Justia California Supreme Court Opinion Summaries

Michael Allan Lamb was convicted of first-degree murder, attempted murder of a peace officer, conspiracy to commit murder, unlawfully carrying a loaded firearm in public as a gang member, possession of a firearm by a felon, and street terrorism. The jury found true the gang-murder special-circumstance allegation and other gang-related enhancements. Lamb was sentenced to death after a penalty phase retrial.The Orange County Superior Court initially reviewed the case, where the jury convicted Lamb on all counts but failed to reach a penalty verdict. A different jury at the penalty phase retrial fixed the penalty at death, and the court entered a judgment of death. Lamb's appeal to the California Supreme Court was automatic.The California Supreme Court reviewed the case and reversed Lamb’s convictions for street terrorism and unlawfully carrying a loaded firearm in public due to recent amendments to section 186.22 from Assembly Bill No. 333. The court also reversed the true findings on the gang enhancements and the gang-murder special circumstance. The death judgment was vacated, and the case was remanded to the trial court for any retrial of the reversed convictions, enhancements, and special circumstance. In all other respects, the court affirmed the judgment. View "People v. Lamb" on Justia Law

In January 1992, J. Sacramento Benitez was killed during a residential burglary and attempted robbery. Luis Ramon Manzano Arellano and two co-defendants were charged with murder, attempted robbery, and first-degree burglary, with firearm use enhancements. Arellano pled guilty to second-degree murder under conditions that included striking the firearm enhancement and dismissing the robbery and burglary charges. He was sentenced to 15 years to life.The Santa Clara County Superior Court received Arellano's petition for resentencing under Penal Code section 1172.6 in October 2020. The district attorney initially opposed but later stipulated to resentencing. The court vacated Arellano's murder conviction and set a hearing to redesignate the charge. The trial court agreed to redesignate the conviction as attempted robbery with a firearm enhancement, despite defense objections that the enhancement was neither admitted nor found true by a jury.The California Court of Appeal reversed the trial court's decision, ruling that the firearm enhancement could not be imposed because it was not proven or admitted. The court held that section 1172.6 does not allow for the imposition of uncharged and unproven enhancements during resentencing.The Supreme Court of California affirmed the Court of Appeal's judgment, holding that section 1172.6, subdivision (e) does not permit a court to impose a sentencing enhancement unless it was pled and proven or admitted by the defendant. The court emphasized that the resentencing procedure is limited to the target offense or underlying felony and does not include uncharged and unproven enhancements. The Supreme Court also reversed the Court of Appeal's order for a remand to reconsider the redesignated conviction, as the trial court had already considered and chosen not to redesignate the underlying felony as burglary. View "People v. Arellano" on Justia Law

This case involves five large water utilities and an association representing investor-owned water utilities' interests, collectively referred to as the Water Companies. The Water Companies sought to overturn an order by the Public Utilities Commission (Commission) that eliminated a conservation-focused ratesetting mechanism known as the Water Revenue Adjustment Mechanism (WRAM). The WRAM was designed to encourage water conservation by decoupling a water company's revenue from the amount of water sold. The Commission's order to eliminate the WRAM was not based on the merits of the mechanism but on procedural issues.The Commission's decision to eliminate the WRAM was made in a proceeding that was ostensibly focused on improving the accuracy of water sales forecasts. The Water Companies argued that the Commission did not provide adequate notice that the elimination of the WRAM was one of the issues to be considered in the proceeding.The Supreme Court of California agreed with the Water Companies. The court found that the Commission's scoping memos, which are supposed to outline the issues to be considered in a proceeding, did not provide adequate notice that the WRAM's elimination was on the table. The court concluded that the Commission's failure to give adequate notice required the order to be set aside. The court did not rule on the merits of the WRAM itself. View "Golden State Water Co. v. Public Utilities Com." on Justia Law

The case involves Nicholas Needham, who was referred for evaluation as a possible Sexually Violent Predator (SVP) under the Sexually Violent Predator Act (SVPA) after serving his prison term for certain sex offenses. Two evaluators initially determined that Needham had a mental disorder making him likely to engage in sexual violence unless civilly committed. However, before the probable cause hearing, one evaluator changed his opinion, leading to the appointment of two other evaluators. One of these evaluators concluded that Needham qualified as an SVP, while the other did not. The trial court found probable cause to believe Needham was an SVP and ordered a trial.The People retained Dr. Craig King as an expert and sought discovery of Needham's evaluations and records. The trial court granted the request and ruled that Dr. King could interview and test Needham. Needham filed motions to preclude Dr. King from testifying at trial, which were denied. Needham sought a writ of mandate/prohibition to prevent Dr. King from conducting any further interviewing or testing and from testifying at trial. The Court of Appeal granted Needham's writ petition and directed the trial court to exclude Dr. King's testimony. The People petitioned for review from that ruling.The Supreme Court of California held that, under the SVPA, the People may call their retained expert to testify at trial, both to contest the testimony of other witnesses and to offer an independent opinion as to whether the defendant qualifies as an SVP. However, the People's retained expert may not compel a defendant to be interviewed or participate in testing before trial. The court reversed the Court of Appeal's contrary judgment and remanded the case for trial. View "Needham v. Superior Court" on Justia Law

The case involves John Harris, Jr., who was charged with attempted first degree murder and aggravated mayhem related to a violent rape committed over 30 years ago. The charges were based on a DNA match between Harris and evidence from the crime scene. The prosecution sought to detain Harris without bail under a provision of the California Constitution (article I, section 12(b)) that allows for pretrial detention without bail for certain violent felonies, if there is clear and convincing evidence that the person's release would result in great bodily harm to others.The trial court denied Harris's bail, relying on a proffer by the prosecution that included hearsay evidence and documents without the full evidentiary foundation required at trial. Harris challenged this decision, arguing that only evidence admissible at a criminal trial could support pretrial detention without bail.The Court of Appeal rejected Harris's argument but conditionally vacated the order denying bail and remanded the matter to the trial court for further findings, because the trial court failed to consider less restrictive alternatives to detention.The Supreme Court of California held that a trial court may consider reliable proffered evidence in making factual findings under article I, section 12(b) without violating due process principles. However, the court remanded the case to the trial court to apply the standards discussed in its opinion and to consider less restrictive alternatives to detention. View "In re Harris" on Justia Law

This case involves a dispute over the interpretation of the "learned intermediary doctrine" in a product liability case involving a medical device. The plaintiff, Michelle Himes, sued the defendant, Somatics, LLC, alleging that the company failed to provide adequate warning about the risks associated with electroconvulsive therapy (ECT), a treatment she underwent for severe depression. Himes claimed that she was only warned about the possibility of short-term memory loss, and not about the potential for permanent brain damage, severe permanent retrograde and anterograde amnesia, and acute and/or chronic organic brain syndrome, which she alleges she suffered as a result of the treatment.The district court granted summary judgment in favor of Somatics, finding that Himes failed to present evidence showing that a more detailed warning would have changed her physician's decision to administer ECT. The Ninth Circuit Court of Appeals agreed with the district court's finding but noted a genuine dispute of material fact as to whether the physician would have communicated a stronger warning to Himes.The Supreme Court of California was asked to clarify the causation standard under the learned intermediary doctrine. The court held that a plaintiff is not required to show that a stronger warning would have altered the physician’s decision to prescribe the product to establish causation. Instead, a plaintiff may establish causation by showing that the physician would have communicated the stronger warning to the patient and an objectively prudent person in the patient’s position would have thereafter declined the treatment. The court emphasized that the causation analysis must take into consideration whether the physician would still recommend the prescription drug or medical device for the patient, even in the face of a more adequate warning. View "Himes v. Somatics, LLC" on Justia Law

The Supreme Court of California ruled that the Taxpayer Protection and Government Accountability Act (TPA), a proposed initiative measure, could not be placed on the November 2024 general election ballot. The TPA sought to revise the California Constitution by requiring voter approval for any new or increased state or local tax, and by expanding the definition of "tax" to include a wider range of government charges. The petitioners, the Legislature of the State of California, Governor Gavin Newsom, and former Senate President Pro Tempore John Burton, argued that the TPA was invalid because it attempted to revise the California Constitution via citizen initiative, and because it would seriously impair essential government functions.The court agreed with the petitioners, finding that the TPA would substantially alter the basic governmental framework set forth in the California Constitution. The court noted that the TPA would eliminate the Legislature's ability to levy taxes without prior voter approval, shift power between the executive and legislative branches, and transform local revenue-raising by requiring that exempt charges go through legislative rather than administrative processes. The court concluded that these changes were so significant that they amounted to a revision of the Constitution, which could not be enacted by initiative. The court therefore issued a writ of mandate directing the Secretary of State to refrain from placing the TPA on the November 2024 election ballot. View "Legislature of the State of California v. Weber" on Justia Law

This case involves a dispute over insurance coverage for continuous injury claims. The plaintiff, Truck Insurance Exchange, was a primary insurer for Kaiser Cement and Gypsum Corporation. Truck filed an equitable contribution claim against several insurers that had issued first-level excess policies to Kaiser for policy years where the directly underlying primary policy had been exhausted. Truck argued that the excess insurers’ indemnity obligations were triggered immediately upon exhaustion of the directly underlying primary policies. The excess insurers, however, argued that they had no duty to indemnify Kaiser until it had exhausted every primary policy issued during the period of continuous damage. The trial court and the Court of Appeal agreed with the excess insurers, interpreting the excess policies as requiring horizontal exhaustion of all primary insurance.The Supreme Court of California disagreed, concluding that the language of the first-level excess policies at issue in this case is essentially identical to the policy language in the higher-level excess policies that it considered in a previous case, Montrose III. The Court held that the first-level excess policies are most reasonably construed as requiring only vertical exhaustion. However, the Court also noted that its conclusion does not fully resolve the questions presented in this appeal, which involves a contribution claim between coinsurers. The Court remanded the matter to allow the Court of Appeal to address these alternative arguments in the first instance. View "Truck Ins. Exchange v. Kaiser Cement & Gypsum Corp." on Justia Law

In the case of The People v. Giles Albert Nadey, Jr., the defendant was convicted of one count of unlawful sodomy and one count of first-degree murder for the killing of Terena Fermenick. The jury found that both offenses were committed with the use of a knife and the murder occurred during the commission of unlawful sodomy. After the first jury deadlocked on penalty, a second jury returned a verdict of death. The Supreme Court of California affirmed the judgment.The case revolved around the murder of Terena Fermenick, who was sexually assaulted and killed. The defendant, Giles Albert Nadey, Jr., was a carpet cleaner who had been assigned to clean the carpets at the Fermenick's new home on the day of the murder. The prosecution's evidence included DNA evidence linking Nadey to the crime, as well as testimony from various witnesses.In the lower courts, Nadey was convicted of the charges and sentenced to death. His appeal to the Supreme Court of California was automatic due to the death sentence.In the Supreme Court of California, Nadey's conviction and sentence were affirmed. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also rejected Nadey's claims of legal error and prosecutorial misconduct. The court held that the prosecutor's comments during closing arguments were not improper and did not prejudice Nadey's right to a fair trial. The court also found that the trial court did not err in admitting certain evidence or in its handling of jury instructions. View "P. v. Nadey" on Justia Law

The Supreme Court of California reviewed a case involving the University of California, Berkeley's (UC Berkeley) plan to build a housing project on a site called People's Park. The plaintiffs, Make UC a Good Neighbor and People’s Park Historic District Advocacy Group, challenged the certification of an environmental impact report (EIR) for the project, arguing that it failed to consider the environmental impacts of "student-generated noise" and did not adequately consider alternatives to the People’s Park location. The Court of Appeal agreed with the plaintiffs.The Supreme Court of California granted review of the Court of Appeal’s decision. During the review, the Legislature passed Assembly Bill No. 1307, which added sections to the Public Resources Code stating that noise generated by project occupants and their guests is not a significant environmental effect for residential projects, and that public higher education institutions are not required to consider alternatives to the location of a proposed residential or mixed-use housing project if certain requirements are met. The plaintiffs conceded that this new law applied to the case and made clear that the EIR was not required to examine "social noise" or potential alternative locations to People’s Park.The Supreme Court of California concluded that none of the plaintiffs' claims had merit in light of the new law. The court held that the new law applied to both the People’s Park housing project and the development plan, and the EIR was not inadequate for having failed to study the potential noisiness of future students at UC Berkeley in connection with this project. The court declined to consider the plaintiffs' alternative locations argument with respect to potential future housing projects. The court reversed the Court of Appeal’s judgment. View "Make UC a Good Neighbor v. The Regents of the University of California" on Justia Law