Justia California Supreme Court Opinion Summaries

Defendant was convicted of possessing cocaine base for sale and placed on three years of probation. The terms of Defendant’s probation barred him from possessing firearms or illegal drugs. Defendant offered no objection to either condition. Defendant appealed, arguing that these conditions were unconstitutionally vague on their face because they did not explicitly define the mens rea required to sustain a violation of probation. The court of appeal affirmed, concluding that the firearms and narcotics conditions did not need to be modified to bar “knowing” possession. The Supreme Court affirmed, holding that the probation conditions afford Defendant fair notice of the conduct required of him because they already include an implicit requirement of knowing possession. View "People v. Hall" on Justia Law

After a jury trial, Defendant was convicted of murder in the course of a robbery with personal use of a deadly weapon. Defendant was sentenced to death. The Supreme Court affirmed, holding (1) there was no Pitchess error; (2) the trial court did not err in its jury selection rulings; (3) the trial court did not err in admitting Defendant’s incriminating recorded statements, as the statements were voluntarily given; (4) the trial court did not err in denying Defendant’s motion for severance; (5) the trial court did not abuse its discretion in admitting photographs of the victim; (6) any error in the stationing of a deputy near the witness stand during Defendant’s testimony was harmless; (7) no prejudicial error occurred during the penalty phase of trial; (8) the trial court did not err in denying Defendant’s automatic motion to modify the death verdict; and (9) California’s use of the death penalty does not violate international norms of evolving standards of decency in violation of the Eighth and Fourteenth Amendments. View "People v. Winbush" on Justia Law

At issue in this case was the Insurance Commissioner’s 2011 regulation (the Regulation) covering replacement cost estimates for homeowners insurance. A few weeks before the Regulation was to become effective, Association of California Insurance Companies and the Personal Insurance Federation of California (collectively, the Association) filed a complaint for declaratory relief challenging the validity of the Regulation. The trial court invalidated the Regulation, concluding that the Regulation exceeded the Commissioner’s authority by attempting to define additional acts or practices by regulation rather than by the procedure set out in Cal. Ins. Code 790.06. The Court of Appeal affirmed. The Supreme Court reversed, holding that Cal. Ins. Code 790.10 explicitly vests in the Commissioner authority to issue “reasonable rules and regulations” to administer the Unfair Insurance Practices Act, and this statutory authority supported the Regulation. View "Association of California Insurance Cos. v. Jones" on Justia Law

After a jury trial, Defendant was convicted of rape of an intoxicated person and rape of an unconscious person. The convictions were based on the same act. On appeal, the Court of Appeal held that Defendant could not be convicted of both counts and vacated the conviction of rape of an unconscious person. The Supreme Court reversed, holding that Defendant was properly convicted of both rape of an intoxicated person and rape of an unconscious person, as the Legislature did not intend a defendant who commits oral copulation of an intoxicated and unconscious person can be guilty of two offenses, whereas a defendant who commits rape of an intoxicated and unconscious person can be guilty of only one offense. View "People v. White" on Justia Law

Eke Wokocha sued Sharp Memorial Hospital alleging that the Hospital’s negligence caused his quadriplegia. The jury found that the Hospital was negligent but that this negligence did not cause Wokocha’s quadriplegia. Wokocha subsequently died, and Wokocha’s widow, Berthe Kabran, was substituted as plaintiff. Kabran moved for a new trial on the basis of evidence obtained from an autopsy that purportedly called into question the jury’s causation determination. Kabran did not timely pay the necessary filing fee in submitting expert affidavits explaining the significance of this new evidence. The Hospital, however, did not object to the timeliness of the affidavits. Consequently, the trial court granted Kabran’s motion for a new trial. The Hospital appealed, arguing that because the affidavits were not timely filed, the trial court lacked jurisdiction to rely on them in hearing the motion for a new trial. The Court of Appeal affirmed. The Supreme Court affirmed, holding that because the Hospital did not object to the timeliness of the affidavits in the trial court, it may not raise this issue for the first time on appeal. View "Kabran v. Sharp Memorial Hospital" on Justia Law

Under California’s anti-SLAPP statute, unless a plaintiff establishes a probability of prevailing on a cause of action arising from constitutionally protected speech or petitioning activity, the court must grant the defendant’s motion to strike the claim and, generally, must also award the defendant attorney’s fees. In the instant case, Plaintiff, an attorney, filed an action against the State Bar after she was disciplined for committing violations of the rules of professional conduct. The State Bar filed a special motion to strike the complaint under the anti-SLAPP statute. The superior court granted the motion and awarded attorney’s fees to the State Bar, concluding that Plaintiff’s claims arose from protected petitioning activity and that Plaintiff had not shown a likelihood of prevailing because, inter alia, a superior court lacks subject matter jurisdiction over attorney discipline matters. The Court of Appeal reversed, concluding that because the trial court had no jurisdiction to rule on the anti-SLAPP motion, it also lacked jurisdiction to award attorney fees under Cal. Civ. Proc. Code 425.16. The Supreme Court reversed, holding that a court that lacks subject matter jurisdiction over a claim may grant a special motion to strike the claim under section 425.16 and thus may award attorney’s fees and costs to the defendant. View "Barry v. State Bar of California" on Justia Law

The ACLU submitted a request under the California Public Records Act (PRA) to the Los Angeles County Counsel seeking invoices specifying the amounts that the County and been billed by any law firm in connection with several different lawsuits alleging excessive force against jail inmates. The County refused to provide invoices for the lawsuits that were still pending on the basis of attorney-client privilege. The ACLU petitioned for writ of mandate seeking to compel the County to disclose the requested records. The superior court granted the petition, concluding that the County had failed to show that the invoices were attorney-client privileged communications. The County then filed a petition for writ of mandate. The court of appeal granted the petition and vacated the superior court’s order, concluding that the invoices were confidential communications within the meaning of Cal. Evid. Code 952. The Supreme Court affirmed, holding (1) the attorney-client privilege does not categorically shield everything in a billing invoice from PRA disclosure, but invoices for work in pending and active legal matters implicate the attorney-client privilege; and (2) therefore, the privilege protects the confidentiality of invoices for work in pending and active legal matters. View "Los Angeles County Board of Supervisors v. Superior Court of Los Angeles County" on Justia Law

After a trial, Defendant was convicted of carjacking and robbery. Both convictions were based on the same forceful taking of a vehicle. Defendant appealed, arguing that his forceful taking of the vehicle constituted a single physical act subject to the prohibition on multiple punishment under Cal. Penal Code 654, and therefore, section 654 barred his robbery sentence. The court of appeal affirmed, concluding that there was sufficient evidence from which the trial court could have concluded that there were two intents. The Supreme Court reversed, holding that the same action completed the actus reus for each of the crimes of which Defendant was convicted, and therefore, Defendant’s one-year robbery sentence must be stayed. View "People v. Corpening" on Justia Law

Plaintiffs worked as security guards for Defendant. Defendant required that guards keep their pagers and radio phones on even during off-duty rest periods required under Cal. Labor Code 226.7 and Industrial Welfare Commission wage order 4-2001. Defendant also required Plaintiffs to be responsive to calls when needs arose. Plaintiffs sued Defendant alleging that Defendant failed to provide the rest periods that Plaintiffs were entitled to receive under state law. The trial court granted summary judgment for Plaintiffs. The Court of Appeal reversed. The Supreme Court reversed, holding that California law requires employers to relieve their employees of all work-related duties and employer control during ten-minute rest periods. View "Augustus v. ABM Security Services, Inc." on Justia Law

This case involved the practice of short-term deferred deposit lending, often referred to as “payday” or “cash advance” lending. After the Legislature enacted the California Deferred Deposit Transaction Law (the Law), which limits the size of each loan and the fees that lenders may charge, some deferred deposit lenders sought affiliation with federal recognized Indian tribes, which are generally immune from suit on the basis of tribal sovereign immunity. In this case, a pair of federally recognized tribes created affiliated business entities, which provide deferred deposit loans through the internet to borrowers in California under terms that allegedly violated the Law. At issue in this case was whether these tribally affiliated entities were immune from suit as “arms of the tribe.” The Supreme Court clarified the legal standard and burden of proof for establishing arm-of-the-tribe immunity and held that the entities in this case failed to show by a preponderance of the evidence that they were entitled to tribal immunity as an arm of its affiliated tribe. Remanded for the trial court to address the issue of whether the parties had the opportunity to fully litigate their claims under that standard. View "People ex rel. Owen v. Miami Nation Enterprises" on Justia Law