Justia California Supreme Court Opinion Summaries

In this action challenging Stanislaus County's classification of well construction permits the Supreme Court held that the blanket classification of all permit issuances as ministerial was unlawful and that under the ordinance authorizing the issuance of these permits some of the County's decisions may be discretionary.Under the California Environmental Quality Act (CEQA), Cal. Pub. Resources Code, 21000 et seq., any government action that may directly or indirectly cause a physical change to the environment is a project, including the issuance of a permit. Projects can be either discretionary or ministerial actions, and discretionary projects general require some level of environmental review, while ministerial projects do not. In this case, Plaintiffs challenged Stanislaus County's practice of categorically classifying a subset of its issuance of well construction permits as ministerial, arguing that the permit issuances are discretionary projects requiring CEQA review. The trial court found the permit issuances were ministerial. The Court of Appeal reversed. The Supreme Court reversed in part, holding (1) Plaintiffs were entitled to a declaration that classifying all issuances as ministerial violates CEQA; but (2) Plaintiffs were not entitled to injunctive relief because they failed to demonstrate that all permit decisions covered by the classification practice were discretionary. View "Protecting Our Water & Environmental Resources v. County of Stanislaus" on Justia Law

The Supreme Court overturned the death penalty for Scott Peterson, who, in 2002, was convicted of killing his wife, Laci Peterson, and the couple's unborn son, holding that the trial court made a series of clear and significant errors in jury selection that undermined Peterson's right to an impartial jury at the penalty phase.The Supreme Court affirmed the judgment as to guilt but reversed the judgment as to the sentence of death, holding (1) Defendant received a fair trial as to guilt; (2) the trial court erred by dismissing many prospective jurors because of written questionnaire responses expressing opposition to the death penalty, even though the jurors gave no indication that their views would prevent them from following the law; and (3) under United States Supreme Court precedent, these errors required reversal of the death sentence in this case. View "People v. Peterson" on Justia Law

The Supreme Court held that the monetary cap of $500 in statutory damages in Cal. Health & Safety Code 1430(b) applies per action, not per regulatory violation.Section 1430(b) gives a current or former nursing care patient or resident the right to bring a private cause of action against a skilled nursing facility for violating certain regulations. The remedies include injunctive relief, attorney fees, and up to $500 in statutory damages. Plaintiff in the instant case filed a complaint against a nursing facility alleging violations of the Patients Bill of Rights, elder abuse and neglect, and negligence. The jury awarded Plaintiff $100,000 in damages and $95,500 in statutory damages - $250 for each of 382 violations. At issue on appeal was whether the $500 cap is the limit in each action or instead applies to each violation committed. The Supreme Court reversed, holding that section 1430(b) authorizes a $500 per lawsuit cap. View "Jarman v. HCR ManorCare, Inc." on Justia Law

The Supreme Court affirmed the judgments of the of the trial court convicting Defendants of first degree murder and other crimes and sentencing both defendants to death, holding that no prejudice resulted from any error of the trial court.Separate juries convicted Daniel Silveria and John Travis of first degree murder, second degree robbery, and second degree burglary. After retrials, a single penalty jury returned death verdicts. The Supreme Court affirmed, holding (1) during the guilt phase, the trial court did not err in denying Travis's motion to suppress or in instructing the jury on first degree murder; and (2) during the joint penalty retrial, there was no abuse of discretion in denying Defendants' severance motions, the trial court did not wrongfully excuse for cause prospective jurors, the trial court did not err in admitting portions of Silveria's first penalty phase testimony, any error in placing conditions on proffered testimony by Travis's trial counsel was harmless, and any other assumed or actual error was not prejudicial. View "People v. Silveria" on Justia Law

Here, the Supreme Court addressed the propriety of a criminal defense subpoena served on Facebook seeking restricted posts and private messages of one of its users, who was a victim and critical witness in the underlying attempted murder prosecution, holding that the trial court erred in denying Facebook's motion to quash the subpoena.Lance Touchstone, the defendant in the prosecution below, argued that the trial court properly denied Facebook's motion to quash. The Supreme Court disagreed, holding that the trial court erred by conducting an incomplete assessment of the relevant factors and interests when it found that Defendant established good cause to acquire the communications at issue from Facebook. After highlighting seven factors a trial court should explicitly consider and balance in ruling on a motion to quash a subpoena directed to a third party the Supreme Court vacated the trial court's order denying the motion to quash and remanded the matter to the trial court to conduct further proceedings consistent with the guidelines set forth in this opinion. View "Facebook, Inc. v. Superior Court" on Justia Law

The Supreme Court affirmed Defendant's convictions for four counts of first degree murder and other crimes and sentence of death, holding that, considering any actual or assumed errors altogether, their cumulative effect did not warrant reversal of Defendant's convictions or sentence.Specifically, the Supreme Court held (1) assuming that the trial court erred by using an unsworn, uncertified interpreter during the preliminary hearing and to interpret a victim's outburst, there was no prejudice; (2) sufficient evidence supported the theory of felony murder for two murders, and even assuming there was no sufficient evidence, the first degree murder verdicts would still be upheld; (3) there was assumed or found error during trial regarding difficulties that made it difficult to hearing the court proceedings, the accuracy of interpreters, and other issues, but there was no prejudice; and (4) none of the assumed or actual errors, considered either individually or collectively, warranted reversal of Defendant's convictions or sentence. View "People v. Suarez" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of first degree murder and one count of second degree murder with a multiple murder special circumstance and various gun use enhancements, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion for a venue change; (2) the trial court did not err in denying Defendant's motion to suppress items discovered during a warrantless search of his vehicle; (3) Defendant's decision not to testify was knowing, intelligent, and voluntary; (4) the trial court did not improperly exclude a defense expert; (5) the trial court did not err by denying Defendant's pretrial motion to exclude evidence of his gang membership; (6) there was no instructional error; (7) the prosecutor did not commit misconduct during penalty phase argument; and (8) Defendant's challenges to the victim impact testimony were unavailing. View "People v. Duong" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of first degree murder and other crimes, holding that there was no error or abuse of discretion during the guilt phase or penalty phase of trial.Specifically, the Supreme Court held (1) the evidence was sufficient to show that Defendant committed the murders with premeditation and deliberation; (2) the trial court did not err in admitting testimony of the People's crime scene reconstruction expert; (3) the trial court did not abuse its discretion by admitting certain crime scene and autopsy photographs of the victims; and (4) during the penalty phase, the trial court did not err by admitting victim impact testimony or in instructing the jury. View "People v. Morales" on Justia Law

The Supreme Court held that *Cal. Civ. Code 1431.2, subdivision (a) does not authorize a reduction in the liability of intentional tortfeasors for noneconomic damages based on the extent to which the negligence of other actors contributed to the injuries in question.While attempting to subdue Barley, law enforcement officers, including Defendant, used their knees to pin Barley to the ground. Burley eventually lost consciousness and died ten days later. The jury found Defendant had committed battery by using unreasonable force against Burley and that twenty percent of the responsibility for Burley's death was attributable to Defendant's actions. The court entered a judgment against Defendant for the entire amount of the jury's award of noneconomic damages. The Court of Appeal reduced the judgment in accordance with the jury's allocation of responsibility to Defendant, expressly disagreeing with the holding in Thomas v. Duggins Construction Co., 139 Cal.App.4th 1005 (2006), that an intentional tortfeasor is not entitled to a reduction or apportionment of noneconomic damages under section 1431.2, subdivision (a). The Supreme Court reversed, holding that because section 1431.2, subdivision (a) incorporates principles of comparative fault, the statute does not entitle Defendant to reduce his liability based on the acts of Burley or the other defendants. View "B.B. v. County of Los Angeles" on Justia Law

The Supreme Court held that tortious interference with at-will contracts requires independent wrongfulness and that a rule of reason applies to determine the validity of a settlement provision requiring Forward Pharma to terminate its agreement with Ixchel Pharma, LLC under Cal. Bus. & Prof. Code 16600.Ixchel, a biotechnology company, entered into an agreement with Forward jointly to develop a drug for the treatment of Friedreich's ataxia. Forward later withdrew from the agreement, which was allowed by the agreement's terms. Pursuant to a settlement with Biogen, Inc., another biotechnology company, Forward agreed to terminate its contract with Ixchel. Ixchel sued Biogen in federal court for tortiously interfering with Ixchel's contractual and prospective economic relationship with Forward in violation of section 16600. On appeal, the federal appeals court certified two questions to the Supreme Court. The Supreme Court held (1) tortious interference with at-will contracts requires independent wrongfulness, and therefore, Ixchel must allege that Biogen interfered with its at-will contract through wrongful means; and (2) the validity of the settlement provision at issue must be evaluated based on a rule of reason. View "Ixchel Pharma, LLC v. Biogen, Inc." on Justia Law