Justia California Supreme Court Opinion Summaries

The Supreme Court vacated as unauthorized the death sentence imposed upon Defendant in connection with his conviction for conspiracy to commit murder and vacated the jury's lying in wait special-circumstance true finding and affirmed, as modified, the judgment in all other respects, holding that no substantial evidence supported the lying in wait special-circumstance finding and that the trial court erred in imposing the death penalty for Defendant's conviction of conspiracy to commit murder.Defendant was convicted of conspiracy to commit murder and first degree murder. The jury found true lying in wait and torture-murder special-circumstance allegations. The jury returned a death verdict. In addition to the errors found on appeal, the Supreme Court assumed error in (1) the trial court's preclusion of impeachment of witnesses with their felony convictions or pending charges; (2) the admission of certain evidence; (3) certain aspects of the prosecutor's guilt phase closing argument; and (4) the trial court's failure to instruct on its own motion that a coperetrator's guilty plea could only be used to assess her credibility. The Court held that the errors and assumed errors, whether considered individually or cumulatively, did not require reversal of Defendant's murder or conspiracy convictions but that the death sentence and lying in wait special-circumstance true finding were improperly imposed. View "People v. Dalton" on Justia Law

In this case involving application of the "catchall" provision of the anti-SLAPP statute, Cal. Code Civ. Proc. 425.16, the Supreme Court held (1) the context of a defendant's statement is relevant, though not dispositive, in analyzing whether the statement was made "in furtherance of" free speech "in connection with" a public issue; and (2) Defendant's confidential reports to its paying clients, which were generated for profit and exchanged confidentially, did not qualify for anti-SLAPP protection under the catchall provision.Plaintiff, a for-profit business entity that distributes web-based entertainment programming, sued Defendant, a for-profit business entity that offers online trafficking and brand safety services to Internet advertisers, alleging that Defendant disparaged its digital distribution network in confidential reports to its paying clients. Defendant filed an anti-SLAPP motion to strike. The court of appeal ruled that Defendant's reports were protected under the anti-SLAPP statute and that context was irrelevant to the anti-SLAPP analysis under subdivision (e)(4). The Supreme Court reversed, holding (1) even where the topic discussed in Defendant's reports was one of public interest the reports did not qualify for anti-SLAPP protection under the catchall provision because Defendant did not issue the reports in furtherance of free speech "in connection with" an issue of public interest. View "FilmOn.com Inc. v. DoubleVerify Inc." on Justia Law

In this real property dispute, the Supreme Court held that Cal. Code Civ. Proc. 580d does not preclude a creditor holding two deeds of trust on the same property from recovering a deficiency judgment on the junior lien extinguished by a nonjudicial foreclosure sale on the senior.In two separate transactions, Defendants borrowed sums of money by executing promissory notes secured by deeds of trust on the same parcel of commercial property. Plaintiff eventually acquired both loans and then purchased the property at a public auction. Plaintiff filed a lawsuit to recover the amount still owed on the second deed of trust extinguished by the foreclosure sale. The trial court concluded that section 580d barred the monetary judgment sought by Plaintiff. The court of appeal reversed, concluding that section 580d did not apply to preclude Plaintiff from suing for the balance due on the junior note in this case. The Supreme Court affirmed, holding that section 580d does not bar a deficiency judgment on a junior lien held by a senior lien holder that sold the property comprising the security for both liens. View "Black Sky Capital, LLC v. Cobb" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder in the course of a robbery and related crimes and sentencing Defendant to death, holding that any assumed errors were harmless.Specifically, the Court held (1) even if it was error for the trial court to admit testimony arguably conveying the substance of a hearsay declarant's out-of-course identification, the error was harmless; (2) assuming there was error in Defendant's absence during one day of the penalty phase trial, the error was harmless; (3) any other possible errors contemplated by this Court were harmless; and (4) Defendant's challenges to the constitutionality of California's capital sentencing scheme were unavailing. View "People v. Bell" on Justia Law

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