Justia California Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeal affirming the decision of the trial court to sentence Defendant to three years for robbery with a twenty-five-years-to-life enhancement under Cal. Penal Code 12022.53(d), holding that the the trial court erred in denying Defendant's motion to strike.A jury convicted Defendant of second degree robbery, assault with a semiautomatic firearm, and driving under the influence. The jury found true the firearm use enhancements on the robbery and assault counts. Before sentencing, Defendant moved under Cal. Penal Code 12022.53(h) to strike the firearm enhancement under section 12022.53(d). The court denied Defendant's motion. On appeal, Defendant argued that the trial court abused its discretion because it was unaware that it could strike the enhancement at issue and then impose a lesser enhancement under either section 12022.53(b) or (c). The court of appeal affirmed, concluding that the trial court could not strike the enhancement and substitute a different unalleged enhancement. The Supreme Court reversed, holding that the Legislature has permitted courts to impose a section 12022.53(b) or (c) penalty when only a section 12022.53(d) enhancement is charged and found true. View "People v. Tirado" on Justia Law

The Supreme Court held that Curtis Olson failed to show the requisite "minimal merit" on a critical element of his breach of contract claim and thus could not defeat Jane Doe's anti-SLAPP motion.Doe and Olson each owned units in the same condominium building. Doe brought a civil harassment restraining order against Olson, and as a result of court-ordered mediation, the parties agreed if they encountered each other in a public or common place "not to disparage one another." Doe later filed a civil lawsuit against Olson seeking damages. Olson cross-complained for breach of contract and specific performance, and Doe moved to strike Olson's cross-complaint under the anti-SLAPP statute. The Supreme Court reversed the court of appeal's judgment insofar as it reversed the trial court's order granting Doe's special motion to strike the breach of contract clause of action with respect to statements in Doe's civil complaint, holding that Doe had no obligation under the contract to refrain from making disparaging statements in litigation, and therefore, Olson could not defeat Doe's anti-SLAPP motion. View "Olson v. Doe" on Justia Law

The Supreme Court affirmed Defendant's convictions for first degree murder and other crimes and Defendant's death sentence, holding that any found or assumed errors were individually harmless and that there was no cumulation of error that merited reversal.Specifically, the Supreme Court found or assumed errors in the admission of prior crimes evidence, a prosecutorial misconduct claim concerning a jury argument that Defendant signed a parole form advising him of a possible life sentence, a claim that the defense was prevented from responding to the prosecutor's argument, a claim that certain expert testimony usurped the trial court's role to instruct the jury about the law, and four additional prosecutorial misconduct claims. The Court held (1) any assumed or actual error in each of these claims was individually harmless; and (2) there was no cumulative error warranting reversal. View "People v. Johnson" on Justia Law

The Supreme Court held that the Department of Corrections and Rehabilitation acted within the authority provided by Cal. Const. art. I, 32(b) when it adopted regulations prohibiting early parole consideration under the scheme set forth in Proposition 57, The Public Safety and Rehabilitation Act of 2016, for inmates "currently serving a term of incarceration for a 'violent felony.'"After Petitioner was convicted of nine violent felony counts and six nonviolent felony counts voters approved Proposition 57. The Department subsequently adopted regulations implementing early parole considerations, including the regulations at issue here. Consistent with these regulations, the Department determined that Petitioner was ineligible for nonviolent offender early parole consideration because he was serving a term of incarceration for a violent felony. The court of appeal granted relief, concluding that the language of article I, section 32(a) requires early parole consideration for any inmate convicted of a nonviolent felony even when that inmate was also convicted of a violent felony. The Supreme Court reversed, holding that the Department acted within its authority provided by article I, section 32(b) when it adopted the regulation at issue. View "In re Mohammad" on Justia Law

The Supreme Court held that Cal. Health & Safety Code 13009 and 13009.1 incorporate the common law theory of respondent superior, and therefore, a corporation cannot be held vicariously liable for the cost of suppressing fires that its agents or employees negligently or unlawfully set or allowed to escape.After a 2016 wildfire burned nearly 7,500 acres of land in California, the California Department of Forestry and Fire Protection (CalFire) determined that the fire had started on the property of Defendant, Presbyterian Camp and Conference Centers, Inc., when an employee of Defendant removed a smoldering log from a fireplace in one of Defendant's cabins. CalFire brought suit, seeking recovery of its expenses from Defendant. Defendant demurred, contending that sections 13009 and 13009.1 do not contemplate vicarious liability. The trial court overruled the demurrer. Thereafter, Defendant brought a writ petition challenging the trial court's order. The court of appeals denied the writ. The Supreme Court affirmed, holding that sections 13009 and 13009.1 incorporate the common law theory of respondent superior. View "Presbyterian Camp & Conference Centers v. Superior Court" on Justia Law

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