Justia California Supreme Court Opinion Summaries

Statutory developments warranted modification of a settlement order between Petitioner and the Board of Parole Hearings (Board) to relieve the Board of any obligation to calculate “base terms” of an inmate serving an indeterminate sentence for use at the inmate’s initial parole hearing.Petitioner filed a petition for writ of habeas corpus in December 2012 against the Board seeking to avoid parole determinations leading to grossly disproportionate prison terms. An ensuing settlement agreement required the Board to calculate “base terms” under the agreement. At the time of the agreement, “base terms” governed the earliest possible release date for inmates serving indeterminate sentences. Since then, statutory developments altered the statutory landscape such that “base terms” no longer governed the release dates of inmates subject to indeterminate sentences. The Court of Appeal concluded that the settlement order could remain in force despite the statutory changes. The Supreme Court disagreed, holding (1) the elimination of “base term” calculations from any statutory role in determining release dates for those sentenced to indeterminate terms was a sufficiently material change that it required modification of the settlement by the Court of Appeal; and (2) the Board was not constitutionally required to continue calculating base terms as required in the settlement order. View "In re Butler" on Justia Law

Defendant was not eligible for resentencing under Proposition 47 because if Proposition 47 had been in effect when Defendant committed his offense in 2007, he would still be guilty of a felony not covered by Proposition 47.Proposition 47, enacted in 2014, reduced certain drug- and theft-related offenses from felonies to misdemeanors and authorized inmates currently serving sentences for a reclassified crime to petition the court for resentencing. As relevant to this appeal, Defendant filed a petition for resentencing on a felony conviction of transportation of methamphetamine. The trial court found Defendant ineligible for resentencing on the transportation offense. On appeal, the court of appeal held, among other things, that only offenders convicted of a felony offense enumerated in Proposition 47’s resentencing provision may have their crimes reduced to misdemeanors. The Supreme Court disagreed, holding (1) the mere fact that former Cal. Health & Safety Code 11379 is not one of the code sections enumerated in Cal. Penal Code 1170.18(a) is not fatal to Defendant’s petition for resentencing on his transportation offense; but (2) the court of appeals correctly found that Defendant was ineligible for resentencing because if Proposition 47 had been in effect when he committed his offense in 2007, he would still be guilty of a felony not covered by Proposition 47. View "People v. Martinez" on Justia Law

Universities have a special relationship with their students and a duty to protect them from foreseeable violence during curricular activities.Damon Thompson, a student at the University of California at Los Angeles (UCLA), stabbed fellow student Katherine Rosen during a chemistry lab. Thompson was experiencing auditory hallucinations, and school administrators had attempted to provide him with mental health treatment. Rosen sued UCLA and several of its employees (collectively, UCLA), alleging negligence for UCLA’s failure to protect her from Thompson’s foreseeable violent conduct. UCLA moved for summary judgment, arguing that colleges have no duty to protect their adult students from criminal acts. The trial court denied the motion. The Court of Appeal granted UCLA’s petition for writ of mandate, ruling that UCLA owed no duty to protect Rosen. The Supreme Court reversed, holding that universities owe a duty to protect students from foreseeable violence during curricular activities. View "Regents of University of California v. Superior Court of Los Angeles County" on Justia Law

Subject to the trial court’s discretion to permit late filing, a defendant must move to strike a cause of action under Cal. Code Civ. P. 425.16 - California’s anti-SLAPP statute - within sixty days of service of the earliest complaint that contains that cause of action.Within sixty days of the filing of a third amended complaint but not within sixty days of any earlier complaint, Defendants moved to strike that complaint under section 425.16. Specifically, Defendants sought to strike Plaintiffs’ claim alleged in the first and subsequent complaints that Defendants fraudulently settled an unlawful detainer action. The trial court denied the motion as untimely. The court of appeal affirmed, ruling that a defendant must file an anti-SLAPP motion within sixty days of service of the first complaint that pleads a cause of action coming within section 425.16(b)(1) unless the trial court in its discretion permits the motion to be filed at a later time. The court also concluded that Defendants’ motion was timely as to the new causes of action pleaded for the first time in the third amended complaint. The Supreme Court affirmed, holding that the court of appeal property interpreted section 425.16(f). View "Newport Harbor Ventures, LLC v. Morris Cerullo World Evangelism" on Justia Law

The Supreme Court granted Petitioner’s petition for writ of habeas corpus and vacated the judgment of conviction because false evidence was introduced at trial.Petitioner, Vincente Benavides Figueroa, was convicted of murder - committed with the special circumstances of felony-murder rape sodomy, and lewd conduct - and rape, sodomy, and lewd conduct. Petitioner was sentenced to death. Petitioner later filed a petition or habeas corpus relief, asserting that false evidence, now repudiated or undermined, resulted in his convictions and the special circumstances findings. The Supreme Court issued an order to show cause on Petitioner's claims that his convictions were based on false evidence and that he received ineffective assistance of counsel. Respondent, the Secretary of the Department of Corrections and Rehabilitation, conceded that Petitioner was entitled to relief based upon the introduction of false evidence and argued that the murder conviction should be revised from first to second degree. The Supreme Court disagreed and vacated the judgment in its entirety, holding that a reduction to second degree murder was not warranted. View "In re Figueroa" on Justia Law

Resentencing is available to defendants who were serving felony sentences on Proposition 47’s effective date but whose judgments were on appeal and thus not yet final only in accordance with the statutory resentencing procedure in Cal. Penal Code 1170.18.Approved by voters in 2014, Proposition 47 reduces many theft- and drug-related offenses from felonies to misdemeanors for offender who do not have prior convictions for specified violent or serious offenses. Proposition 47 also permits eligible defendants who were serving felony sentences as of Proposition 47’s effective date to obtain the benefit of these changes by petition for resentencing. The resentencing petition must be granted unless the court determines that resentencing a defendant would pose an unreasonable risk of danger to public safety. At issue was whether defendants whose judgments were not yet final were entitled to automatic resentencing under Proposition 47 or whether these defendants must seek resentencing through the statutory resentencing procedure. The Supreme Court held the latter. View "People v. DeHoyos" on Justia Law

Under California law, a dissolved law firm has no property interest in legal matters handled on an hourly basis and therefore no property interest in the profits generated by the law firm’s former partners’ work on hourly fee matters pending at the time of the firm’s dissolution.The district court held that the law firm in this case did not have a property interest in the hourly fee matters pending at dissolution. The law firm appealed to the Ninth Circuit, which asked the Supreme Court to provide guidance. The Supreme Court held that, under California partnership law, a dissolved law firm does not have a property interest in legal matters handled on an hourly basis, or in the profits generated by former partners who continue to work not the hourly fee matters after they are transferred to the partners’ new firms. View "Heller Ehrman LLP v. Davis Wright Tremaine LLP" on Justia Law

The Supreme Court reversed Defendant’s conviction for conspiracy to murder Dean Noyes for lack of territorial jurisdiction and affirmed in all other respects the judgment convicting Defendant of first degree murder and conspiracy to murder his wife, Carole Garton, and her fetus. The Supreme Court held (1) any error in the trial court’s ruling prohibiting Defendant from wearing his wedding ring during trial was harmless; (2) the trial court did not err by allowing the prosecution’s investigating officers to bypass metal detectors while entering the courthouse; (3) Defendant was not prejudiced by the introduction of hearsay statements by the county coroner concerning the state of Carole’s body and her cause of death; (4) the trial court erred in finding that it had jurisdiction over the charge that Defendant conspired to murder Dean in Oregon; (5) any error in the trial court’s instructions to the jury was harmless; (6) the trial court did not err in denying Defendant’s motion for entry of judgment of acquittal; and (7) there was no cumulative error requiring reversal of Defendant’s convictions. View "People v. Garton" on Justia Law

In calculating an employee’s overtime pay rate when the employee has earned a flat sum bonus during a single pay period, the divisor for purposes of calculating the per-hour value of the bonus should be the number of nonovertime hours the employee worked during the pay period, rather than the number of hours the employee actually worked during the pay period, including overtime hours, or the number of nonovertime hours that exist in the pay period, regardless of the number of hours the employee actually worked.Plaintiff filed a complaint against Defendant, his former employer, alleging that Defendant had not properly computed his overtime pay under California law. Defendant moved for summary judgment, arguing that the trial court should look for “persuasive guidance” to a federal regulation explaining how to factor a flat sum bonus into an employee’s regular rate of pay and that its formula for calculating overtime compensation was complaint with the relevant federal regulation. The trial court granted summary judgment for Defendant. The Court of Appeal affirmed. The Supreme Court reversed, thus favoring the formula that allocates an employee’s bonus to the nonovertime hours worked, rather than to all hours worked. View "Alvarado v. Dart Container Corp. of California" on Justia Law

The Supreme Court affirmed Defendant’s convictions for murder, residential robbery, residential burglary, and vehicle theft and Defendant’s sentence of death for the murder, holding that any potential error was harmless and that none of the potential errors were cumulatively prejudicial.On appeal, the Supreme Court held (1) Defendant failed to establish that any conflict of interest adversely affected his counsel’s performance; (2) any error resulting from Defendant’s absence from two discussions about counsel’s supposed conflict of interest was harmless beyond a reasonable doubt; (3) any challenged comments made by the judge did not disqualify the judge from presiding over the trial; (4) the trial judge’s choice to limit counsel’s time to question jurors during voir dire was not an abuse of discretion; (5) the trial court did not abuse its discretion in choosing to remove a seated juror during the guilt phase proceedings; (6) the prosecutor did not engage in impermissible misconduct; (7) any error in the trial court’s evidentiary rulings was harmless beyond a reasonable doubt; (8) any error in the trial court’s instructions to the jury was harmless; and (8) Defendant’s sentence did not violate the Eighth Amendment’s requirement of proportionate sentencing. View "People v. Perez" on Justia Law