Justia California Supreme Court Opinion Summaries

Defendant pleaded no contest to second degree burglary and having served a prior prison term for vehicle theft. Defendant was sentenced to probation on conditions including a year in jail and a condition that he not enter the premises or adjacent parking lot of any Home Depot store in California. The appellate court struck the challenged probation condition, concluding that the condition was unconstitutionally overbroad. The court also suggested that the condition violated Defendant’s constitutional right to travel. The Supreme Court reversed, holding (1) the probation condition at issue was reasonably related to Defendant’s crime and to preventing future criminality, rendering it permissible under state law; and (2) the condition did not implicate Defendant’s right to travel and thus was constitutionally permissible. View "People v. Moran" on Justia Law

California’s anti-SLAPP statute provides that a cause of action against a person arising from allegations of certain activity shall be subject to a special motion to strike unless the court determines there is a probability that the plaintiffs will prevail on the claim. At issue here was how a special motion to strike operates against a “mixed caused of action” that combines allegations of activity unprotected by the statute with allegations of protected activity. Plaintiff filed a second amended complaint pleading four causes of action against Defendant. Defendant filed an anti-SLAPP motion seeking to strike allegations within a certain cause of action. The trial court denied the motion without deciding whether the complaint contained allegations of protected activity, ruling that the motion applied to the complaint as a whole, not to isolated allegations. The court of appeal affirmed, concluding (1) an anti-SLAPP motion must be brought against a mixed cause of action in its entirety; and (2) Plaintiff established a probability of succeeding on claims based on allegations of activity not protected by the anti-SLAPP statute. The Supreme Court reversed, holding that the Legislature’s choice of the term “motion to strike” reflects the understanding that an anti-SLAPP motion may be used to attack parts of a count as pleaded. View "Baral v. Schnitt" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, first degree burglary, and first degree robbery. The jury was unable to reach a penalty verdict, and after the penalty phase was retried with a new jury, the trial court sentenced Defendant to death for the murder conviction and to 212 years to life on the remaining counts. The Supreme Court remanded the case to the trial court to recalculate the noncapital portion of Defendant’s sentence but affirmed the judgment in all other respects, holding (1) there was no prejudicial error in the trial court’s pretrial rulings; (2) the trial court erred in imposing consecutive sentences for certain sex crimes because they were committed against a single victim on a single occasion; and (3) no other prejudicial error occurred during the guilt phase and penalty phase of trial. View "People v. Jackson" on Justia Law

When Plaintiff was hired by Defendants, he signed multiple arbitration agreements as a condition of employment. Plaintiff later sued Defendant, alleging racial discrimination, harassment, and retaliation. The complaint sought to bring claims on behalf of a “class of current and former employees of color.” Defendants filed a motion to compel individual arbitration based on the arbitration agreements. The trial court granted the motion but struck the class allegations, concluding that the agreements did not permit class arbitration. The court of appeal reversed in part, ruling (1) the trial court erred in concluding that existing precedent compelled the court to determine whether class arbitration was available; and (2) the availability of class proceedings under an arbitration agreement is for an arbitrator to decide in the first instance. The Supreme Court affirmed, holding (1) there is no universal rule allocating the decision of whether an arbitration agreement permits or prohibits classwide arbitration to a court or an arbitrator, but rather, who decides is in the first instance a matter of agreement with the parties’ agreement subject to interpretation under state contract law; and (2) under state law, the arbitration agreement in this case allocates the decision to the arbitrator. View "Sandquist v. Lebo Automotive, Inc." on Justia Law

Defendant was charged with the unlawful taking of a vehicle and receiving stolen property. The complaint also contained a gang enhancement allegation under Cal. Penal Code 186.22(b) that exposed Defendant to up to an additional four years in prison. Defendant pleaded guilty to the charges, and the trial court accepted the defense invitation to dismiss the gang enhancement allegation under Cal. Penal Code 1385(a). The District Attorney appealed, arguing that, by enacting section 186.22(g), the Legislature intended to eliminate a trial court’s section 1385(a) discretion to dismiss or strike entirely a section 186.22(b) gang enhancement. Because the trial court failed to state its reasons for the gang enhancement dismissal, the Court of Appeal remanded the case to allow the trial court to do so, and otherwise affirmed the trial court’s judgment. The Supreme Court affirmed, holding (1) a trial court has the discretion under section 1385(a) to strike entirely a sentencing enhancement under section 186.22(b)(1) for a gang-related offense; and (2) because the trial court orally statement its reasons for dismissing the gang enhancement on the record, no remand was required. View "People v. Fuentes" on Justia Law

The California Department of Water Resources (Department) sought to conduct environmental and geological studies and testing on over 150 privately-owned parcels of property that the state, in the future, might seek to acquire. Proceeding through the procedure established by the California Eminent Domain Law relating to precondemnation entry and testing, the Department sought a court order granting it authority to enter the properties to undertake environmental and geological testing activities. The trial court authorized the Department to enter the private properties and conduct environmental activities but denied the Department’s request to conduct geological testing. The Court of Appeal affirmed the trial court’s denial of the Department’s proposed geological testing and reversed the trial court’s authorization of environmental testing, concluding that the procedure established by the precondemnation entry and testing statutes did not satisfy the demands of the California Constitution’s takings clause with regard to both the geological and environmental testing sought by the Department. The Supreme Court reversed, holding that, assuming, without deciding, that the environmental and geological activities amount to a taking or damaging of property, the procedure established by the precondemnation entry and testing statutes satisfies the requirements of the California takings clause when the procedure is reformed to comply with the jury trial requirement of that clause. View "Property Reserve, Inc. v. Superior Court" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first degree murder and one count of second degree murder with the personal use of a firearm, among other crimes. A mistrial was declared after the first penalty trial. After a second penalty trial, the jury fixed the penalty as death. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding that there was no prejudicial error during the guilt phase of trial or the penalty phase of trial, and Defendant’s challenges to California’s death penalty scheme were unavailing. View "People v. Simon" on Justia Law

This was an appeal from a child dependency proceeding involving two minors. The children were eligible for tribal membership but were not Indian children as defined in the Indian Child Welfare Act (ICWA). Rule 5.482(c) of the California Rules of Court requires a juvenile court in this scenario to “proceed as if the child is an Indian child” and to take steps “to secure tribal membership for the child.” The juvenile court in this case directed the Department of Health and Human Services to make efforts to secure tribal membership for the children. While the applications were pending, the court proceeded as if ICWA applied, held a hearing, and adjudged the children to be dependents of the court and ordered them placed with their maternal grandmother. The Court of Appeal reversed, concluding that Rule 5.482(c) conflicted with state law. The Supreme Court reversed the judgment of the Court of Appeal to the extent it held that related Rule 5.484(c)(2) was invalid and affirmed in all other respects, holding (1) Rule 5.482(c) is invalid because it conflicts with the Legislature’s intent to enforce ICWA by codifying its provisions, including the federal definition of Indian child; and (2) Rule 5.484(c)(2) is consistent with state law and valid. View "In re Abbigail A." on Justia Law

After a jury trial, Defendant was convicted of first degree murder and robbery. The jury returned a verdict of death following the penalty phase trial. The Supreme Court reversed the death judgment but otherwise affirmed, holding (1) the evidence was sufficient to support the convictions; (2) the trial court did not err in denying Defendant’s request to subpoena Defendant’s brother, who was originally charged together with Defendant; (3) the trial court did not err in excluding a segment from Defendant’s brother’s videotaped interview; (4) the prosecution did not violate its statutory or constitutional discovery violations; (5) the trial court did not err in instructing the jury, and even if error occurred, the error was not prejudicial; (6) the trial court did not err in failing to suppress Defendant’s statements to police; (7) the trial court did not err by failing to discharge a certain juror at the guilt phase; but (8) there was error in the death-qualification of the jury. View "People v. Zaragoza" on Justia Law

Defendant was charged with a number of criminal violations. Defendant was represented by seven different appointed counsel over the course of approximately two years and made repeated requests for continuances. When his trial finally commenced, Defendant moved to dismiss his public defender and represent himself pursuant to Faretta v. California. The trial court granted the request but did not grant Defendant’s motion for a one-day continuance. Defendant failed to appear in court for the next day of trial. The trial court chose not to revoke Defendant’s status as his own counsel and did not reappoint counsel to represent him. The court then proceeded with the trial in Defendant’s absence. The jury convicted Defendant of some of the charges. The Court of Appeal reversed, concluding that the trial court erred by proceeding with trial in Defendant’s absence and without the reappointment of defense counsel and abused its discretion by denying Defendant’s motion for a one-day continuance. The Supreme Court reversed, holding that the trial court (1) acted within its discretion in proceeding with the trial after Defendant waived his constitutional right to counsel and his constitutional right to be present; and (2) did not abuse its discretion in denying Defendant’s request for a one-day continuance. View "People v. Espinoza" on Justia Law