Justia California Supreme Court Opinion Summaries

The Supreme Court held that the determination of the California Department of Social Services (the Department) that a household member's income that is used to pay child support for a child living in another household counts as income "reasonably anticipated" to be "received" by the paying household within the meaning of Cal. Welf. & Inst. Code 11265.2 for the purposes of determining eligibility for state welfare benefits was reasonable and therefore valid.Plaintiff applied for California Work Opportunity and Responsibility to Kids (CalWORKs) aid to support herself and her family. The Director of the Department denied the claim, concluding that child support payments garnished from Plaintiff's husband's earned income and unemployment insurance benefits was correctly included as nonexempt available income in determining eligibility for CalWORKs benefits. The superior court declared the department's policy of counting court-ordered child support payments as available income of CalWORKs applicants invalid. The court of appeal reversed. The Supreme Court affirmed, holding that the Department’s determination that funds garnished to pay child support for the benefit of a child living in another household are not exempt from the paying household’s income for purposes of determining its eligibility for or amount of CalWORKs aid was a reasonable exercise of its lawmaking authority and was therefore valid. View "Christensen v. Lightbourne" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and his sentence of death, holding that none of Defendant's challenges to his convictions and death sentence warranted reversal.Defendant was one of three members of a gang who were charged with the murders of Michael Faria and Jessica Salazar. This automatic appeal concerned only Defendant. The Supreme Court affirmed Defendant's conviction of two counts of first degree murder and death sentence, holding (1) any error in allowing a gang expert to testify was harmless; (2) the trial court did not err in declining to exclude two portions of a jailhouse conversation Defendant had with a friend; (3) there was sufficient evidence to support a finding that Defendant shot Faria; (4) the trial court did not abuse its discretion in limiting the cross-examination of a certain witness; (5) the trial court did not abuse its discretion in admitting a photograph depicting Faria's body; (6) the victim impact evidence admitting in this case was within the bounds of what precedents permit; and (7) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Mendez" on Justia Law

In this case concerning whether a certified class of state correctional employees is entitled to additional compensation for time spent on pre- and postwork activities, the Supreme Court held that the represented plaintiffs' claims failed insofar as they sought additional compensation for either "duty-integrated walk time" or "entry-exit walk time" and that, as to the subclass of unrepresented plaintiffs, they may be entitled to additional compensation for duty-integrated walk time.The Supreme Court referred to the time the employees spent traveling from the outermost gate of the prison facility to their work posts within the facility as "entry-exit walk time" and the time the employees spent after beginning the first activity they were assigned to but before arriving at their assigned work post the "duty-integrated walk time." The trial court divided the plaintiff class into two subclasses: one for supervisory employees who were not represented by a union and the other for represented employees. The Court concluded (1) the subclass of represented plaintiffs expressly agreed to a specific amount of compensation for duty-integrated walk time; and (2) the collective bargaining agreements precluded other forms of compensation, and therefore, the represented plaintiffs' claims failed insofar as they sought additional compensation for either duty-integrated walk time or entry-exit walk time. View "Stoetzl v. Department of Human Resources" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder, with the special circumstance that the murder was committed during a rape, and Defendant's sentence of death holding that there was no prejudicial error in the proceedings below.Specifically, the Court held (1) the victim's brother testified at the penalty phase in contravention of a court order, but any prejudice was cured by the trial court's admonition and by other evidence undermining the significance of Defendant's assertions; (2) any assumed error in failing to instruct at the guilt phase on a good faith but unreasonable belief in consent to intercourse was not prejudicial; and (3) Defendant offered no compelling reasons for the Court to reconsider its precedent rejecting Defendant's constitutional challenges to California's death penalty scheme. View "People v. Molano" on Justia Law

The Supreme Court affirmed Defendant's convictions for three counts of first degree murder and three counts of first degree attempted murder arising from two shootings committed by Defendant on the same day and Defendant's sentence of death, holding that only one error occurred during the proceeding, and the error was harmless beyond a reasonable doubt.Specifically, the Court held (1) none of Defendant's claims of error at the guilt phase had merit, and therefore, there was no cumulative error requiring reversal of his convictions; and (2) during the penalty phase, the trial court erred in failing to instruct the jury that a witness's prior conviction of a felony bore on his credibility, but the error was harmless, and therefore, there was no cumulative error requiring reversal of Defendant's penalty of death. View "People v. Mitchell" on Justia Law

The Supreme Court reversed the judgment of the trial court upholding Defendants' convictions of two counts of attempted murder, holding that the evidence was insufficient to support an instruction on the kill zone theory in connection with one of the two alleged attempted murder victims.Defendants were jointly charged and tried on counts including first degree murder and two attempted murders. The trial court gave a kill zone instruction in connection with one of the two alleged attempted murder victims. Under the kill zone theory, a defendant may be convicted of the attempted murder of an individual who was not the defendant's primary target. The court of appeals upheld the attempted murder convictions. The Supreme Court reversed, holding (1) a jury may convict a defendant under the kill zone theory only when the evidence supports a finding that the defendant harbored the requisite specific intent to kill both the primary target and everyone within the zone of fatal harm; and (2) there was insufficient evidence in the record to support an instruction on the kill zone theory. View "People v. Canizales" on Justia Law

The Supreme Court held that the City and County of San Francisco (San Francisco) can lawfully apply a tax collection requirement, which requires parking lot operators to collect a tax from drivers who park their cars in paid parking lots and remit the proceeds to the city, to state universities that operate paid parking lots in the city, holding that the collection requirement is not unconstitutional.San Francisco, a consolidated city and county that has adopted a charter for its own governance, requires that state universities collect the parking tax at issue with whatever parking fees they charge and remit the proceeds to the city. The trial court concluded that the universities were exempt from compliance with the parking tax ordinance. The court of appeal affirmed, concluding that the constitutional principles articulated and applied in In re Means, 14 Cal.2d 254 (1939), and Hall v. City of Taft, 47 Cal.2d 177 (1956), exempts state agencies from collecting and remitting the parking tax. The Supreme Court reversed, holding that charter cities may require state agencies to assist in the collection and remittance of municipal taxes and that San Francisco's collection requirement is a valid exercise of its power from which state universities are not immune. View "City & County of San Francisco v. Regents of the University of California" on Justia Law

The Supreme Court affirmed the judgment of the trial court sentencing Defendant Socorro Susan Caro to death for killing three of her four children, holding that any error in the admission of statements from a detective's interview of Defendant in the hospital after she underwent emergency surgery for a gunshot wound to her head was harmless.Specifically, the court held (1) the trial court committed certain evidentiary errors, but the errors were harmless, were not cumulatively prejudicial, and did not affect Defendant's right to present a defense; (2) assuming error on Defendant's claim that the prosecution should have provided its investigatory material about prospective jurors, the error was harmless; and (3) assuming that the prosecution committed misconduct, the misconduct did not require reversal. View "People v. Caro" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming the decision of a resentencing court refusing to dismiss Defendant's conviction for street terrorism after Proposition 47 came into effect, holding that Defendant was entitled to have his street terrorism conviction dismissed.Proposition 47 reclassified as misdemeanors certain narcotics and theft offenses previously cast as felonies. The gang crime of street terrorism occurs when "a person who actively participates in any criminal street gang...willfully promotes, furthers, or assists in any felonious criminal conduct by members of that gang." On the basis of his act of stealing a bicycle Defendant was convicted of both felony grand theft and street terrorism. After Proposition 47 took effect, the resentencing court refused to dismiss Defendant's street terrorism conviction even though the theft of the bicycle supplied the "felonious criminal conduct" necessary for the commission of the offense. The court of appeal affirmed. The Supreme Court reversed, holding that Defendant was entitled to have his street terrorism conviction dismissed in a full resentencing. View "People v. Valenzuela" on Justia Law

The Supreme Court reversed the judgment of the court of appeal granting Anthony Cook's petition for writ of habeas corpus and remanded the matter to the court of appeal with directions to deny the petition, holding that resort to a petition for writ of habeas corpus was unnecessary in this case, at least in the first instance.Cook was convicted of two counts of first degree murder and one count of premeditated attempted murder. Cook, who was seventeen years old when he committed the murders, was sentenced to life with the possibility of parole for the attempted murder and five consecutive terms of twenty-five years to life for the murders and enhancements. Cook later filed a petition for writ of habeas corpus arguing that his sentence was cruel and unusual punishment in violation of the Eighth Amendment and Miller v. Alabama, 567 U.S. 460 (2012). The court of appeal granted the writ, holding that, in light of People v. Franklin, 63 Cal.4th 261 (2016), Cook was entitled to make a record before the superior court of mitigating evidence tied to his youth. The Supreme Court reversed, holding that Cal. Penal Code 1203.01 provides an adequate remedy at law to preserve evidence of youth-related factors. View "In re Cook" on Justia Law