Justia California Supreme Court Opinion Summaries

Petitioner was charged with robbery. Pursuant to a plea agreement, Petitioner pleaded guilty to grand theft from the person, a felony, and admitted a prior robbery conviction on condition that he receive a six-year prison sentence. The People, in return, dismissed the robbery charge. The electorate later enacted Proposition 47, which reduced the grand theft offense to a misdemeanor. Defendant filed a petition for recall of sentence, asking the trial court to resentence him as a misdemeanant. The trial court denied relief, concluding that reducing the sentence would deprive the People of the benefit of their plea bargain, and thus they should be permitted to rescind the plea and reinstate the original robbery charge. The Court of Appeal affirmed. The Supreme Court reversed, holding that the People were not entitled to set aside the plea agreement when Defendant sought to have his sentence recalled under Proposition 47. View "Harris v. Superior Court of Los Angeles County" on Justia Law

Petitioner, an inmate, filed a petition for writ of habeas corpus, alleging that he received ineffective assistance of counsel in his criminal proceedings. One week later, Petitioner asked the court clerk for the name of the judge assigned to his petition. Superior Court Judge John M. Thompson subsequently summarily denied Petitioner’s habeas corpus petition. Petitioner then filed a new petition for writ of habeas corpus, and, in addition, Petitioner alleged that he was denied his statutory right to peremptorily challenge Judge Thompson. The Court of Appeal issued a writ of mandate directing the superior court to reassign the assessment of Maas’s petition for writ of habeas corpus to a judge other than Judge Thompson. The Supreme Court affirmed, holding that a petitioner who requests the name of the judge assigned to examine his habeas corpus petition is entitled to notice of that assignment and is entitled to peremptorily challenge the assigned judge, so long as all of the procedural requirements of Cal. Civ. Proc. Code 170.6 have been satisfied. View "Maas v. Superior Court" on Justia Law

In 2006, the San Mateo Community College District and its Board of Trustees (collectively, District) proposed a district-wide facilities improvement plan that called for demolishing certain buildings and renovating others. The District approved the plan, determining that it would have no potentially significant, unmitigated effect on the environment. In 2011, the District proposed changes to the plan. The District approved the changes, determining that they did not require the preparation of a subsequent or supplemental environmental impact report under Public Resources Code section 21166 and CEQA Guidelines section 15162. The Court of Appeal invalidated the District’s decision, ruling that the District’s proposal was a new project altogether and, therefore, subject to the initial environmental review standards of Public Resources Code section 21151 rather than the subsequent review standards of section 21166 and section 15162. The Supreme Court reversed, holding that the Court of Appeal erred in its application of the new project test. Remanded for further proceedings. View "Friends of College of San Mateo Gardens v. San Mateo Cmty. College Dist." on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder and related crimes. After the penalty phase of the trial, the jury returned a verdict of death. The Supreme Court reversed the judgment of death, remanded the matter for a new penalty determination and reconsideration of the question of a restitution fine under the currently applicable statute, and affirmed the judgment in all other respects, holding (1) no prejudicial error occurred during the guilt phase of trial; (2) the trial court erred in excusing a prospective juror for cause under Witt based solely on written questionnaire responses regarding his views on capital punishment, and therefore, the penalty judgment must be reversed for error under Wainwright v. Witt and Witherspoon v. Illinois; and (3) the question of Defendant’s restitution fine must be remanded for reconsideration because Defendant’s restitution fine was imposed pursuant to a statute that was subsequently repealed in its entirety and replaced by a statute lessening punishment. View "People v. Covarrubias" on Justia Law

Eight separate complaints were filed in San Francisco Superior Court by or on behalf of 678 individuals. Eighty-six of those individuals were California residents and the remainder were nonresidents. All of the plaintiffs were allegedly prescribed Plavix, a drug created and marketed by Bristol-Myers Squibb Company (BMS), and allegedly suffered adverse consequences. BMS, which conducts significant business and research activities in California but is neither incorporated nor headquartered in the state, moved to quash service of summons on the ground that the court lacked personal jurisdiction over it to adjudicate the claims of the nonresident plaintiffs. The superior court denied BMS’s motion. BMS petitioned the Court of Appeal for a writ of mandate, naming the nonresident plaintiffs as real parties in interest. The Court of Appeal denied the writ, concluding that BMS was subject to the personal jurisdiction of the California courts on the basis of specific jurisdiction. The Supreme Court affirmed, holding that, in light of BMS’s extensive contacts with California, courts may exercise specific personal jurisdiction over the nonresident plaintiffs’ claims in this action, which arise from the same course of conduct that gave rise to the California plaintiffs’ claims. View "Bristol-Myers Squibb Co. v. Superior Court of San Francisco County" on Justia Law

The Regional Water Quality Control Board, Los Angeles Region, a state agency, issued a permit authorizing local agencies (collectively, Operators) to operate storm drain systems. Permit conditions required that the Operators take various steps to maintain the quality of California’s water and to comply with the federal Clean Water Act. Some Operators sought reimbursement for the cost of satisfying the conditions. The Commission on State Mandates concluded that each required condition was mandated by the state, rather than by federal law, and therefore, the Operators were entitled to reimbursement for the associated costs. The Court of Appeal reversed, concluding that the permit conditions were federally mandated and thus not reimbursable. The Supreme Court reversed, holding that the permit conditions were imposed as a result of the state’s discretionary action, and therefore, the conditions were not federally mandated and were reimbursable. View "Dep’t of Fin. v. Comm’n on State Mandates" on Justia Law

Defendant was charged with criminal offenses. Defendant filed a renewed motion to suppress pursuant to Cal. Penal Code 1538.5(i). Judge Vincent Chiarello granted the renewed motion, and the case was dismissed at the People’s request. Thereafter, the People filed a new complaint alleging the same offenses. Defendant filed a motion to suppress, asserting that the proper venue for the motion was before Judge Chiarello pursuant to section 1538.5(p). The matter came before Judge Vanessa Zecher after Judge Jerome Nadler concluded that Judge Chiarello was not available. Judge Zecher denied Defendant’s motion. Defendant filed a renewed motion to suppress, arguing that Judge Chiarello should have heard the relitigated motion to suppress. The trial court concluded that a renewed motion to suppress under section 1538.5(i) was not the proper vehicle for setting aside Judge Zecher’s order. Defendant was found guilty of child pornography. The Court of Appeal affirmed. The Supreme Court reversed, holding (1) a trial court’s discretion to make determinations concerning the availability of judges must be exercised in a manner consistent with constraints imposed by section 1538.5(p); and (2) in this case, the trial court abused its discretion by not taking reasonable measures to ensure compliance with section 1538.5(p), and the error was prejudicial. View "People v. Rodriguez" on Justia Law

Defendant was charged by criminal complaint with unpermitted use of a suction dredge. Suction dredging is a technique used by miners to remove matter from the bottom of waterways, extract minerals, and return the residue to the water. Defendant demurred, arguing (1) state law aimed at environmental conservation effectively banned suction dredging in California, thereby preventing him from using the only commercially practicable method of extracting gold from his mining claim; and (2) because federal law promoted mining on federal land, the state’s contrary legislation should be preempted. The trial court overruled the demurrer. The Court of Appeal reversed and remanded for consideration of additional evidence and argument. The Supreme Court reversed, holding that Congress did not guarantee miners a right to mine immunized from exercises of the states’ police powers. View "People v. Rinehart" on Justia Law

After a jury trial, Defendant was convicted of one count each of murder, robbery, burglary, conspiracy to commit robbery, conspiracy to commit burglary, and the unlawful driving or taking of a vehicle. The trial court sentenced Defendant to death for the murder. Defendant appealed, arguing that the trial court erred in excluding certain statements made by the actual killer of the murder victim in which the killer claimed that he acted alone in committing the murder and that Defendant was not involved. Specifically, Defendant asserted that the hearsay statements were admissible as declarations against interest. The Supreme Court reversed the judgment of death, holding that the trial court erred in excluding the testimony and that the error was harmless at the guilt phase but was not harmless at the penalty phase. View "People v. Grimes" on Justia Law

Plaintiff, a retired employee of the State Department of Justice, filed suit against the State and State Controller’s Office on behalf of herself and a class of resigned and retired state employees who did not receive their final wages within the time period set out in Cal. Labor Code 202 and 203. Under these statutes, an employer must make prompt payment of the final wages owed to an employee who is “discharged” or “quits” his or her employment. The trial court sustained Defendants’ demurrer, concluding that because Plaintiff had “retired” from her job, she had not stated a claim for statutory penalties under section 203. The Court of Appeal reversed, holding that sections 202 and 203 apply when an employee “quits to retire.” The Supreme Court affirmed, holding (1) sections 202 and 203 apply when employees “retire” from their employment; and (2) Plaintiff’s decision to name the State as a defendant rather than the Department of Justice was not a basis for dismissing her suit. View "McLean v. State" on Justia Law