Justia California Supreme Court Opinion Summaries

These three consolidated cases presented similar issues concerning Proposition 47’s effect on felony-based enhancements in resentencing proceedings under Cal. Penal Code 1170.18.Proposition 47, or the Safe Neighborhoods and Schools Act, reclassified as misdemeanors offenses that were previously felonies or “wobblers” and added section 1170.18, which permits allows defendants previously convicted of felony offenses that Proposition 47 reduced to misdemeanors to petition to have those felony convictions resentenced or redesignated as misdemeanors.The Supreme Court held that Proposition 47’s directive that the resentenced or redesigned offense “be considered a misdemeanor for all purposes” permits defendants to challenge felony-based Cal. Penal Code 667.5 and Cal. Penal Code 12022.1 enhancements when the underlying felonies have subsequently been resentenced or redesignated as misdemeanors.The Court further held that such challenges may be brought in a resentencing procedure under section 1170.18 or may be brought on a petition for writ of habeas corpus, under which instance relief is limited to judgments that were not final at the time the initiative took effect. Finally, those convicted under Cal. Penal Code 1320.5 cannot obtain similar relief. View "People v. Buycks" on Justia Law

After issuing an order to show cause with respect to Petitioner habeas claim that prejudicial juror misconduct occurred when a juror did not timely disclose a history of childhood abuse, the Supreme Court discharged the order to show cause and held that Petitioner was not entitled to relief.Petitioner was convicted of four counts of first degree murder and was sentenced to death. Petitioner then filed this amended habeas corpus petition alleging that the jury foreperson had committed misconduct by concealing that he was abused as a child. The Supreme Court issued an order to show cause and ordered a reference hearing directing a referee to answer four questions. After an evidentiary hearing, the referee found that there was no prejudicial juror misconduct because the juror’s nondisclosure was neither intentional nor deliberate and that juror was not biased against Petitioner.The Supreme Court agreed generally with the referee’s findings and held that Petitioner failed to establish that he was entitled to habeas corpus relief on his claim of prejudicial juror misconduct. View "In re Manriquez" on Justia Law

The Supreme Court accepted the Ninth Circuit’s request for certification and answered (1) California’s wage and hour statutes and regulations have not adopted the de minimis doctrine found in the federal Fair Labor Standards Act (FLSA); and (2) the relevant wage order and statutes do not permit application of the de minimis principle on the facts of this case.Here, an employer required an employee to work “off the clock” for several minutes per shift. The employer moved for summary judgment on the ground that the employee’s uncompensated time was so minimal that the employer was not required to compensate him. The district court concluded that the de minimis doctrine applied and granted summary judgment for the employer. On appeal, the Ninth Circuit asked the Supreme Court to answer whether the FLSA’s de minimis doctrine applies to claims for unpaid wages under California Labor Code sections 510, 1194, and 1197. The Supreme Court held (1) the pertinent statutes and wage order have not incorporated the de minimis doctrine set forth in the FLSA; and (2) while California has a de minimis rule that has operated in various contexts, that rule is not applicable under the facts of this case. View "Troester v. Starbucks Corp." on Justia Law

The Supreme Court reversed the sentence of death imposed in connection with Defendant’s conviction for the first degree murder of a police officer and the attempted murder of a police officer, holding that the trial court, over defense objection, erroneously excused for cause a prospective juror based on his written response to questions about his view on capital punishment, requiring reversal of the penalty verdict.After finding that Defendant did not have an intellectual disability, and following a penalty trial, the jury returned a verdict of death. The trial court imposed a judgment of death after denying the automatic motion to modify the verdict. The court also imposed a prison sentence on the other counts for which Defendant was convicted and enhancement allegations. The Supreme Court held (1) the trial court erred in excusing a prospective juror based on his questionnaire responses, an error that automatically compelled reversal of the penalty phase; and (2) the trial court’s judgment is affirmed in all other respects. View "People v. Woodruff" on Justia Law

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