Justia California Supreme Court Opinion Summaries

Petitioner’s constitutional challenges to Proposition 66, the Death Penalty Reform and Savings Act of 2016, did not warrant relief.Proposition 66, which was approved by California voters in the November 2016 election, is intended to facilitate the enforcement of judgments and achieve cost savings in capital cases. Petitioner sought writ relief from the Supreme Court, arguing that Proposition 66 embraces more than one subject in violation of the California Constitution, interferes with the jurisdiction of courts to hear original petitions for habeas corpus relief, violates inmates’ equal protection rights by treating capital prisoners differently from other prisoners with respect to successive habeas corpus petitions, and violates the separation of powers doctrine by materially impairing courts’ ability to resolve capital appeals and habeas corpus petitions. The Supreme Court denied relief, holding (1) Proposition 66 is not unconstitutional; but (2) in order to avoid separation of powers problems, provisions of Proposition 66 that appear to impose strict deadlines on the resolution of judicial proceedings must be deemed directive rather than mandatory. View "Briggs v. Brown" on Justia Law

The Supreme Court reversed Defendant’s conviction of misdemeanor battery of a peace officer, holding that the People failed to prove that the victim, a member of the City of Santa Barbara harbor patrol, was a “peace officer” within the meaning of Cal. Pen. Code 243(b). The Court of Appeal affirmed the conviction, concluding that a harbor patrol officer need not have the primary duty of law enforcement to be a peace officer. The Supreme Court reversed the judgment of the Court of Appeal to the extent it affirmed Defendant’s conviction for battery under section 243(b), holding (1) this court agrees with People v. Miller, 164 Cal. App. 4th 653, 665-668 (2008), and concludes that a harbor patrol officer must have the primary duty of law enforcement to be a peace officer; and (2) the People in this case did not prove that the primary duty of the harbor patrol officer battered by Defendant was law enforcement. View "People v. Pennington" on Justia Law

The interim adverse judgment rule applies when a trial court had initially denied summary judgment on the basis that a lawsuit had sufficient potential merit to proceed to trial but concluded after trial that the suit had been brought in bad faith because the claim lacked evidentiary support.In the underlying case, Plaintiffs were sued for misappropriation of trade secrets. Plaintiffs moved for summary judgment, which the trial court denied. The trial court subsequently granted judgment in favor of Plaintiffs. Plaintiffs later brought a malicious prosecution against the opposing parties’ lawyers in the trade secrets case. Defendants filed an anti-SLAPP motion, arguing that Plaintiffs could not establish a probability of success because the order denying summary judgment in the underlying trade secrets action established probable cause to prosecute that action. The trial court granted the motion to strike, concluding that the action was untimely. The court of appeal concluded that the action was timely but that the interim adverse judgment rule applied, thus barring the malicious prosecution suit. The Supreme Court affirmed, holding that the denial of summary judgment in the trade secrets action established probable cause to bring that action, and therefore, Plaintiffs could not establish a probability of success on their malicious prosecution claim. View "Parrish v. Latham & Watkins" on Justia Law

In this real estate purchase transaction the Supreme Court affirmed the court of appeal’s judgment reversing the trial court’s denial of an award of attorney fees. Here Seller brought a breach of contract action against Buyers for failing to purchase the subject property. The trial court concluded that Buyers were not liable under the purchase agreement because it had been superseded by the parties’ option agreement that granted Buyers the exclusive right, but not the obligation, to purchase the property. At issue before the Supreme Court was whether Buyers were entitled to attorney fees under the attorney fees provision in the option agreement. The Supreme Court held (1) Buyers’ assertion of the option agreement as an affirmative defense did not trigger the attorney fees provision in that agreement; but (2) under the circumstances of this case Buyers were nevertheless entitled to attorney fees under the attorney fees provision in the option agreement. View "Mountain Air Enterprises, LLC v. Sundowner Towers, LLC" on Justia Law

The Interstate Commerce Termination Act (ICCTA) preempts state regulation of rail transportation, and in this case, the application of the California Environmental Quality Act (CEQA) to North Coast Railroad Authority (NCRA) would not be inconsistent with the ICCTA and its preemption clause.The Supreme Court reversed the judgment of the court of appeal, which determined that CEQA is preempted by federal law when the project to be approved involves railroad operations. The Supreme Court held that the ICCTA is not so broadly preemptive, and under the circumstances of this case, the ICCTA does not preempt the application of CEQA to the freight rail project that was the subject of this litigation. The court remanded the matter for further proceedings consistent with this opinion. View "Friends of Eel River v. North Coast Railroad Authority" on Justia Law

Under the Criminal Justice Realignment Act of 2011 (Realignment Act) incarcerated parolees facing revocation under Cal. Penal Code 1203.2 are entitled to a timely preliminary hearing.At issue in this case was whether the enactment of the Realignment Act, which transferred jurisdiction over most parole revocation hearings from the Board of Parole Hearings to the superior courts, made unnecessary a prompt preliminary hearing after arrest to determine whether there was probable cause to believe a parole violation had occurred. Even though this case was moot, the Supreme Court exercised its discretion to decide what procedure should govern parole revocation proceedings under the Realignment Act. The Supreme Court held that the preliminary hearing requirement set forth in Morrissey v. Brewer, 408 U.S. 471, (1972) applies to parole revocation proceedings conducted in superior court. View "People v. DeLeon" on Justia Law

To find that an inmate was armed with a firearm during the commission of the inmate’s challenged third strike offense under the Three Strikes law, a court reviewing a Three Strikes Reform Act of 2012 (the Act) recall petition may rely on facts underlying counts dismissed pursuant to the inmate’s plea agreement, so long as those facts establish that the defendant was armed during his offense of conviction.In this case, Petitioner petitioned to recall his sentence under the Act. The trial court denied the petition, finding that Petitioner was armed with a firearm during the commission of his third offense qualifying as a strike under the Three Strikes law. In making this finding, the trial court reviewed the transcript of the 1996 preliminary hearing held before Petitioner pleaded guilty. The court of appeal affirmed the denial of the petition. The Supreme Court affirmed, holding that the trial court did not err in determining that Petitioner was armed with a firearm during the commission of his grand theft from a person offense. View "People v. Estrada" on Justia Law

The first clause of Cal. Welf. & Inst. Code 300(b)(1) authorizes a juvenile court to exercise dependency jurisdiction over a child without a finding that a parent is at fault or blameworthy for her failure or inability to supervise or protect her child. The court of appeal also concluded that section 300(b)(1)’s first clause does not require such a finding. In this case, the Los Angeles County Department of Children and Family Services filed a petition to declare then seventeen-year-old R.T. a dependent of the juvenile court on the ground that she faced a substantial risk of serious physical harm or illness as a result of Mother’s failure or inability adequately to supervise or protect her. The juvenile court asserted jurisdiction over R.T. The court of appeal affirmed the jurisdictional and dispositional orders of the juvenile court. The Supreme Court affirmed, holding that when a child’s behavior places her at substantial risk of serious physical harm and a parent is unable to protect or supervise that child, the juvenile court’s assertion of jurisdiction is authorized under section 300(b)(1). View "In re R.T." on Justia Law

The Supreme Court affirmed Defendant’s convictions for two counts of first degree murder and related crimes and Defendant’s sentence of death. The court held (1) any error in the trial court’s restriction of cross-examination was harmless beyond a reasonable doubt; (2) the trial court did not abuse its discretion in excluding certain testimony during the guilt phase to the effect that Defendant was no longer an active member of the Rolling 20’s Crips at the time of the shootings; (3) the trial court did not err in permitting the prosecution to play for the jury a recorded telephone call between Defendant and his brother that took place shortly before Defendant’s first preliminary hearing; (4) the trial court did not err in excusing a certain juror during the death qualification phase of jury selection; and (5) Defendant’s challenges to California’s capital sentencing scheme and to his death sentence were unavailing. View "People v. Jones" on Justia Law

The Medical Board of California did not violate patients’ right to privacy under Cal. Const. art. I, 1 when it obtained data from the Controlled Substance Utilization Review and Evaluation System (CURES), California’s prescription drug monitoring program, without a warrant or subpoena supported by good cause during the course of investigating the patients’ physician, Dr. Alwin Carl Lewis. The Supreme Court affirmed the judgment of the court of appeal, which determined that the Board’s actions did not involve a significant intrusion on a privacy interest protected by the state Constitution’s privacy provision and, even if there was an invasion of privacy, it was justified. The Supreme Court held that even assuming the Board’s actions constituted a serious intrusion on a legally protected privacy interest, its review of Lewis’s patients’ CURES records was justified by the state’s dual interest in protecting the public from the unlawful use and diversion of a particularly dangerous class of prescription drugs and protecting patients from negligent or incompetent physicians. View "Lewis v. Superior Court of Los Angeles County" on Justia Law