Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Defendant's automatic motion to modify the jury's verdict convicting Defendant of two counts of first degree murder and sentencing him to death, holding that any errors were minimal and did not warrant reversal.Specifically, the Court held (1) even assuming that the trial court erred in excluding Defendant's proffered statements to impeach a witness's credibility, the error was harmless and not so severe as to violate Defendant's right under the United States Constitution to confront the witnesses against him; (2) any error in the trial court's ruling permitting certain cross-examination when Defendant testified was harmless; (3) any impropriety on the part of the prosecutor during his guilt phase closing argument to the jury was not prejudicial; and (4) any error in the admission of evidence that Defendant. committed a crime involving force or violence against his stepdaughter was harmless. View "People v. Sanchez" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that this lawsuit brought by security guards at Oracle Park (the former AT&T Park in San Francisco) against San Francisco Baseball Associates LLC (the Giants) alleging a violation of Cal. Lab. Code 201, subd. (a) was preempted under federal law and must be submitted to arbitration, holding that the trial court correctly denied the Giants' motion to compel arbitration.In this action, the guards claimed that they were discharged after every Giants homestead, at the end of the baseball season, and after other events at the park, and that they were entitled under section 201 to receive their unpaid wages immediately after each discharge. The Giants moved to compel arbitration, arguing that this action was preempted by the Labor Management Relations Act because the controversy required interpretation of the collective bargaining agreement (CBA) entered into between the parties. The trial court denied the motion. The court of appeal reversed. The Supreme Court reversed, holding (1) while the CBA may be relevant to this lawsuit, the dispute turned on the meaning of "discharge" under section 201 rather than an interpretation of the CBA itself; and (2) therefore, the lawsuit was not preempted, and state courts may decide it on the merits. View "Melendez v. San Francisco Baseball Associates LLC" on Justia Law

In this case concerning the proper interpretation of Proposition 47, the ballot initiative that reduced certain felony offenses to misdemeanors, the Supreme Court held that defendants who had not yet been sentenced as of Proposition 47's effective date were entitled to initial sentencing under Proposition 47's amended penalty provisions without regard to the resentencing procedures applicable to those who were already serving their sentences.Proposition 47 took effect after Defendant committed his offense but before he was charged, tried, or sentenced. On appeal, Defendant argued that his felony Vehicle Code section 10851 conviction must be reduced to a misdemeanor under Cal. Penal Code 490.2(a), the new Penal Code provision added by Proposition 47. The court of appeal affirmed Defendant's felony conviction and sentence. The Supreme Court granted Defendant's petition for review and held (1) the court of appeal erred in holding that Proposition 47 is inapplicable to violations of Cal. Veh. Code 10581; but (2) the court of appeal correctly affirmed Defendant's conviction on that charge because the evidence at trial was sufficient to sustain a felony conviction under Cal. Veh. Code 10851. View "People v. Lara" on Justia Law

The Supreme Court affirmed the judgments of the trial court and court of appeal rejecting Plaintiffs' facial challenge to the ordinance adopted by the City and County of San Francisco (the City) requiring wireless telephone service companies to obtain permits to install and maintain lines and equipment in public rights-of-way, holding that the lower courts properly found that ordinance was lawful.Specifically, Plaintiffs argued that the ordinance was preempted by Cal. Pub. Util. Code 7901 and that the ordinance violated Cal. Pub. Util. Code 7901.1. The trial court ruled that section 7901 did not preempt the challenged portions of the ordinance and rejected Plaintiffs' claim that it violated section 7901.1. The court of appeal affirmed. The Supreme Court affirmed, holding (1) section 7901 does not preempt the ordinance based on aesthetic considerations; and (2) the ordinance does not violate section 7901.1 by singling out wireless telephone corporations for regulation. View "T-Mobile West LLC v. City & County of San Francisco" on Justia Law

The Supreme Court held that the rule set forth in Stone v. Superior Court, 31 Cal.3d 503, that a court must accept a partial verdict of acquittal as to a charged greater offense when a jury has expressly indicated that it has acquitted on that offense but has deadlocked on uncharged lesser included offenses, has not been abrogated by the United States Supreme Court's decision in Blueford v. Arkansas, 566 U.S. 599, which concluded that federal double jeopardy principles do not require a court to accept a partial verdict.Defendant was charged with murder. At the close of evidence, the court instructed the jury on first degree murder and uncharged lesser included offenses. The jury foreperson reported that jurors were split between second degree murder, voluntary manslaughter, and a not guilty verdict. The court concluded that the jury was deadlocked and declared a mistrial. Defendant moved to dismiss the first degree murder allegation on double jeopardy grounds, arguing that the court's failure to receive a partial acquittal verdict on first degree murder barred a retrial on that charge. The court dismissed the first degree murder charge. The court of appeal affirmed. The Supreme Court affirmed, holding (1) Stone survives Blueford under California law; and (2) the trial court improperly declared a mistrial as to first degree murder. View "People v. Aranda" on Justia Law

The Supreme Court reversed the judgment of the court of appeals ruling that Defendant did not have a right to appointed counsel to respond to the prosecution's appeal of the order of the trial court granting Defendant's motion to suppress the prosecution's evidence against her, holding that Defendant had a right to appointed counsel in the present appeal.Defendant was charged by misdemeanor complaint with driving under the influence of alcohol and driving while having a blood-alcohol content of 0.08 percent or higher. With the assistance of court-appointed counsel, Defendant filed a successful motion to suppress evidence collected during a warrantless traffic stop. The prosecution's appealed the suppression order. Defendant asked the appellate division to appoint new counsel to represent her, but the appellate division refused. Defendant then filed a petition for a writ of mandate, which the court of appeal denied. Without addressing whether the public defender remained appointed to represent Defendant, the court concluded that Defendant did not have the right to appointment of counsel on appeal. The Supreme Court reversed and remanded the case, holding that Defendant was entitled to the assistance of counsel to respond to the prosecution's appeal. View "Gardner v. Appellate Division of Superior Court" on Justia Law

The Supreme Court reversed the judgment of the Court of Appeal upholding the juvenile court's finding that H.W. possessed an "other instrument or tool with intent feloniously to break or enter" within the meaning of Cal. Penal Code 466, holding that the pair of pliers that H.W. was in possession of when he was apprehended were not an "other instrument or tool" within the meaning of section 466.H.W., a minor, entered a Sears department store with the intent to steal a pair of jeans. When H.W. was apprehended and searched, he had in possession the jeans and a pair of pliers approximately ten inches in length, with a half-inch blade. The juvenile court sustained the burglary tool possession allegation brought against H.W. The Court of Appeal upheld the juvenile court's determination. The Supreme Court reversed, holding (1) the record did not support the conclusion that H.W. intended to use the pliers to do anything other than remove the anti-theft tag from the jeans; and (2) therefore, there was insufficient evidence to support the section 466 allegation. View "In re H.W." on Justia Law

The Supreme Court modified the judgment of the trial court convicting Defendant of two counts of first degree murder and related crimes, sentencing Defendant to death, and imposing a four-year determinate term based on the age of the victims by striking the four-year determinate term but otherwise affirmed, holding that there was error in the elderly victim enhancements but no other prejudicial error.Specifically, the Court held (1) the evidence was sufficient to support Defendant's convictions; (2) there was no reversible error in the guilt-phase instructions given to the jury; (3) any statutory error in allowing an investigator to read aloud from his report of an interview with a driver of Defendant was harmless at the guilt phase, and the admission of the driver's statement during the guilt phase did not prejudice the jury's penalty determination; (4) no other error occurred during the penalty phase of trial; (5) murder is not one of the crimes eligible for an elderly victim enhancement; (6) any error on the part of the trial court in initially imposing a $10,000 restitution fine was harmless; and (7) none of Defendant's challenges to California's death penalty scheme had merit. View "People v. Potts" on Justia Law

The Supreme Court affirmed the decisions of the trial court and court of appeal, which determined that the elimination of the opportunity to purchase additional retirement service (ARS) credit set forth in the California Public Employees’ Pension Reform Act of 2013 (PEPRA), Cal. Gov. Code 7222 et seq., did not violate the California Constitution, holding that the opportunity to purchase ARS credit is not a right protected by the contract clause, and in the absence of constitutional protection, the opportunity to purchase ARS credit can be altered or eliminated at the discretion of the legislature.PEPRA effectively repealed the statute granting public employees the opportunity to purchase ARS credit. At issue in this case was whether the opportunity to purchase ARS credit was a vested right protected by the constitutional contract clause and whether the elimination of the opportunity to purchase ARS credit was an unconstitutional impairment of public employees’ vested rights. The Supreme Court answered the first question in the negative and declined to address the second issue, holding that the opportunity to purchase ARS credit is not a vested right. View "Cal Fire Local 2881 v. California Public Employees' Retirement System" on Justia Law

The Supreme Court affirmed the judgment of the trial court and court of appeal sustaining Defendants’ demurrer in this case, holding that customers who have paid sales tax reimbursement on purchases they believe to be exempt from sales tax are not authorized to file suit to compel the retailers to seek a tax refund from the California Department of Tax and Fee Administration (Department) when there has been no determination by the Department or a court that the purchases are exempt.A customer who has paid excess sales tax reimbursement has no statutory remedy to obtain a refund from the Department directly. In Javor v. State Board of Equalization, 12 Cal.3d 790 (1974), however, the Supreme Court authorized a customer suit to compel certain retailers to seek a tax refund where the Board of Equalization, upon determining that the retailers had collected excess sales tax reimbursement, had promulgated rules to provide refunds to overpaying customers. The lower courts declined to extend Javor to authorize a similar judicial remedy under the circumstances of this case. The Supreme Court affirmed, holding that plaintiffs in this case did not have an equitable cause of action to compel the retailers to seek a refund of sales taxes paid to the State. View "McClain v. Sav-On Drugs" on Justia Law