Justia California Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Defendant’s automatic motion to modify the jury’s verdict of death and imposing a judgment of death in this case in which Defendant pleaded guilty to two counts of first degree murder under the special circumstances of multiple murder and murder in the course of a robbery.In affirming, the Supreme Court held (1) Defendant’s counsel provided constitutionally effective assistance; (2) the trial court did not prejudicially err in denying Defendant’s motion to change venue; (3) no prejudicial error occurred during jury selection; (4) Defendant’s challenges to the admission of certain testimony were unavailing; (5) reliance on evidence in aggravation of two crimes of violence Defendant committed when he was seventeen years old and of his conviction for one of those crimes did not violate Defendant’s rights under the Eighth Amendment; (6) there was no error in excluding evidence of the impact of Defendant’s execution on his family; and (7) none of Defendant’s remaining arguments warranted relief from the judgment. View "People v. Rices" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of first degree murder and one count of second degree murder and sentencing him to death. The court held (1) Defendant was not deprived of the right to a jury drawn from a fair cross-section of the community; (2) the trial court did not err in ruling that evidence of an uncharged murder would be admissible to impeach Defendant’s witness under certain circumstances; (3) the trial court did not err in ruling that the prosecution could admit evidence that Defendant had attempted to escape from jail; (4) the trial court did not err in admitting the victim’s statement that Defendant was into “heavy stuff” or in admitting victim impact evidence; (4) there was no prejudicial error in the jury instruction; (5) the trial court did not err in denying Defendant’s requests for a separate penalty phase jury and sequestered voir dire; (6) Defendant was not prejudiced by any improper argument by the prosecutor; (7) the trial court did not abuse its discretion in admitting photographs of the victims or evidence that Defendant will kill a guard to escape; and (8) Defendant’s sentence was constitutional. View "People v. Henriquez" on Justia Law

On a petition for a writ of habeas corpus, as on direct appeal, error under People v. Chiu, 325 P.3D 972 (Cal. 2014), requires reversal unless the reviewing court concludes beyond a reasonable doubt that the jury actually relied on a legally valid theory in convicting the defendant of first degree murder.Petitioner was convicted of first degree murder. The jury was instructed on both a direct aiding and abetting theory and a natural and probable consequences theory. After Petitioner was convicted, the Supreme Court held in Chiu that a natural and probable consequences theory of liability cannot serve as a basis for a first degree murder conviction. Petitioner filed this petition for writ of habeas corpus arguing that he was entitled to have his conviction reduced to second degree murder under Chiu. The court of appeal acknowledged that the jury instruction on natural and probable consequences was error under Chiu but affirmed the first degree murder conviction on the ground that it was supported by sufficient evidence. The Supreme Court reversed and remanded with directions to grant Petitioner habeas corpus relief, holding that the Chiu error in this case was prejudicial. View "In re Martinez" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the court of appeal in this case concerning the application of constitutional limitations to a statutorily authorized ground water charge imposed on well operators by a local water conservation district to fund certain conservation activities. The City of San Buenaventura argued (1) the charges violate article XIII D of the California Constitution; and (2) alternatively, the charges violate article XIII C of the California Constitution, as amended by Proposition 26. The Supreme Court held (1) the court of appeal properly concluded that article XIII C, as amended by Proposition 26, rather than article XIII D, supplies the proper framework for evaluating the constitutionality of the groundwater pumping charges at issue in this case; but (2) because the court of appeal did not address the City’s argument that the charges do not bear a fair or reasonable relationship to the payor’s burdens or on benefits from the United Water Conservation District’s conservation activities, as required by article XIII C, this case must be remanded for consideration of that question. View "City of San Buenaventura v. United Water Conservation District" on Justia Law

A person convicted before Proposition 47’s (the “Safe Neighborhoods and Schools Act”) passage for vehicle theft under Cal. Veh. Code 10851 may be resentenced under Cal. Penal Code 1170.18 if the person can show the vehicle was worth $950 or less.As approved by voters in 2014, Proposition 47 added Cal. Penal Code 490.2, which provides that “obtaining any property by theft” is to be punished as a misdemeanor if the value of the property taken is $950 or less. Cal. Penal Code 1170.18 establishes procedures under which a person serving a felony sentence at the time of Proposition 47’s passage may be resentenced to a misdemeanor term. At issue was the application of these provisions to a prior conviction under Cal. Veh. Code 10851 - taking or driving a vehicle without the owner’s consent. The Supreme Court held that the lower courts in this case erred in holding that a defendant with a Cal. Veh. Code 10851 conviction is categorically ineligible for resentencing under Proposition 47. View "People v. Page" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal ruling that a court’s error in failing to issue a statement of decision as required by Cal. Code Civ. Proc. 632 is not reversible per se but is subject to harmless error review.The trial court issued a tentative decision finding that Defendant committed acts of sexual assault against Plaintiff and that Defendant’s conduct was a substantial factor in causing Plaintiff’s injuries. Plaintiff’s counsel submitted a proposed judgment to the court. The court signed the judgment without issuing a separate statement of decision. Defendant appealed, arguing that the trial court erred in failing to issue a statement of decision and that the error was reversible per se. The court of appeals concluded that the trial court erred but that the error did not result in a miscarriage of justice. The Supreme Court affirmed, holding that a trial court’s error in failing to issue a statement of decision upon a timely request is not reversible per se but is, rather, subject to harmless error review. View "F.P. v. Monier" on Justia Law

For the reasons set forth in a companion case issued today, Gerawan Farming, Inc. v. Agricultural Labor Relations Board, the Supreme Court held that the court of appeal correctly rejected Employer’s defense that Union had abandoned its employees and thus forfeited its status as bargaining representative.In this case, Employer refused to bargain with the labor union that its employees had elected as their bargaining representative under the Agricultural Labor Relations Act (ALRA). The Agricultural Labor Relations Board (Board) rejected Employer’s abandonment defense and determined that Employer’s refusal constituted an unfair labor practice under the ALRA. The Board ordered Employer to pay make-whole relief under Cal. Labor Code 1160.3. The court of appeal affirmed the Board’s rejection of Employer’s abandonment defense but reversed the Board’s make-whole relief award. The Supreme Court reversed in part, holding that the court of appeal (1) properly rejected Employer’s abandonment defense, but (2) did not accord the Board sufficient deference as to the issue of make-whole relief and improperly exercised the Board’s remedial authority. View "Tri-Fanucchi Farms v. Agricultural Labor Relations Board" on Justia Law

The Agricultural Labor Relations Act’s (ARLA) “mandatory mediation and conciliation” (MMC) statute neither violates equal protection nor unconstitutionally delegates legislative power. Further, employers may not refuse to bargain with unions - whether during the ordinary bargaining process or during MMC - on the basis that the union has abandoned its representative status.In this case, the United Farm Workers’ of America (UFW) filed an MMC request with the Agricultural Labor Relations Board after failing to reach a collective bargaining agreement with Gerawan Farming, Inc. Mediation also failed to produce an agreement, and therefore, the mediator submitted a report fixing the contractual terms. The Board adopted the report in its final order. The court of appeal concluded (1) the MMC statute on its face violates equal protection principles and improperly delegates legislative authority, and (2) an employer may not defend against a union’s MMC request by challenging the union’s certification as bargaining representative on the basis of abandonment. The Supreme Court disagreed, holding (1) the MMC statutes is not unconstitutional; and (2) an employer may not raise an abandonment defense to an MMC request. View "Gerawan Farming, Inc. v. Agricultural Labor Relations Board" on Justia Law

A landowner does not have a duty to assist invitees in crossing a public street when the landowner does no more than site and maintain a parking lot that requires invitees to cross the street to access the landowner’s premises, as long as the public street’s dangers are not obscured or magnified by some condition of the landowner’s premises or by some action taken by the landowner.Plaintiff sued Grace Family Church (the Church) for injuries he received when he was struck by a car as he crossed a public street between the main premises of the Church and the Church’s overflow parking area. In his complaint, Plaintiff alleged that the Church, which did not control the public street, owed him a duty of care to assist him in safely crossing the public street and that the Church was negligent in failing to do so. The trial court granted the Church summary judgment. The Court of Appeal reversed. The Supreme Court reversed, holding that because the Church did nothing more than site and maintain a parking lot that required its invitees to cross a public street, the Church owed Plaintiff no duty to protect him from the obvious dangers of crossing the public street. View "Vasilenko v. Grace Family Church" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of first-degree murder and other crimes and sentencing him to death but remanded the case to the trial court for reconsideration of Defendant’s restitution fine. The court held (1) although Defendant’s absent from portions of the proceedings violated his statutory right to be present, the error was harmless; (2) the trial court did not violate Defendant’s right to an impartial jury by excusing a prospective juror for cause because of her views on the death penalty; (3) the trial court did not err in admitting Defendant’s confession; (4) the trial court did not abuse its discretion by excluding evidence of a conditional plea offer as mitigation during the penalty phase; (5) Defendant’s challenges to California’s death penalty scheme were unavailing; and (6) the trial court applied the wrong statute in imposing Defendant’s restitution fine. View "People v. Wall" on Justia Law