Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of murdering James Madden and sentencing Defendant to death.On appeal, Defendant raised a number of issues, most of which focused on purported errors made by the trial court. Defendant also took issue with the Supreme Court’s decision not to supplement the appellate record with the trial transcripts of his codefendants and also challenged the constitutionality of California’s death penalty scheme. The Supreme Court affirmed the judgment of the trial court in its entirety, holding that there was no reversible error in this case. View "People v. Spencer" on Justia Law

At issue was which statute of limitations applies to a suit brought by a child allegedly harmed by in utero exposure to hazardous chemicals: that for toxic exposure claims - Cal. Code Civ. Proc. 340.8(a) - or that for prenatal injuries - Cal. Code Civ. Proc. 340.4.Plaintiff brought suit when she was twelve years old alleging that she and her mother were exposed to toxic chemicals at a Sony Electronics, Inc. manufacturing plant, resulting in her birth defects. Sony moved for summary judgment, arguing that the action was barred by the six-year statute of limitations under section 340.4. In response, Plaintiff argued that her action fell under section 340.8. Section 340.8’s limitations period is only two years but, unlike section 340.4, permits tolling during minority and periods of mental incapacity. The trial court granted summary judgment after applying section 340.4. The Supreme Court reversed, holding (1) because the toxic exposure statute was more recently enacted, and its language plainly encompasses prenatal injuries, it applies in this case; and (2) therefore, Plaintiff’s claims are not time-barred. View "Lopez v. Sony Electronics, Inc." on Justia Law

As applied to in forma pauperis litigants who are entitled to a waiver of official court reporter fees, the San Diego Superior Court’s general policy of not providing official court reporters in most civil trials while permitting privately retained court reporters for parties who can afford to pay for such reporters is invalid, and an official court reporter, or other valid means to create an official verbatim record for purposes of appeal, must generally be made available to in forma pauperis litigants upon request.Plaintiff was statutorily entitled to a waiver of official court reporter attendance fees but did not have a court reporter at a his civil trial because of the San Diego Superior Court’s policy, which provided that a court reporter would be present at a civil trial only if a private court reporter was hired and paid for by a party or the parties to the litigation. Because no court reporter was present at Plaintiff’s trial, the court of appeal rejected Plaintiff’s appeal on the ground that Plaintiff’s legal contentions could not be pursued in the absence of a reporter’s transcript. The Supreme Court reversed, holding that the court policy was invalid as applied to plaintiff and other fee waiver recipients. View "Jameson v. Desta" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendants Joseph Adam Mora and Ruben Rangel of two counts of murder and two counts of attempted robbery and sentencing Defendants to death.On appeal, Defendants argued that several errors during the guilt and penalty phases of their trial warranted reversal of their convictions. The Supreme Court disagreed with the exception of a guilt phase instructional error. The Court held (1) the trial court erred by permitting the jury to find the multiple murder special circumstance try without finding that either defendant intended to kill or actually killed either victim, but the error was harmless; and (2) no error or assumed error, whether considered separately or collectively, merited reversal. View "People v. Mora" on Justia Law

At issue was the validity of a court order entered upon default judgment in a defamation case, insofar as it directed Yelp Inc. to remove certain consumer reviews posted on its website.Plaintiffs brought the underlying lawsuit alleging that certain consumer reviews posted on Yelp were libelous. Yelp was not named as a defendant and did not participate in the judicial proceedings that led to the eventual default judgment. Yelp only became involved in the litigation after being served with a copy of the judgment and order directing that the challenged reviews be purged. Yelp field a motion to set aside and vacate the judgment, arguing that, to the extent the removal order would impose upon Yelp a duty to remove the reviews at issue, the order was barred under the Communications Decency Act of 1996, 47 U.S.C. 230. The trial court denied the motion. The court of appeals affirmed, concluding that the order as to Yelp was beyond the scope of section 230. The Supreme Court reversed, holding the the court of appeal adopted too narrow a construction of section 230 and that section 230 immunity applied in this case. View "Hassell v. Bird" on Justia Law

The Supreme Court affirmed, as modified, the judgment of the trial court convicting Defendant of first degree murder, conspiracy to commit robbery and burglary, and two counts of residential burglary, including the judgment of death, and modified the judgment by striking a one-year enhancement the trial court imposed for the finding that Defendant had served one prior prison term.The Supreme Court held that no prejudicial error occurred during the guilt phase of trial or the penalty phase of trial, with the exception of the one-year enhancement for the prior prison term, holding that because the prison term was served for two of the convictions for which the Court also enhanced the sentence, the enhancement for the prior prison term must be stricken. View "People v. Anderson" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death.Defendant was convicted of first-degree murder for killing his girlfriend’s twenty-one-month-old granddaughter, assault resulting in the death of a child under eight years old, and committing lewd and lascivious conduct on a child under the age of fourteen. The Supreme Court affirmed, holding (1) the admission of testimony from child witnesses was not in error and did not violate Defendant’s due process rights; (2) the evidence was sufficient to support Defendant’s murder conviction; (3) the trial court did not err in admitting evidence of a witness’s broken leg; (4) the trial court did not improperly coerce a death verdict; (5) the trial court’s response to a jury question, coupled with the prosecutor’s argument, did not allow the jury to consider inadmissible evidence during its penalty determination; (6) the prosecutor did not commit error under Griffin v. California, 380 U.S. 609 (1965); and (7) the admission of rebuttal character evidence was not in error. View "People v. Lopez" on Justia Law

The Supreme Court reversed the decision of the court of appeal interpreting Cal. Civ. Code 3531 as authorizing a court to declare Cal. Penal Code 31910(b)(7)(A) unenforceable when a complainant alleges, and the court finds, that complying with the statute is impossible.Penal Code 31910(b)(7)(A) amended the definition of unsafe handguns under the Unsafe Handgun Act to include semiautomatic pistols that are not equipped with with dual placement microstamping. National Shooting Sports Foundation, Inc. (NSSF) filed a complaint seeking declaratory and injunctive relief, alleging that dual placement micro stamping technology was impossible to implement and, therefore, Penal Code 31910(b)(7)(A) was unenforceable on the basis of Civil Code 3531’s declaration that “[t]he law never requires impossibilities.” The court of appeals held that NSSF may present evidence of impossibility and that the judiciary may invalidate Penal Code 31910(b)(7)(A) if compliance is shown to be impossible. The Supreme Court reversed, holding that Civil Code 3531’s maxim that "[t]he law never requires impossibilities” is an interpretive aid that occasionally authorizes an exception to a statutory mandate in accordance with the Legislature’s intent behind the mandate and has never been recognized, nor will it be recognized in this case, as a ground for invalidating a statutory mandate altogether. View "National Shooting Sports Foundation, Inc. v. State" on Justia Law

A jailer’s authority “to set a time and place for the appearance of the arrested person” under Cal. Penal Code 1269b(a) makes that appearance “lawfully required” for purposes of forfeiting bail under Cal. Penal Code 1305, former subdivision (a)(4), under which a court may declare the bail forfeited if a defendant fails to appear on “[a]ny other occasion prior to the pronouncement of judgment if the defendant’s presence in court is lawfully required.”Based on a criminal defendant’s failure to personally appear for a pretrial conference, the trial court ordered her bail forfeited. The court then granted summary judgment on the forfeited bond and sent a demand for payment to Financial Casualty & Surety, Inc. Financial Casualty moved to set aside summary judgment on the ground that the defendant was not ordered to appear at the hearing. The trial court granted the motion. The Court of Appeal affirmed. The Supreme Court reversed, holding that the defendant’s obligation to appear to the hearing was “lawfully required” under section 1305 because, when she was released on bond, the jailer set the time and place for her next appearance, as authorized under section 1269b(a). View "County of Los Angeles v. Financial Casualty & Surety, Inc." on Justia Law

At issue was the claim and issue preclusive significance in future litigation of a conclusion relied on by the trial court and challenged on appeal but not addressed by the appellate court. The Supreme Court overruled People v. Skidmore, 27 Cal. 287 (1865), holding that Skidmore reflects a flawed view of preclusion and that stare decisis does not compel continued adherence to Skidmore.Plaintiff sued both Dr. Haitham Matar and Dr. Stephen Nahigian for professional negligence and alleged that Matar was vicariously liable for Nahigian’s alleged tort. The trial court granted summary judgment for both defendants in two successive judgments. In the first judgment with respect to Nahigian, the trial court concluded that the suit was untimely and that there was no genuine issue regarding causation. In the second judgment, the trial court concluded that the court’s earlier no-causation determination precluded holding Matar liable for Nahigian’s conduct. The court of appeals affirmed the first judgment on statute of limitations grounds without reaching the no-causation ground. As to Matar, the court of appeal reversed, concluding that claim preclusion was unavailable because Plaintiff sued both defendants in a single lawsuit and that Skidmore was inapplicable to issue preclusion. The Supreme Court held that Skidmore must be overruled and that Matar was not entitled to summary judgment on preclusion grounds. View "Samara v. Matar" on Justia Law