apply even when a case settles before trial but after a section 998 offer is rejected or deemed withdrawn. The Court reasoned that the statute’s language and purpose—to encourage the settlement of lawsuits before trial—support this interpretation. The Court clarified that parties are free to agree on their own allocation of costs and fees as part of a settlement agreement, but absent such an agreement, section 998’s default cost-shifting rules apply. View "Madrigal v. Hyundai Motor America" on Justia Law

In 2018, the California Legislature amended the law of homicide, eliminating several theories of liability based on imputed malice and offering relief to those convicted under certain now-invalid theories, such as the natural and probable consequences doctrine. Petitioners seeking relief must file a facially valid petition and make a prima facie showing before a court issues an order to show cause and holds an evidentiary hearing.Ramon Patton, who pleaded guilty to attempted murder and intentionally discharging a firearm, filed a petition for resentencing under the amended law. The People referenced the preliminary hearing transcript, which indicated Patton was the sole shooter, to argue against his prima facie showing. Patton offered no factual counterweight, relying solely on checkbox allegations.The Los Angeles County Superior Court found Patton failed to establish a prima facie case and denied the petition. The Court of Appeal affirmed, noting the preliminary hearing transcript showed Patton was the sole shooter, and his conviction did not implicate an invalid theory.The Supreme Court of California held that a petitioner who offers only conclusory allegations in response to a record of conviction demonstrating the conviction was under a still-valid theory has not made a prima facie showing. The court affirmed the judgment but remanded to allow Patton an opportunity to amend his petition. The court clarified that at the prima facie stage, courts may reference the record of conviction to refute conclusory allegations without engaging in impermissible factfinding. View "P. v. Patton" on Justia Law

Brian Ranger, a maintenance worker for Alamitos Bay Yacht Club, was injured while performing his duties, which included hoisting and mooring vessels. On August 28, 2018, he slipped and fell while boarding a vessel, resulting in serious injuries. Ranger applied for state workers' compensation and subsequently sued the Club under general maritime law, alleging negligence and unseaworthiness.The Los Angeles County Superior Court sustained the Club's demurrer without leave to amend, concluding that Ranger failed to allege facts implicating federal admiralty jurisdiction. Although the court acknowledged the tort occurred on navigable waters, it found that Ranger did not demonstrate his fall posed more than a fanciful risk to maritime commerce. The Court of Appeal affirmed the decision but on different grounds, holding that the Longshore and Harbor Workers’ Compensation Act (LHWCA) displaced general maritime law, making California’s workers’ compensation scheme Ranger’s exclusive remedy.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that the 1984 amendments to the LHWCA, which exclude certain workers from federal workers' compensation if they are covered by state laws, did not abrogate general maritime remedies for those outside the LHWCA’s scope. The court also determined that California’s workers’ compensation exclusive-remedy provision could not deprive Ranger of his substantive federal maritime rights under the supremacy clause of the federal Constitution. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings to address unresolved issues, including whether Ranger’s claims properly invoked admiralty jurisdiction. View "Ranger v. Alamitos Bay Yacht Club" on Justia Law

Michael Ayala, a correctional officer for California’s Department of Corrections and Rehabilitation (CDCR), was injured in a planned attack by inmates. He filed a workers’ compensation claim, asserting that his injuries were due to CDCR’s serious and willful misconduct in failing to address a credible threat of inmate violence. A workers’ compensation administrative law judge (WCJ) initially rejected this claim, but the Workers’ Compensation Appeals Board (Board) found in favor of Ayala, concluding that he was entitled to a 50 percent increase in compensation under Labor Code section 4553 due to CDCR’s serious and willful misconduct.The CDCR did not dispute the finding of serious and willful misconduct but argued that the 50 percent increase should be calculated based on the temporary disability (TD) benefits Ayala would have received under the workers’ compensation law, not the more generous industrial disability leave (IDL) and enhanced industrial disability leave (EIDL) benefits he received under the Government Code. The WCJ agreed with CDCR, but the Board reversed, including IDL and EIDL benefits in the calculation of the increased compensation.The California Supreme Court reviewed the case and agreed with the Court of Appeal, which had reversed the Board’s decision. The Supreme Court held that the term “compensation” under Labor Code section 4553, as defined in section 3207, is limited to benefits provided under the workers’ compensation law. Therefore, the 50 percent increase in compensation for serious and willful misconduct should be calculated based on the TD benefits Ayala was entitled to under the workers’ compensation law, not the IDL and EIDL benefits provided under the Government Code. The judgment of the Court of Appeal was affirmed. View "Dept. of Corrections & Rehabilitation v. Workers' Comp. Appeals Bd." on Justia Law

The defendant was convicted and sentenced to death for the murder of Alfonso Martinez during a robbery and kidnapping, and for the attempted murder of Deborah Pizano. The jury also found him guilty of several other crimes, including second-degree robbery and multiple counts of attempted murder related to a separate drive-by shooting. The jury found true the allegations that a principal discharged a firearm causing death or great bodily injury but did not find that the crimes were committed for the benefit of a criminal street gang.The trial court denied the defendant's motion to suppress his custodial statements, finding that he was properly advised of his Miranda rights and that his waiver was voluntary. The court also denied the defendant's motion to sever the charges related to the two incidents, finding that the evidence was cross-admissible and that the charges were of the same class. The jury was instructed on multiple theories of liability, including direct aiding and abetting, natural and probable consequences, and felony murder.The California Supreme Court reviewed the case and reversed the six counts of attempted premeditated murder and the one count of being an active participant in a criminal street gang. The court also vacated the gang-murder special-circumstance true finding. The court affirmed the judgment in all other respects, including the first-degree murder conviction and the death sentence. The court found that the instructional errors related to the natural and probable consequences doctrine and felony murder were harmless beyond a reasonable doubt for the murder conviction but not for the attempted murder convictions. The court also held that the evidence was insufficient to support the gang allegations under the amended statute. View "P. v. Hin" on Justia Law

A landowner sought to confirm that a conveyance occurring before March 4, 1972, created separate parcels under the Subdivision Map Act. The property in question was described in a 1944 deed as Lot 18, Lot 17, and a portion of Lot 16 on an antiquated subdivision map. The landowner argued that this conveyance created three separate parcels, including Lot 18, and sought a certificate of compliance to confirm Lot 18 as a separate legal parcel.The Alameda County Superior Court denied the landowner's petition for a writ of mandate to compel the City of Oakland to issue the certificate. The landowner appealed, and the First Appellate District, Division One, reversed the trial court's decision, concluding that Lot 18 was a separate parcel entitled to the conclusive presumption of legality under section 66412.6(a) of the Subdivision Map Act.The Supreme Court of California reviewed the case and reversed the Court of Appeal's judgment. The court held that the phrase "division of land" in section 66412.6(a) should be interpreted in light of the Act’s general definition of "subdivision" in section 66424. The court concluded that a conveyance does not create multiple parcels merely by referring separately to lots of the contiguous property being conveyed. Since Lot 18 was always conveyed together with contiguous land and never separately, it was not created as a separate parcel under the Act. Therefore, the landowner was not entitled to a certificate of compliance for Lot 18 as a separate legal parcel. View "Cox v. City of Oakland" on Justia Law

In October 2014, Oscar Lopez and Sergio Vidrio stopped their car next to Nestor M. and Noel A.'s car. After a brief exchange, Lopez and Vidrio fired multiple shots, killing Nestor and injuring Noel. Lopez was convicted of first-degree murder, attempted premeditated murder, shooting at an occupied vehicle, and possession of a firearm by a felon. The jury found that Lopez committed the crimes for the benefit of a criminal street gang and used a firearm. Lopez was sentenced to 141 years to life in prison.Lopez appealed, and the Court of Appeal modified his sentence and conditionally reversed the judgment, remanding the case to the trial court for resentencing under Senate Bill Nos. 620 and 1393. While awaiting resentencing, Assembly Bill 333, which amended the gang enhancement statute, was enacted. The trial court declined to apply Assembly Bill 333 retroactively, resentencing Lopez to 101 years to life. Lopez appealed again, and the Court of Appeal held that the judgment was nonfinal for Estrada purposes but that the superior court lacked jurisdiction to apply Assembly Bill 333.The Supreme Court of California reviewed the case and held that Lopez was entitled to the retroactive application of Assembly Bill 333 because his judgment was not final for Estrada purposes. The court clarified that a criminal case is not final until the entire prosecution, including sentencing, is complete. The court reversed the judgment below and remanded for further proceedings consistent with its opinion, allowing Lopez to renew his arguments for resentencing under Senate Bill Nos. 567 and 81. View "P. v. Lopez" on Justia Law