Justia California Supreme Court Opinion Summaries

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

The juvenile court removed Isaiah W., a newborn, from the care of his parents and placed him in foster care. The court found the federal Indian Child Welfare Act (ICWA) inapplicable and did not order the Los Angeles County Department of Children and Family Services to notify any tribe or the Bureau of Indian Affairs. Mother did not appeal from the order placing Isaiah in foster care. More than one year later, the juvenile court terminated Mother’s parental rights. Mother appealed from the second order, arguing that the juvenile court erred by failing to order the Department to comply with ICWA’s notice requirements. The Court of Appeal denied relief. The Supreme Court reversed, holding (1) a parent may challenge a finding of ICWA’s inapplicability in the course of appealing from a subsequent order terminating parental rights, even if the parent did not raise such a challenge in an appeal from the initial order; and (2) in this case, the fact that Mother did not allege ICWA notice error in an appeal from the original dispositional order did not preclude her from raising the claim in this appeal. View "In re Isaiah W." on Justia Law

After a jury trial, Defendant was convicted of several firearm-related and gang-related offenses. Defendant appealed, arguing that the trial court erred by admitting case-specific statements related by the prosecution expert concerning Defendant’s gang membership. Specifically, Defendant argued that the admission of this evidence violated the federal confrontation clause because the declarants were not unavailable and he had not previously cross-examined them. The Supreme Court reversed the jury findings on the street gang enhancements, holding that the admission of the case-specific statements constituted inadmissible hearsay under California law, and the error was not harmless beyond a reasonable doubt. Remanded. View "People v. Sanchez" on Justia Law

Defendant was convicted of driving under the influence of alcohol and related offenses. The trial court sentenced Defendant under the Three Strikes law to an indeterminate term of twenty-five years to life. While Defendant’s appeal was pending, voters enacted the Three Strikes Reform Act of 2012, which amended the law to reduce the punishment prescribed for certain third strike defendants. The court of appeals subsequently affirmed. Defendant petitioned for rehearing, requesting that he be resentenced under the new sentencing provisions of the Three Strikes law. The court denied relief. Defendant appealed, arguing that he was entitled to automatic resentencing under the revised penalty provisions of the Act without a determination by the trial court as to whether that resentencing would pose “an unreasonable risk of danger to public safety.” The Supreme Court affirmed, holding that prisoners presently serving indeterminate life sentences imposed under the prior version of the Three Strikes law, including those with nonfinal judgments, may seek resentencing under the Act, but subject to judicial determination of whether resentencing would pose an unreasonable danger to the public. View "People v. Conley" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first degree murder. The jury found true five special-circumstance allegations, including that Defendant committed murder while engaged in the commission of a burglary and while in the attempted commission of a robbery. At a penalty phase retrial, the jury returned a verdict for death. The trial court sentenced Defendant to death. The Supreme Court vacated the burglary-murder and robbery-murder special-circumstance findings but otherwise affirmed the judgment in its entirety, holding (1) there was no prejudicial error in the selection of the jury; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) prosecutorial misconduct did not occur in this case; (4) the trial court did not err in instructing the jury during the guilt phase; (5) the evidence was insufficient to support the jury’s true findings as to two special-circumstances pertaining to one murder; (6) the evidence was sufficient to support the jury’s true findings as to the remaining special-circumstances allegations; and (7) there was no prejudicial error during the penalty phase of trial. View "People v. Clark" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, first degree burglary with use of a knife, and assault causing great bodily injury. Defendant appealed, arguing that the trial court violated his Sixth and Fourteenth Amendment rights by terminating his right to self-representation. The court’s rationale was that Defendant had been “dilatory” and had been “stalling.” The Supreme Court reversed, holding that the district court’s order was an abuse of discretion where the record was bereft of information to support the trial court’s revocation of Defendant’s pro per status, and thus, Faretta v. California and its progeny required reversal of the judgment. View "People v. Becerra" on Justia Law

Plaintiff, a metal foundry worker, alleged that he developed interstitial pulmonary fibrosis as the result of his exposure to fumes from molten metal and dust from plaster, sand, limestone, and marble. Plaintiff sought recovery from Defendants, the companies that supplied products for use in the foundry’s manufacturing process, alleging that Defendants’ products produced harmful fumes and dust that were a substantial cause of his illness. The trial court sustained Defendants’ demurrer without leave to amend, relying on the Court of Appeal decision in Maxton v. Western States Metals, which held that under the “component parts doctrine,” a supplier of materials was not liable for injuries suffered under circumstances similar to those in the present case. The Court of Appeal reversed after explicitly disagreeing with the analysis and conclusion in Maxton. The Supreme Court affirmed, holding that the component part doctrine was not applicable in this case, and therefore, the Court of Appeal did not err in concluding that the trial court’s dismissal of Plaintiffs’ action could not be upheld. Remanded for further proceedings. View "Ramos v. Brenntag Specialties, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, attempted murder, twenty-six counts of robbery, two counts of attempted robbery, five counts of assault with a deadly weapon, and two counts of assaults with a stun gun. The jury returned a verdict of death, and the trial court imposed a judgment of death. The Supreme Court reversed one robbery count, modified the determinate prison sentence accordingly, and otherwise affirmed, holding (1) no reversible error occurred in the selection of the jury; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) the evidence was insufficient as to one of the robberies; (4) the evidence was sufficient to support the attempted murder conviction; (5) Defendant’s claims of instructional error failed; (6) no prejudicial error occurred during the penalty phase of trial; and (7) Defendant’s challenges to California’s death penalty law failed. View "People v. Sanchez" on Justia Law

Penal Code section 424 applies to "[e]ach officer of this state, or of any county, city, town, or district of this state, and every other person charged with the receipt, safekeeping, transfer, or disbursement of public moneys." The court held that section 424 applies only to those public officers imbued with such responsibility over public moneys. In this case, the court concluded that the evidence was sufficient to support the jury's verdict finding defendant, who served as superintendent of the District, was charged with the "receipt, safekeeping, transfer, or disbursement" of public funds. The evidence demonstrated that defendant had explicit contractual responsibilities to oversee the "budget and business affairs" of the District, testimony that superintendents like defendant owe a duty to safeguard school district funds, and defendant‘s responsibility to ensure such public funds were spent in accordance with the law. Accordingly, the court reversed and remanded. View "People v. Hubbard" on Justia Law

Defendant pleaded guilty to felony possession of heroin and was sentenced to 16 months in prison. Defendant was given credit for time served, including conduct credits, of 220 days. Penal Code section 1170.18, subdivision (d), provides that a person who has been resentenced under the measure and given credit for time served “shall be subject to parole for one year following completion of his or her sentence, unless the court, in its discretion, as part of its resentencing order, releases the person from parole.” The court concluded that credit for time served does not reduce the parole period. When it voted on Proposition 47, the electorate was informed, and it intended, that a person who benefited from the new legislation by receiving a reduced sentence would be placed on parole for one year after completion of the reduced sentence, subject to the court's discretion to release the person from that parole. The court reversed and remanded for further proceedings. View "People v. Morales" on Justia Law