Justia California Supreme Court Opinion Summaries

This California Environmental Quality Act (CEQA) dispute centered on whether an environmental impact report (EIR) must identify areas that might qualify as environmentally sensitive habitat areas (ESHA) under the California Coastal Act and account for those areas in its analysis of mitigation measures and project alternatives. The City of Newport Beach approved a project for the development of a parcel known as Banning Beach. Banning Ranch Conservancy (BRC) sought a writ of mandate to set aside the approval, alleging (1) the EIR was inadequate, and (2) the City violated a general plan provision by failing to work with the California Coastal Commission to identify wetlands and habitats. The trial court found the EIR sufficient but concluded that the general plan required the City to cooperate with the Coastal Commission before approving the project. The Court of Appeal (1) agreed that the EIR complied with CEQA requirements; but (2) reversed on the general plan issue. The Supreme Court reversed and granted BRC relief on its CEQA claim, holding (1) CEQA requires an EIR to identify areas that might qualify as ESHA under the Coastal Act; and (2) the City’s failure to discuss ESHA requirements and impacts was neither insubstantial nor merely technical. View "Banning Ranch Conservancy v. City of Newport Beach" on Justia Law

Defendant, a Canadian citizen, pleaded guilty to a drug possession charge. Defendant filed a motion to withdraw the plea on grounds of mistake or ignorance. The trial court denied the motion, concluding that it was insufficient because Defendant had received the standard statutory advisement that a criminal conviction may have the consequences of deportation. The Court of Appeal affirmed. The Supreme Court reversed, holding that receipt of the standard statutory advisement that a criminal conviction “may” have adverse immigration consequences does not bar a noncitizen defendant from seeking to withdraw a guilty plea on that basis. Remanded to permit the trial court to determine whether Defendant has shown good cause for withdrawing his plea. View "People v. Patterson" on Justia Law

At issue in this case was whether theft of access card account information is one of the crimes eligible for reduced punishment under Proposition 47. In 2014, Defendant pleaded no contest to a felony. Voters subsequently approved Proposition 47, which reduced the punishment for several crimes previously punished as felonies. In 2015, Petitioner filed a resentencing petition. The superior court denied the petition, concluding that Proposition 47 does not apply to theft of access card information. The Court of Appeal reversed. The Supreme Court affirmed, holding that theft of access card account information is one of the crimes eligible for reduced punishment under Proposition 47. View "People v. Romanowski" on Justia Law

Under the terms of a spendthrift trust established by his parents, Defendant was entitled to receive over one million dollars, all to be paid out of trust principal. Before the trust’s first payment, Defendant filed for bankruptcy. The bankruptcy trustee sought a declaratory judgment on the extent of the bankruptcy trustee’s interest in the trust. The bankruptcy court concluded that the bankruptcy trustee, standing as a hypothetical lien creditor, could reach twenty-five percent of Defendant’s interest in the trust. The bankruptcy appellate panel affirmed. On appeal, the Court of Appeals for the Ninth Circuit asked the Supreme Court to clarify the relevant provisions of the California Probate Code. The Supreme Court held (1) where a spendthrift trust pays the beneficiary entirely out of principal, the California Probate Code does not limit a bankruptcy estate’s access to the trust to twenty-five percent of the beneficiary’s interest; and (2) with limited exceptions, a general creditor may reach a sum up to the full amount of any distributions that are currently due and payable to the beneficiary even though they are still in the trustee’s hands and separately may reach a sum up to twenty-five percent of any payments that are anticipated to be made to the beneficiary. View "Carmack v. Reynolds" on Justia Law

In 2014, the electorate passed the Safe Neighborhoods and Schools Act (the Act), which reduced penalties for certain theft and drug offenses by amending existing statutes. The Act created the crime of “shoplifting,” which was defined as entering an open commercial establishment during regular business hours with the intent to commit “larceny” of property worth $950 or less. In 2013, Defendant entered a bank to cash a stolen check for less than $950. Defendant pled guilty to felony burglary. Defendant later petitioned for recall of his sentence and resentencing under Cal. Penal Code 1170.18, arguing that his conduct would have constituted misdemeanor shoplifting under the Act. The trial court denied the petition. The court of appeal affirmed. The Supreme Court reversed, holding (1) the electorate intended that the shoplifting statute apply to an entry to commit a nonlarcenous theft; and (2) therefore, Defendant’s criminal act now constitutes shoplifting under Cal. Penal Code 459.5, subd. (a), and Defendant may properly petition for misdemeanor resentencing. View "People v. Gonzales" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and other crimes. The jury found true special-circumstance allegations. After a penalty phase, the jury returned a verdict of death.The trial court denied Defendant’s motion for modification of his sentence to life without the possibility of parole. The Supreme Court affirmed, holding (1) no prejudicial error occurred during the pretrial phase of trial or during the guilt phase of trial; (2) substantial evidence supported Defendant’s convictions; (3) no prejudicial error occurred during the penalty phase of trial; and (4) Defendant’s challenges to the constitutionality of California’s death penalty scheme were unavailing. View "People v. Brooks" on Justia Law

Defendant pleaded no contest to two counts of nonforcible lewd conduct. The trial court placed Defendant on probation, ordered him to register as a sex offender, mandated his participation in an approved sex offender management program, and imposed two probation conditions that were the subject of this appeal - (1) that Defendant waive any privilege against self-incrimination and participate in polygraph examinations, pursuant to Cal. Penal Code 1203.067(b)(3); and (2) that Defendant waive any psychotherapist-patient privilege, pursuant to Cal. Penal Code 1203.067(b)(4). Defendant appealed, arguing that conditioning probation on the waiver of his privilege against self-incrimination and on his participation in polygraph examinations violated his Fifth Amendment rights and, like the waiver of his psychotherapist-patient privilege, was unconstitutionally overbroad. The Court of Appeal upheld the validity of the subdivision (b)(4) and (b)(3) conditions. The Supreme Court affirmed, holding that the probation conditions challenged in this case were not unconstitutional where they enabled those charged with monitoring the probation to obtain the information they need while otherwise safeguarding the probation’s privacy and protecting the probation from compelled self-incrimination. View "People v. Garcia" on Justia Law

After a jury trial, Defendant was convicted of two counts of robbery. The jury found true allegations that Defendant personally used a firearm during both robberies. On appeal, Defendant argued that the trial court committed reversible error by failing to instruct the jury on the elements of robbery. The Attorney General conceded the error but argued that it was harmless beyond a reasonable doubt. The Court of Appeal reversed, concluding that the error was reversible per se. The Supreme Court reversed, holding (1) under the circumstances of this case, the trial court’s failure to give the standard jury instruction on the elements of robbery was not reversible per se but was reversible unless harmless beyond a reasonable doubt; and (2) the error in this case was harmless beyond a reasonable doubt. View "People v. Merritt" on Justia Law

In People v. Hosner, the Supreme Court held that an indigent criminal defendant facing retrial is presumptively entitled to a full and complete transcript of the prior proceedings. Defendant in this case was an indigent pro se defendant charged with making criminal threats, among other offenses. A jury deadlocked on the charges, the court declared a mistrial, and retrial was set. At a pretrial hearing, the trial court granted Defendant’s motion for a “complete record of trial transcripts.” Defendant received a transcript that included all witness testimony from the first trial but omitted the opening statements and closing arguments. The court then denied Defendant’s request for a transcript of the opening statements and closing arguments. After a trial, the jury found Defendant guilty as charged. The Court of Appeal affirmed, holding that Hosner’s presumption applies only to transcripts of witness testimony and not to transcripts of opening statements and closing arguments. The Supreme Court affirmed on different grounds, holding (1) a defendant facing retrial is presumptively entitled to a full transcript of the previous trial, including opening and closing statements; (2) when a defendant is denied only a portion of the transcript, the harmless error rule applies; and (3) the error was harmless in this case. View "People v. Reese" on Justia Law

Plaintiff, a minor, filed a complaint against Huntington Beach Union High School District (District), alleging that he was injured in a school football game. Plaintiff’s personal injury action accrued on October 31, 2011, the date of his diagnosis. Plaintiff did not file a claim within six months, as required by Cal. Gov't Code 911.2(a), but presented the District with an application to file a late claim nearly one year after the claim accrued. Because the District took no action on the application, it was deemed denied on December 8, 2012 by operation of law. Under Cal. Gov't Code 946.6(b), a petition for relief from the obligation to present a claim before brining suit must be filed within six months after a late claim application is either denied or deemed denied. Plaintiff did not file such a petition until October 28, 2013. The trial court rejected the petition. The court of appeal affirmed. The Supreme Court affirmed, holding that Plaintiff missed the six-month window for petition the trial court for relief, and therefore, the trial court properly dismissed the petition as untimely. View "J.M. v. Huntington Beach Union High School District" on Justia Law