Justia California Supreme Court Opinion Summaries

In June 2012, Maurice Walker assaulted a woman and a 78-year-old man in Los Angeles. Walker was convicted of assault with a deadly weapon, elder abuse, and misdemeanor battery. The jury found true the enhancement allegations that he used a deadly weapon and inflicted great bodily injury on an elderly person. Walker admitted to having prior strike convictions and a prior serious felony conviction. Initially, he was sentenced to 20 years in prison, which was later reduced to 19 years after one enhancement was struck in a habeas proceeding. Another habeas proceeding in 2018 led to the removal of his remaining prior prison term enhancement, and the case was remanded for potential resentencing.The Los Angeles County Superior Court conducted a full resentencing hearing in April 2022. Despite the new provisions of Penal Code section 1385, subdivision (c)(2), which favor dismissing enhancements under certain mitigating circumstances, the trial court declined to dismiss Walker’s enhancements. The court did not find it in the interest of justice to dismiss the enhancements, even though multiple enhancements were present. Walker appealed, arguing that the trial court misapplied section 1385.The California Supreme Court reviewed the case to resolve a conflict between appellate courts on the interpretation of section 1385, subdivision (c)(2). The court concluded that the statute does not create a rebuttable presumption in favor of dismissing an enhancement unless it endangers public safety. Instead, it requires trial courts to give significant weight to mitigating circumstances but allows them to consider other factors. The court affirmed the judgment of the Court of Appeal, finding that Walker was not entitled to relief under the clarified interpretation of the statute. View "P. v. Walker" on Justia Law

John’s Grill, Inc., a restaurant in San Francisco, suffered significant financial losses during the COVID-19 pandemic and sought compensation from its property insurer, Sentinel Insurance Company, Ltd. Sentinel denied the claim, stating that the losses did not fall under the policy’s “Limited Fungi, Bacteria or Virus Coverage” endorsement, which only covers virus-related losses if the virus results from specific causes like windstorms or water damage. John’s Grill argued that this limitation made the virus-related coverage illusory and unenforceable.The San Francisco City and County Superior Court sustained Sentinel’s demurrer, finding the policy language clear and enforceable. The court reasoned that the specified causes of loss could potentially cause virus damage, thus the coverage was not illusory. The Court of Appeal reversed, agreeing with John’s Grill that the specified cause of loss limitation rendered the virus coverage illusory, as the listed causes were not realistically related to virus transmission. The appellate court held that the policy’s promise of virus-related coverage was illusory and allowed John’s Grill’s claims to proceed.The Supreme Court of California reversed the Court of Appeal’s decision. The court held that the policy’s specified cause of loss limitation was clear and unambiguous, and thus enforceable. It concluded that John’s Grill did not have a reasonable expectation of coverage for pandemic-related losses under the policy. The court also determined that the illusory coverage doctrine, as articulated by John’s Grill, did not apply because the policy did offer a realistic prospect for virus-related coverage under certain conditions. The case was remanded for further proceedings consistent with this opinion. View "John's Grill, Inc. v. The Hartford Financial Services Group, Inc." on Justia Law

In June 2017, Scotlane McCune crashed a vehicle into a tree while driving without a license, injuring his passenger, Miguel Villa. McCune fled the scene, leading to charges of felony hit and run with injury and misdemeanor driving without a license. He pleaded no contest to the felony charge, and the misdemeanor was dismissed. In June 2018, McCune was placed on five years’ probation and ordered to pay restitution to Villa, with the amount to be determined later. In December 2020, Villa sought $30,166.23 in restitution. However, new legislation effective January 1, 2021, capped felony probation at two years, leading to the termination of McCune’s probation on January 14, 2021. The trial court later set the restitution amount at $21,365.94.McCune objected, arguing that the court lacked authority to set the restitution amount after his probation ended. The trial court disagreed, citing Penal Code sections 1202.4 and 1202.46, which allow the court to retain jurisdiction to determine restitution amounts until the victim’s losses are ascertainable. The Court of Appeal upheld this decision, stating that the court’s authority to fix restitution amounts persists even after probation ends, as per sections 1202.4 and 1202.46.The Supreme Court of California affirmed the Court of Appeal’s judgment. The court held that section 1202.46 applies to both probation and nonprobation cases, allowing the court to retain jurisdiction to set restitution amounts once the victim’s losses become ascertainable. The court rejected McCune’s argument that section 1203.3 limits this authority to the probation term, clarifying that section 1202.46 provides additional authority to ensure full victim restitution, consistent with the constitutional mandate. The court disapproved of contrary interpretations in Hilton v. Superior Court and People v. Waters. View "P. v. McCune" on Justia Law

Robert Ward Frazier was convicted by a jury of the murder, forcible rape, and forcible sodomy of Kathleen Loreck. The jury also found true two felony-murder special-circumstance allegations. At the penalty phase, the jury returned a death verdict, which the trial court upheld, sentencing Frazier to death. Frazier's appeal is automatic.The trial court excused a prospective juror for cause due to his views on the death penalty, denied Frazier's request for individually sequestered voir dire, and gave a jury instruction on flight from the scene of a crime. The court also denied Frazier's requests to represent himself during the penalty phase and post-verdict proceedings, including the hearing on his automatic motion to modify the death verdict and sentencing.The California Supreme Court affirmed the trial court's decisions. The court held that the trial court did not err in excusing the prospective juror, as substantial evidence supported the finding that the juror's views would substantially impair his performance. The court also found no error in denying individually sequestered voir dire, as there is no federal constitutional requirement for such in capital cases, and the trial court did not abuse its discretion under state law.The court upheld the flight instruction, finding sufficient evidence to support it and rejecting Frazier's additional arguments against the instruction. The court also ruled that Frazier's requests for self-representation were untimely and that the trial court did not abuse its discretion in denying them. Finally, the court rejected Frazier's claim that his Sixth Amendment right to choose the objective of his defense was violated by the presentation of certain mitigating evidence over his objection. View "P. v. Frazier" on Justia Law

Wilson next argues that the trial court erred in admitting statements he made to detectives after the break when he was outside smoking with Detective Hagen. As Wilson notes, Detective Hagen agreed to end the interview in response to Wilson’s statement that he was not going to discuss the case further and request to be taken back to the holding cell. These circumstances reflect Wilson’s unambiguous invocation of his right to remain silent. (People v. Krebs, supra, 8 Cal.5th at p. 313 [defendant’s invocation was unambiguous when he asked to be returned to his cell and told officers he had nothing to say].) Despite recognizing that Wilson no longer wished to speak, Detective Hagen made additional comments that were reasonably likely to prompt Wilson to continue speaking: He encouraged Wilson to cooperate “right now” to get beneficial treatment before his “partner” did, and he stated that he had “[n]o doubt [Wilson] did it.”However, the trial court found that Wilson reinitiated the conversation during the cigarette break, and substantial evidence supports this finding. Detective Hagen testified that Wilson began discussing the case again during the break, expressing concerns about his family’s safety and asking questions about the investigation. This testimony indicates that Wilson voluntarily chose to resume the conversation, thereby waiving his previously invoked right to remain silent. The trial court’s credibility determinations and factual findings are supported by substantial evidence, and we defer to those findings.Given these circumstances, the trial court did not err in admitting the statements Wilson made to the California detectives after the cigarette break. Wilson’s reinitiation of the conversation and his voluntary engagement in the subsequent interview indicate that his statements were not the product of coercion or improper interrogation tactics. Therefore, the admission of these statements did not violate Wilson’s Fifth Amendment rights. View "P. v. Wilson" on Justia Law

The case involves three Lyft drivers, Tina Turrieta, Brandon Olson, and Million Seifu, who each filed separate lawsuits under the California Labor Code Private Attorneys General Act of 2004 (PAGA) against Lyft, Inc. for alleged labor violations. Turrieta settled her case with Lyft, but before the settlement was approved, Olson and Seifu sought to intervene and object to the settlement, arguing it was unfair and that they had overlapping claims. The trial court denied their motions to intervene, approved the settlement, and later denied their motions to vacate the judgment.Olson and Seifu appealed the trial court's decisions. The Court of Appeal affirmed the trial court's rulings, holding that Olson and Seifu lacked standing to intervene or to challenge the settlement because they were not aggrieved by the judgment. The appellate court reasoned that PAGA actions are representative actions on behalf of the state, and thus, Olson and Seifu did not have a personal interest in the settlement of Turrieta’s PAGA claim.The California Supreme Court reviewed the case and agreed with the Court of Appeal. The Supreme Court held that PAGA does not authorize one aggrieved employee to intervene in another employee’s PAGA action asserting overlapping claims. The Court reasoned that allowing such intervention would be inconsistent with the statutory scheme of PAGA, which provides for oversight of settlements by the Labor and Workforce Development Agency (LWDA) and the courts, but does not mention intervention by other PAGA plaintiffs. The Court emphasized that the statutory language and legislative history indicate that the Legislature intended for the LWDA and the courts to ensure the fairness of PAGA settlements, not other PAGA plaintiffs.The Supreme Court affirmed the judgment of the Court of Appeal, concluding that Olson and Seifu did not have the right to intervene, object to, or move to vacate the judgment in Turrieta’s PAGA action. View "Turrieta v. Lyft, Inc." on Justia Law

Deandre Lynch was convicted of three counts of domestic violence resulting in a traumatic condition and one count of simple assault. The trial court imposed an upper term sentence based on eight aggravating circumstances, including Lynch's use of a weapon and his prior convictions. The court cited Lynch's criminal history and the severity of his actions as reasons for the upper term sentence.The Court of Appeal affirmed the upper term sentence, finding that two of the aggravating circumstances were proven in compliance with the current law, but the remaining six were not. The court applied a "reasonably probable" standard to determine that the failure to satisfy the current statute was harmless error.The California Supreme Court reviewed the case to determine the appropriate standard for remanding cases for resentencing under the amended Penal Code section 1170(b). The court held that a sentence imposed under the former version of section 1170(b) must be reversed and remanded unless the reviewing court concludes beyond a reasonable doubt that a jury would have found true all of the aggravating facts upon which the trial court relied to justify the upper term sentence, or that those facts were otherwise proven in compliance with the current statute.The court concluded that Lynch's sentence must be reversed and remanded for resentencing because the trial court relied on aggravating facts that were not proven beyond a reasonable doubt by a jury. The court also applied the Gutierrez standard, which requires a remand unless the record clearly indicates that the trial court would have imposed the same sentence even if it had been aware of its more limited discretion under the current law. The court found that the record did not clearly indicate that the trial court would have imposed the same sentence under the new law. View "P. v. Lynch" on Justia Law

In May 2019, the City of Sunnyvale Department of Public Safety imposed a 44-hour suspension on Officer David Meinhardt, which was upheld by the City of Sunnyvale Personnel Board. Meinhardt challenged the suspension by filing a petition for writ of administrative mandate in the Santa Clara County Superior Court. On August 6, 2020, the court issued an order denying the petition. Subsequently, on September 25, 2020, a formal judgment was entered, and Meinhardt filed a notice of appeal on October 15, 2020.The Fourth Appellate District, Division One, dismissed the appeal as untimely, concluding that the August 6 order was the final judgment from which Meinhardt should have appealed. The court reasoned that the order denied the petition in its entirety and did not contemplate further action, thus starting the 60-day period for filing an appeal.The Supreme Court of California reviewed the case to resolve the uncertainty about when the time to appeal starts in writ of administrative mandate proceedings. The court held that the time to appeal begins with the entry of a "judgment" or the service of notice of entry of "judgment," rather than with the filing of an "order" or other ruling. This decision was based on the plain language of relevant statutes and rules, which contemplate the entry of a "judgment," and the policy of providing clear jurisdictional deadlines to avoid inadvertent forfeiture of the right to appeal. The court reversed the judgment of the Court of Appeal, concluding that Meinhardt's notice of appeal was timely filed within 60 days of the entry of the September 25 judgment. View "Meinhardt v. City of Sunnyvale" on Justia Law

Twanda Bailey, an African-American employee, sued the San Francisco District Attorney’s Office, former District Attorney George Gascon, and the City and County of San Francisco for racial harassment and retaliation under the California Fair Employment and Housing Act (FEHA). Bailey alleged that a coworker called her the N-word, and after reporting the incident, the human resources manager obstructed her complaint, engaged in intimidating conduct, and threatened her.The San Francisco City and County Superior Court granted summary judgment for the City, finding that Bailey failed to make a prima facie case for her FEHA claims. The trial court concluded that a single racial slur by a coworker did not constitute severe or pervasive harassment and that Bailey did not suffer an adverse employment action. The Court of Appeal affirmed the trial court’s decision.The Supreme Court of California reviewed the case and held that an isolated act of harassment, such as the use of an unambiguous racial epithet like the N-word, can be actionable if it is sufficiently severe under the totality of the circumstances. The Court emphasized that the severity of harassment should be judged from the perspective of a reasonable person in the plaintiff’s position. The Court also held that a course of conduct that effectively withdraws an employee’s means of reporting and addressing racial harassment can constitute an adverse employment action. The Court found that there were triable issues of fact regarding both Bailey’s harassment and retaliation claims and reversed the judgment of the Court of Appeal, remanding the case for further proceedings. View "Bailey v. San Francisco District Attorney's Office" on Justia Law

Peter Quach filed a lawsuit against California Commerce Club (Commerce Club) after being terminated from his job at the casino where he had worked for nearly 30 years. Quach's complaint included claims of wrongful termination, age discrimination, retaliation, and harassment, and he demanded a jury trial. Commerce Club had previously provided Quach with a signed arbitration agreement from 2015, which mandated binding arbitration for employment-related disputes. Instead of moving to compel arbitration, Commerce Club answered the complaint and engaged in extensive discovery, including propounding interrogatories and taking Quach’s deposition.The Los Angeles County Superior Court denied Commerce Club’s motion to compel arbitration, finding that Commerce Club had waived its right to arbitrate by engaging in litigation for 13 months. The court noted that Commerce Club had actively participated in discovery and requested a jury trial, actions inconsistent with an intent to arbitrate. Commerce Club appealed, and the Second Appellate District, Division One, reversed the trial court’s decision, holding that Quach had not shown sufficient prejudice from Commerce Club’s delay in seeking arbitration.The Supreme Court of California reviewed the case and abrogated the state’s arbitration-specific prejudice requirement, aligning with the U.S. Supreme Court’s decision in Morgan v. Sundance, Inc. The court held that under California law, as under federal law, courts should apply the same principles to determine waiver of the right to compel arbitration as they do for other contracts. The court concluded that Commerce Club had waived its right to compel arbitration by engaging in litigation conduct inconsistent with an intent to arbitrate. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings consistent with this decision. View "Quach v. Cal. Commerce Club, Inc." on Justia Law