Justia California Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of the first degree murder of a peace officer. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not err in failing to suspend proceedings and investigate whether Defendant was competent to stand trial; (2) Defendant’s ineffective assistance of counsel claim was inappropriate to address on appeal; (3) the trial court’s failure to suspend proceedings and hold a competency hearing prior to judgment did not violate Defendant’s due process rights; (4) the trial court did not err in allowing Defendant to waive his right to counsel; (5) the trial court did not err by failing to revoke Defendant’s self-representation during the penalty phase pursuant to Cal. Penal Code 686.1; (6) the trial court did not err in failing to obtain an updated Faretta waiver after the People filed a notice of intent to seek death; (7) Defendant’s claim that certain jurors should have been excused for cause was forfeited; (8) the trial court did not deprive Defendant of his constitutional right to testify in his own defense by excluding his liberty defense; and (9) Defendant’s challenges to the death penalty statute were without merit. View "People v. Mickel" on Justia Law

The Automobile Sales Finance Act (ASFA) is a consumer protection law that governs the sale of vehicles in which the buyer finances all or part of the car’s purchase. Plaintiffs were consumers who purchased vehicles from Raceway Ford, Inc., an automobile dealership. Plaintiffs alleged that Raceway violated ASFA when (1) after agreeing to an initial finance contract, Raceway would enter into a subsequent finance contract with a buyer and backdate the second contract to the date of the first contract, and (2) a computer error caused Raceway to incorrectly include smog-related fees in buyers’ purchase contracts. The trial court found in favor of Raceway on all claims relevant to this appeal. The court of appeal affirmed with respect to Plaintiffs’ smog fee claims but reversed with respect to Plaintiffs’ backdating claims. The Supreme Court affirmed in part and reversed in part, holding (1) Raceway’s practice of backdating contracts did not violate the ASFA; and (2) Raceway did violate the ASFA when its disclosed inaccurate smog fees, but Plaintiffs were not entitled to a remedy under ASFA because the violation was due to an accidental or bona fide error in computation. View "Raceway Ford Cases" on Justia Law

In 2006, Milan REI IV LLC (Milan) purchased more than fifty acres of land in the Orange Park Acres area in the City of Orange with plans to develop a residential development on the property. The City approved Milan’s request to amend its general plan and permit development on the property, despite controversy over the private development replacing public open space. Orange Citizens for Parks and Recreation and Orange Parks Association (together, Orange Citizens) challenged the City’s amendment by referendum. The City concluded that the referendum, whatever its outcome, would have no effect because a resolution from 1973 permitted residential development on the property. In 2012, fifty-six percent of voters rejected the City’s general plan amendment. The court of appeal upheld the City’s approval of the project. The Supreme Court reversed, holding that the City abused its discretion in interpreting its 2010 General Plan to permit residential development on the property. View "Orange Citizens for Parks & Recreation v. Superior Court of Orange County" on Justia Law

The City of San Diego adopted an ordinance imposing a tax on visitors for occupancy in hotels located within the City. The tax, known as the transient occupancy tax, is calculated as a percentage of the “rent charged by the operator” of the hotel. The City of San Diego issued transient occupancy tax assessments against online travel companies (OTCs) on the basis that the OTCs were liable as the “operator” of every hotel. The OTCs appealed. A hearing officer found that the OTCs owed tax on the amount retained by the OTCs above the amount remitted to the hotels as the agreed wholesale cost of the room rental. The superior court vacated the decision, concluding that OTCs are not operators of the hotels and that the markup the OTCs charge for their services is not part of the rent subject to the tax. The court of appeal affirmed. The Supreme Court affirmed, holding (1) under the ordinance, the operator of a hotel is liable for tax on the wholesale cost plus any additional amount for room rental the operator requires the OTC to charge the visitor under the “rate party” provisions of hotel-OTC contracts; but (2) OTCs are not operators within the meaning of the ordinance. View "In re Transient Occupancy Tax Cases" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, two counts of assault by a life prisoner with malice aforethought, and one count of custodial possession of a weapon. The jury returned a verdict of death following a penalty trial. The trial court sentenced Defendant to death. The Supreme Court struck the one-year enhancement imposed on the assault by a life prisoner count for personal use of a deadly weapon and otherwise affirmed the judgment, holding (1) Defendant’s guilt phase claims were unavailing; and (2) under the circumstances of this case, imposition of the use of a deadly or dangerous weapon enhancement was barred on the assault by a life prisoner count, but the remainder of Defendant’s sentence was proper. View "People v. Landry" on Justia Law

After a jury trial, Defendant was convicted of first degree murder under the special circumstance of murder in the commission of robbery, attempted premeditated murder, and first degree residential robbery. The jury found true personal firearm-use allegations. The jury returned a verdict of death after a penalty trial, and the trial court imposed a judgment of death. The Supreme Court affirmed, holding (1) substantial evidence supported the trial court’s determination that the prosecutor’s stated reasons as to the exercise of peremptory challenges against three African-American prospective jurors were genuine and race neutral; (2) the trial court did not abuse its discretion in its evidentiary rulings; and (3) there was no reason to reconsider previous holdings regarding challenges to California’s death penalty law. View "People v. Melendez" on Justia Law

Financial Casualty & Surety, Inc. posted a bail bond on behalf of Oscar Grijalva. The bail was subsequently forfeited. Under Cal. Penal Code 1305, the bond would be exonerated if Grijalva appeared in court by the 185th day after the notice was mailed. Five days after the appearance period ended, Financial Casualty moved to extend the period under section 1305.4. The trial court granted an extension for fewer than 180 days. At the end of the extension period, Financial Casualty filed a second extension motion. The trial court denied the second extension motion and entered summary judgment on the bond. The court of appeal affirmed. The Supreme Court affirmed, holding (1) a trial court may weigh the likelihood of apprehension in deciding whether the surety has shown good cause for an extension; (2) because at the time Financial Casualty’s second extension motion was heard fewer than 180 days had passed since the first extension was ordered, the trial court had discretion to grant a further extension; and (3) the trial court did not abuse its discretion in considering, as grounds for denying the extension of the period for exonerating the bail bond, that Financial Casualty had not shown the requests extension was likely to produce Grijalva’s appearance in court. View "People v. Financial Casualty & Surety, Inc." on Justia Law