Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed the court of appeal's judgment ordering four of Defendant's sentence enhancements stricken, holding that a convicted defendant who is placed on probation after imposition of sentence is suspended, and who does not timely appeal from the order granting probation, may take advantage of ameliorative statutory amendments that take effect during a later appeal from a judgment revoking probation and imposing sentence.In three separate cases, Defendant pleaded guilty to drug-related offenses and admitting having sustained four prior felony drug-related convictions for purposes of sentence enhancement under Cal. Health & Safety Code former 11370.2. The trial court later revoked probation and imposed a prison sentence that included four three-year prior drug conviction enhancements under former section 11370.2(c). Thereafter, the governor signed Senate Bill No. 180, which revised section 11370.2 so that Defendant's prior drug-related convictions no longer qualified Defendant for sentence enhancement. The Supreme Court remanded the case for reconsideration in light of the revised statute. On remand, the court of appeal concluded that Defendant could take advantage of the revisions to the statute that rendered the sentence enhancements inapplicable to Defendant's prior drug-related convictions. The Supreme Court affirmed, holding that the Legislature must have intended section 11370.2's ameliorative changes to operate in cases like this one. View "People v. McKenzie" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that the admission of expert testimony did not violate the prohibition against communication of case-specific hearsay set forth in People v. Sanchez, 63 Cal.4th 665 (2016) and that sufficient evidence supported Defendant's conviction for possession of alprazolam, holding that the court of appeal did not err.Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for his or her opinion unless the facts are independently proven or fall within a hearsay exception. In the instant case, an expert told the jury that he identified the controlled substance Defendant was charged with possessing by comparing the visual characteristics of the pills seized against a database containing descriptions of pharmaceuticals. On appeal, Defendant argued that the expert related inadmissible case-specific hearsay. The court of appeal affirmed. The Supreme Court affirmed, holding (1) the expert related no inadmissible case-specific hearsay in testifying to the contents of a drug identification database; and (2) substantial evidence supported Defendant's conviction. View "People v. Veamatahau" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that a defense counsel's failure to object at trial, before People v. Sanchez, 63 Cal.4th 665 (2016), was decided, forfeited a claim that a gang expert's testimony related case-specific hearsay in violation of the confrontation clause, holding that a defense counsel's failure to object under such circumstances does not forfeit a claim based on Sanchez.Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for her opinion unless the facts are independently proven or fall within a hearsay exception. Defendants in the instant case were each convicted of two counts of first degree special circumstance murder and other crimes. Before Defendants' appeals were resolved, the Supreme Court issued its opinion in Sanchez. On appeal, one of the defendants argued that a gang expert testified to case-specific hearsay in violation of the confrontation clause. The court of appeal held that the defendant's failure to object to case-specific hearsay in expert testimony at trial forfeited any Sanchez claim on appeal. The Supreme Court reversed, holding that the court of appeal erred in finding that the defendant forfeited his claim on appeal based on Sanchez by failing to object at a trial that occurred before Sanchez was decided. View "People v. Perez" on Justia Law

The Supreme Court affirmed the decision of the appellate court dismissing a minor's appeal challenging the juvenile court's neglect of its mandatory duty under Cal. Welf. & Inst. Code 702 to declare a wobbler offense to be a misdemeanor or a felony, holding that the minor may not bring such a challenge in an appeal from a later dispositional order after the time to appeal the original disposition expired.Two wardship petitions were filed against G.C. alleging that G.C. committed three wobbler offenses. G.C. admitted all three allegations. The court, however, did not declare on the record whether the offenses were felonies or misdemeanors. Thereafter, G.C. was adjudged a ward and placed on probation. G.C. did not appeal the disposition. After G.C. violated the terms of her probation the juvenile court maintained G.C. in her mother's custody under the supervision of the probation department with various conditions. G.C. appealed, arguing that the court failed expressly to declare whether the offenses were misdemeanors or felonies. The appellate court determined that the issue was not timely raised. The Supreme Court affirmed, holding that although section 702 is mandatory, noncompliance did not make the original dispositional order an unauthorized sentence that could be corrected at any time. View "In re G.C." on Justia Law

The Supreme Court affirmed the decision of the court of appeal affirming the trial court's grant of Defendant's demurrer and dismissing Plaintiff's complaint alleging that Defendant negligently allowed a fire to spread from Defendant's property to Plaintiff's property, harming some of Plaintiff's trees, holding that Plaintiff could not rely on Cal. Civ. Code 3346's extended statute of limitations and that his complaint was otherwise untimely.Section 3346 provides enhanced damages to plaintiffs suffering wrongful injuries to timber, trees, or underwood. The relevant statute of limitations where a plaintiff seeks such damages is five years. In this case, Plaintiff alleged that section 3346's enhanced damages and five-year statute of limitations applied to property damage from a fire negligently allowed to escape from Defendant's property. Defendant filed a demurrer, arguing that Plaintiff's claims were time-barred. The trial court granted the demurrer. The court of appeal affirmed, concluding that the three-year statute of limitations in Cal. Code Civ. Proc. 338(b) applied to this action for trespass upon or injury to real property. The court of appeal agreed. The Supreme Court affirmed, holding that section 3346 is inapplicable to damages to timber, trees, or underwood from negligently escaping fires and that Plaintiff's complaint was otherwise untimely. View "Scholes v. Lambirth Trucking Co." on Justia Law

The Supreme Court granted the request of the United States Court of Appeals for the Ninth Circuit to decide a question of California law regarding Industrial Welfare Commission wage order No. 7-2001 (Wage Order 7), which requires employers to pay their employees a minimum wage for all "hours worked," concluding that time spent on the employer's premises waiting for, and undergoing, mandatory exit searches of bags, packages, or personal technology devices voluntarily brought to work purely for personal convenience by employees is compensable as "hours worked" within the meaning of Wage Order 7.Employees filed a class action complaint against Employer, Apple Inc., alleging that Employer failed to pay them minimum and overtime wages for time spent waiting for and undergoing Employer's exit searches in violation of California law. A federal district court granted summary judgment for Employer. On appeal, the Ninth Circuit asked the Supreme Court to address the state law issue. The Supreme Court concluded that, in the instant case, Employees' time spent on Employer's premises waiting for, and undergoing, required exit searches of packages, bags, or personal technology devices, such as iPhones, brought to work purely for personal convenience, is compensable as "hours worked" within the meaning of Wage Order 7. View "Frlekin v. Apple Inc." on Justia Law

The Supreme Court granted Petitioner habeas corpus relief, holding that Petitioner was denied his constitutional right to the assistance of competent counsel at the guilt phase of his criminal trial, and trial counsel's deficient performance undermined the reliability of the jury's guilty verdict.Petitioner was convicted of the first degree murder of a police officer and sentenced to death. While his appeal was pending, Petitioner filed his first petition for a writ of habeas corpus, arguing that the judgment should be vacated because he had received constitutionally ineffective assistance of counsel. During the habeas proceedings, the Supreme Court found that Petitioner's trial counsel had defrauded Petitioner in order to induce Petitioner to retain him instead of the public defender. Counsel went on to commit serious errors during the penalty phase undermining the reliability of the death verdict. The Supreme Court granted the petition and ordered a new penalty phase trial. Petitioner later filed this petition for a writ of habeas corpus challenging his convictions. The Supreme Court granted the writ and vacated Defendant's conviction for first degree murder, holding that Petitioner was denied the effective assistance of counsel at the guilt phase of his trial. View "In re Gay" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree murder, finding Defendant was sane at the time of the crimes, and sentencing Defendant to death, but struck an improperly imposed restitution fine, holding that the restitution fine should be stricken from the abstract of judgment and that any other error was not prejudicial.The trial court imposed a $10,000 restitution fine but did not impose the fine at the sentencing hearing. Rather, the fine was later added to the abstract of judgment. The Supreme Court ordered the restitution fine stricken from the record and the minutes because the trial court never imposed the fine in open court in Defendant's presence. The Court assumed other errors during the trial proceedings but found no prejudice. Further, the Court held that the error regarding the restitution fine and any assumed error were not cumulatively prejudicial. View "People v. Frederickson" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and kidnapping and sentence of death, holding that Defendant was not entitled to relief.Specifically, the Court held (1) the superior court did not err in exercising its jurisdiction in this matter; (2) the trial court did not err in the voir dire proceedings; (3) Defendant's argument that there was a material variance between the kidnap alleged in the indictment and the prosecutor's argument regarding his actual offense was unavailing; (4) the trial court did not err in admitting Defendant's custodial confession; (5) the trial court did not err by compelling Defendant to testify as a foundation for testimony by Defendant's expert that his confession was false; (6) the trial court did not err by limiting expert witness testimony; (7) the trial court did not err by compelling Defendant to undergo a prosecution-conducted psychiatric examination; (8) the prosecutor did not commit misconduct during the guilt phase closing argument; (9) there was no instructional error; (10) there was sufficient evidence to support the kidnap-murder special circumstance; (11) Defendant's claims of prosecutorial misconduct during the penalty phase closing argument lacked merit; and (12) Defendant's remaining penalty phase claims were unavailing. View "People v. Hoyt" on Justia Law

The Supreme Court reversed the decision of the court of appeal dismissing an appeal of an order directing an attorney to pay sanctions because the notice of appeal identified the attorney's client as the appealing party but other indicia made it clear that the attorney was the party seeking review, holding that, under the circumstances of this case, the notice of appeal should be construed to include the omitted attorney.Attorney represented K.J. in a negligence action against the Los Angeles Unified School District (collectively, LAUSD). During the litigation, LAUSD filed an application seeking sanctions from Attorney. The trial court awarded sanctions based on its finding that Attorney had violated discovery statutes. A notice of appeal was filed by K.J.'s attorney. The court of appeal dismissed the appeal for lack of jurisdiction, holding that when a sanctions order is entered against an attorney, the right of appeal is vested in the attorney and not the attorney's client. The Supreme Court reversed, holding that when it is clear from the record that the omitted attorney intended to participate in the appeal and the respondent was not misled or prejudiced by the omission, the rule of liberal construction requires that the notice be construed to include the omitted attorney. View "K.J. v. Los Angeles Unified School District" on Justia Law