Justia California Supreme Court Opinion Summaries

The defendant was convicted in 2019 of home invasion robbery, burglary, assault with a firearm, kidnapping, and false imprisonment. The jury also found that a principal in the offense was armed with a firearm. The trial court found that the defendant had two prior strikes based on 2006 and 2007 convictions for felony active participation in a criminal street gang. The defendant filed a Romero motion to dismiss the prior strikes, which the trial court initially denied, citing his criminal history and the nature of his current offenses. The defendant was sentenced to a determinate prison term of 30 years and a consecutive indeterminate term of 27 years to life.The Court of Appeal reversed the trial court’s findings regarding the prior strikes, noting that recent judicial authority had narrowed the scope of the offense. At the 2023 resentencing, the District Attorney conceded that the 2007 conviction did not qualify as a strike, and the trial court found the 2006 conviction did qualify. The defendant filed a new Romero motion, which the trial court granted, citing recent legislative changes and the remoteness of the 2006 strike. The trial court dismissed the strike and imposed a reduced sentence.The California Supreme Court reviewed the case and concluded that the Court of Appeal erred in directing the trial court to reinstate the strike and resentence the defendant under the Three Strikes law. The Supreme Court held that the proper remedy was to remand the case to the trial court to allow it to exercise its discretion based on a correct understanding of the law. The judgment of the Court of Appeal was reversed, and the case was remanded for resentencing in accordance with the Supreme Court's opinion. View "P. v. Dain" on Justia Law

In 2016, a trial court found Jerry Anthony Faial guilty of petty theft with a prior theft-related conviction, two counts of making criminal threats, and first-degree burglary. The court imposed a 12-year sentence but suspended its execution, placing Faial on four years of probation. In 2019, the court revoked and terminated Faial’s probation due to violations and ordered the execution of the suspended sentence. Faial appealed the decision.The Court of Appeal concluded that Assembly Bill 1950, which limits probation terms for most felonies to two years, did not apply to Faial because his probation had been revoked and terminated before the legislation became operative on January 1, 2021. The court reasoned that the legislation was intended to apply only to defendants whose probation had not been revoked and terminated.The Supreme Court of California reviewed the case and concluded that Assembly Bill 1950 applies retroactively to shorten Faial’s probation term to two years, as his case was not yet final. The court held that the ameliorative changes of Assembly Bill 1950 could be applied to Faial’s case, meaning his probation term expired by operation of law two years after it was imposed. Consequently, the orders revoking and terminating his probation and executing his suspended sentence were invalid. The judgment of the Court of Appeal was reversed, and the case was remanded for proceedings consistent with this opinion. View "P. v. Faial" on Justia Law

On January 20, 2018, Francisco Gutierrez was driving his truck on a California highway when an ambulance driven by Uriel Tostado, an EMT employed by ProTransport-1, LLC, rear-ended his vehicle. At the time, Tostado was transporting a patient between medical centers. Gutierrez filed a lawsuit on January 7, 2020, claiming the collision caused him neck and back injuries. He framed his complaint as a general negligence action. Defendants moved for summary judgment, arguing the claim was time-barred under the Medical Injury Compensation Reform Act (MICRA)’s one-year statute of limitations for medical professional negligence. Gutierrez opposed, asserting his claim was timely under the two-year statute of limitations for general negligence.The trial court granted summary judgment for the defendants, finding that MICRA’s statute of limitations applied because Tostado was rendering professional medical services at the time of the accident. Gutierrez appealed, and the Court of Appeal affirmed the trial court’s decision, reasoning that MICRA applied as long as the plaintiff was injured due to negligence in the rendering of professional services.The Supreme Court of California reviewed the case and held that MICRA’s statute of limitations does not apply to Gutierrez’s claim. The court concluded that the applicable statute of limitations depends on the nature of the right being sued upon. Since Gutierrez’s claim was based on a breach of a duty owed to the public generally, rather than a professional obligation owed to a patient, the two-year statute of limitations for general negligence claims applied. The court reversed the judgment of the Court of Appeal and remanded the case for further proceedings consistent with this opinion. View "Gutierrez v. Tostado" on Justia Law

The defendant, high on methamphetamine and upset over his marriage's end, drove through Elk Grove, California, and shot bystanders with a shotgun, killing two men and injuring two others. He was convicted of two counts of murder and five counts of attempted murder, with special circumstances and firearm enhancements. The jury sentenced him to death, and the court denied his motions for a new trial and to modify the death verdict.The Sacramento County Superior Court oversaw the trial. The defense argued for a change of venue due to pretrial publicity, which was denied. The court also denied the defense's request to exclude Elk Grove residents from the jury pool. The defense's challenges to certain jurors for cause were mostly denied, and the court allowed the use of physical restraints on the defendant during the trial. The court admitted the defendant's statements made in the hospital and allowed cross-examination of the defense expert on the defendant's lack of remorse and possession of a Satanic Bible.The California Supreme Court reviewed the case. It affirmed the trial court's decisions, including the denial of the change of venue, the use of physical restraints, and the admission of the defendant's statements. The court found no abuse of discretion in the trial court's handling of jury selection, the admission of victim impact evidence, and the cross-examination of the defense expert. The court also upheld the constitutionality of California's death penalty statutes and found no cumulative error that would warrant reversing the judgment. The judgment of death was affirmed. View "People v. Dunn" on Justia Law

The defendant was convicted of three first-degree murders and several related offenses, including rape and sexual penetration with a foreign object, committed between 1988 and 1998 in Stockton and Oakland, California. The prosecution’s case relied heavily on DNA evidence linking the defendant to the victims, as well as ballistics evidence connecting the same firearm to multiple murders. The victims were found in isolated areas, often bound, and killed by gunshots to the head. The defendant was also convicted of the rape and kidnapping of another woman, Yvette R., who survived and testified. The defense presented no evidence at the guilt phase but, during the penalty phase, offered expert testimony about the defendant’s abusive childhood and mental health issues, including sexual sadism.The San Joaquin County Superior Court jury found the defendant guilty on all counts, found true the special circumstance allegations (multiple murders and murder during rape), and returned death verdicts for each murder. The court imposed a death sentence and additional terms for the noncapital offenses. The defendant’s appeal to the Supreme Court of California was automatic.The Supreme Court of California reviewed numerous claims, including alleged instructional errors, challenges to the constitutionality of special circumstances, claims of prosecutorial misconduct, and issues related to victim impact evidence and penalty phase instructions. The court held that there was no substantial evidence to support instructions on voluntary manslaughter or that the victims were dead at the time of sexual assault, and found no reversible error in the instructions given. The court also rejected challenges to the constitutionality of California’s death penalty scheme and the admission of victim impact evidence. The court found harmless any error in failing to redefine reasonable doubt at the penalty phase and in the response to a jury question about parole eligibility. The judgment was affirmed in its entirety, with a minor correction to the firearm enhancement terms. View "People v. Choyce" on Justia Law

A corporation, its controlling stockholder, and associated individuals were sued by a minority stockholder for breach of contract, fraudulent concealment, and other claims. The defendants moved to dismiss the lawsuit based on forum non conveniens, citing mandatory forum selection clauses in the corporation’s certificate of incorporation and bylaws, which required stockholder lawsuits to be brought in the Delaware Court of Chancery. The trial court denied the motion, and the Court of Appeal denied a petition for writ of mandate, holding that the forum selection clauses were unenforceable because they would deprive the plaintiff of the right to a jury trial, which is not recognized in the Delaware Court of Chancery.The California Supreme Court reviewed the case to determine whether the lower courts were correct in declining to enforce the forum selection clauses on the basis that they would deprive the plaintiff of a jury trial. The Court of Appeal had found that the lack of a jury trial right in Delaware was dispositive and did not consider other arguments against enforcement of the forum selection clause.The California Supreme Court concluded that the lower courts were incorrect in their reasoning. The court held that forum selection clauses serve vital commercial purposes and should generally be enforced. It emphasized that California’s strong public policy in favor of the right to a jury trial applies to California courts and does not extend to other forums. Therefore, a forum selection clause is not unenforceable simply because it requires litigation in a jurisdiction that does not afford the same right to a jury trial as California. The court reversed the judgment of the Court of Appeal and remanded the case for further proceedings to consider other arguments against the enforcement of the forum selection clause. View "EpicentRx v. Superior Ct." on Justia Law

The case involves a defendant who was convicted of five counts of first-degree murder, 20 counts of arson, and 17 counts of possession of an incendiary device. The charges stemmed from a series of wildland fires in Southern California, culminating in the Esperanza Fire, which resulted in the deaths of five firefighters. The prosecution's case was built on evidence including DNA, eyewitness testimony, and expert analysis of the incendiary devices used to start the fires. The defense argued that the evidence was insufficient to prove the defendant's guilt and challenged the credibility of the prosecution's witnesses.In the lower court, the Riverside County Superior Court, the jury found the defendant guilty on all counts and made true findings on the special-circumstance allegations. The jury returned a verdict of death in the penalty phase, and the trial court denied the defendant's motion to reduce the death verdict, sentencing him to death on the murder convictions and to 28 years on the remaining convictions. The defendant's appeal was automatic.The Supreme Court of California reviewed the case and addressed several issues raised by the defendant, including the sufficiency of the evidence, the admission of certain evidence, and alleged instructional errors. The court found that substantial evidence supported the jury's findings and that any assumed instructional errors were harmless beyond a reasonable doubt. The court also rejected the defendant's challenges to the admission of evidence and the handling of jury selection.The Supreme Court of California affirmed the judgment in its entirety, upholding the defendant's convictions and death sentence. The court concluded that the cumulative effect of any assumed errors did not warrant reversal and rejected the defendant's challenges to California's death penalty statute. View "People v. Oyler" on Justia Law

Wanda Brown, the elected treasurer of the City of Inglewood since 1987, raised concerns in late 2019 and early 2020 about the city's financial management, specifically alleging that the mayor had misappropriated public funds. Following these allegations, Brown claimed she faced retaliatory actions from the city and its officials, including a reduction in her salary and authority, exclusion from meetings and committees, and other punitive measures. Brown subsequently filed a lawsuit against the city, its mayor, and council members for retaliation under California Labor Code section 1102.5, which protects whistleblowers.The Los Angeles County Superior Court denied the defendants' anti-SLAPP motion, which sought to strike Brown's retaliation claim on the grounds that she was not an "employee" under section 1102.5. The court reasoned that Brown's claim did not arise from protected speech activities but from alleged retaliatory actions. The Court of Appeal reversed this decision, concluding that Brown's retaliation claim did arise from protected activities and that she was not an "employee" under section 1102.5, as the statute did not explicitly include elected officials within its protections.The Supreme Court of California reviewed the case and affirmed the Court of Appeal's judgment. The court held that elected officials, such as Brown, are not considered "employees" under Labor Code section 1106 and therefore cannot invoke the protections of section 1102.5. The court's decision was based on the statutory language, legislative history, and the context of related whistleblower statutes, which indicated that the Legislature did not intend to include elected officials within the scope of these protections. View "Brown v. City of Inglewood" on Justia Law

Geovanni Quijadas Silva was charged with committing a lewd act on a child, and his bail was set at $100,000. The North River Insurance Company posted the bail bond. Silva failed to appear for a plea hearing, leading the trial court to declare the bond forfeited. North River was notified and given 180 days to either produce Silva or demonstrate reasons to set aside the forfeiture. North River requested and received an additional 180-day extension. Near the end of this period, North River located Silva in Mexico and filed a motion to vacate the forfeiture, arguing that the bond should be exonerated if the prosecution chose not to seek extradition.The trial court denied North River’s motion, stating that the prosecution had not made an extradition decision within the appearance period and no statutory provisions required them to do so. The court also denied the request to toll the appearance period or continue the matter, as the prosecution had not agreed to a continuance. Summary judgment was entered against North River for $100,000.North River appealed, and the Court of Appeal initially affirmed the trial court’s decision but later reversed it upon rehearing. The appellate court held that the trial court should either compel the prosecution to make an extradition decision or continue the hearing to allow time for such a decision.The California Supreme Court reviewed the case and concluded that section 1305 does not authorize the trial court to compel the prosecution to make an extradition decision or require the court to continue the hearing on the motion to vacate until the prosecution makes such a decision. The court emphasized that the statutory language and legislative history indicate that prosecuting agencies have exclusive control over extradition decisions. The judgment of the Court of Appeal was reversed. View "P. v. The North River Ins. Co." on Justia Law

Plaintiffs purchased Ford vehicles from various dealerships, signing sales contracts that included arbitration provisions. They later sued Ford Motor Company, alleging defects in the vehicles and claiming Ford violated express and implied warranties and engaged in fraudulent concealment. Ford, not a party to the sales contracts, sought to compel arbitration based on the arbitration clauses in the sales contracts between plaintiffs and the dealerships.The trial court denied Ford's motion to compel arbitration. Ford appealed, and the Court of Appeal affirmed the trial court's decision. The appellate court concluded that the arbitration clauses in the sales contracts did not apply to Ford, as Ford was not a party to those contracts and the plaintiffs' claims were not intimately founded in or intertwined with the sales contracts.The Supreme Court of California reviewed the case and affirmed the Court of Appeal's judgment. The court held that the estoppel approach, which allows a nonsignatory to compel arbitration if the plaintiff's claims are intimately founded in and intertwined with the contract containing the arbitration clause, did not apply here. The court found that plaintiffs' claims against Ford were based on statutory obligations and fraud, not on the sales contracts themselves. Therefore, plaintiffs were not estopped from pursuing their claims in court, and Ford could not compel arbitration based on the sales contracts between plaintiffs and the dealerships. View "Ford Motor Warranty Cases" on Justia Law