Justia California Supreme Court Opinion Summaries

This case arose from Plaintiff’s sale of property to Defendants. In November 2006, Plaintiff filed a complaint against Defendants alleging negligence, fraud, intentional infliction of emotional distress, and failure to follow home equity sales contract requirements. In May 2012, Fidelity National Title Insurance Company moved to dismiss the complaint for failure to bring the action to trial within the five-year time frame required by Cal. Code Civ. Proc. 583.310. The trial court dismissed the case in its entirety. In so doing, the trial court concluded that the time during which the court had vacated the trial date and ordered a 120-day stay of proceedings to permit the parties to engage in mediation did not support tolling. The court of appeal affirmed. The Supreme Court affirmed, holding that the trial court’s order did not effect a complete stay of the prosecute of the action, nor did it create a circumstance of impracticability, and therefore, the period of the “mediation stay” did not toll the five-year period. View "Gaines v. Fidelity Nat’l Title Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of the first degree murder of a correctional officer and conspiracy to commit murder and to commit assault on correctional staff. The jury found true the special circumstance allegation that the murder involved the knowing and intentional killing of a peace officer engaged in the performance of his duties. The trial court sentenced Defendant to death on the murder count and to life with the possibility of parole on the conspiracy count. The Supreme Court affirmed, holding that no prejudicial error occurred during either the guilt or penalty phases and that any alleged error regarding pretrial issues was harmless. View "People v. Masters" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder, one count of conspiracy to commit murder, and one count of robbery. After a penalty trial, the jury returned a verdict of death. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to sever the three murder counts; (2) Defendant’s claims of error regarding jury issues were unavailing; (3) no prejudicial error occurred during the guilt phase of trial; (4) no prejudicial error occurred during the penalty phase of trial; (5) the trial court did not err in denying Defendant’s motion for new trial; and (6) any actual or assumed errors did not, considered altogether, deprive Defendant of a fair trial. View "People v. O'Malley" on Justia Law

Plaintiff was a borrower on a home loan secured by a deed of trust. The deed of trust was assigned multiple times. After Plaintiff’s home was sold at public auction, Plaintiff filed this wrongful foreclosure action alleging that the assignment of the deed of trust to the foreclosing party bore defects rendering the assignment void. The court of appeals concluded that Plaintiff could not state a cause of action for wrongful foreclosure based on the allegedly void assignment because she lacked standing to assert improprieties in the assignment where, as an unrelated third party to that assignment, Plaintiff was unaffected by such deficiencies. The Supreme Court reversed, holding that a home loan borrower who has suffered a nonjudicial foreclosure has standing to sue for wrongful foreclosure based on an allegedly void assignment even though she was in default on the loan and was not a party to the challenged assignment because an allegation that the assignment was void will support an action for wrongful foreclosure. View "Yvanova v. New Century Mortgage Corp." on Justia Law

After a jury trial, Defendant was found guilty of three counts of first degree premeditated murder. The trial court sentenced Defendant to death for the multiple murders. The Supreme Court affirmed, holding (1) the jury’s verdict finding Defendant competent to stand trial was supported by substantial evidence; (2) the trial court’s failure to conduct additional competency hearings at various points during the proceedings did not constitute a violation of Defendant’s federal constitutional right to due process of law; (3) assuming the trial court erred in permitting evidentiary portions of the trial to proceed in his absence, the error was harmless; (4) the prosecutor did not commit misconduct during closing argument at the guilt phase of trial; (5) Defendant’s constitutional challenges to his sentence on the basis of evidence that he was mentally ill at the time of the offenses and at trial were unavailing; and (6) Defendant’s challenges to the constitutionality of the death qualification process in jury selection and to California’s death penalty scheme failed. View "People v. Mendoza" on Justia Law

Defendant was convicted of four counts of first degree murder and sentenced to death. The Supreme Court affirmed, holding (1) there was no prejudicial error committed during the guilt phase or the penalty phase of trial; (2) Defendant’s request that the Court take judicial notice of the decision of the Commission on Judicial Performance removing Judge Platt from judicial office two years after the completion of Defendant’s trial, as well as Judge Platt’s temporary suspension from the practice of law for the same underlying incidents, is denied, as Judge Platt’s removal from the bench and subsequent suspension are irrelevant to the proceedings against Defendant; (3) the prosecutor did not commit prejudicial misconduct in either phase of the trial; and (4) California’s death penalty statute is not unconstitutional. View "People v. Peoples" on Justia Law

After a jury trial, Defendant was convicted of murder and attempted premeditated murder, among other crimes. After a penalty phase, the jury returned a death verdict. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) as to issues arising during the guilt phase, (i) there was sufficient evidence to support the first degree murder conviction and the lying-in-wait special circumstance, (ii) the trial court did not err in its evidentiary rulings, and (iii) the instructions to the jury were proper; (2) as to issues arising during the penalty phase, (i) the trial court erred in admitting certain evidence, but the error was harmless, (ii) the admission of evidence of Defendant’s juvenile misconduct in aggravation was not error, (iii) the imposition of the death penalty based on a sole lying-in-wait special circumstance renders a defendant eligible for the death penalty, and (iv) California’s death penalty law is not unconstitutional. View "People v. Casares" on Justia Law

Elshaddai Bent was charged with felony drunk driving. His bail was set at $25,000, and the bail bond was executed by Safety National Casualty Company. When Bent failed to appear at a pretrial hearing the trial court ordered that his bail be forfeited. Safety National moved to vacate the bail forfeiture on the grounds that Bent was not ordered to appear at the hearing, nor was his presence at the hearing required by law. The trial court denied the motion. The Court of Appeal reversed, holding that Cal. Pen. Code 977(b)(1) did not provide a basis for Bent's mandatory appearance that the hearing. The Supreme Court reversed, holding that, unless a defendant fails to execute a written waiver of personal presence, or has a sufficient excuse for his or her absence at a scheduled pretrial proceeding, the trial court must declare any bail forfeited under section Cal. Pen. Code 1305(a). View "People v. Safety Nat’l Cas. Corp." on Justia Law

Monterey Peninsula Water Management District, a public agency, undertook work to mitigate environmental damage caused by California-American Water Co. (Cal-Am), a public utility, and then assessed a fee on the utility’s customers for the work. The fee was charged as a line item on Cal-Am’s bill and was collected by the Cal-Am on behalf of the District. In the underlying proceedings, Cal-Am filed an application with the Public Utilities Commission (PUC) for authorization to collect the District user’s fee. Before the PUC responded, Cal-Am, the District, and the PUC’s Division of Ratepayer Advocates entered into a settlement agreement under which the parties agreed that the District’s requested user fee was appropriate. The PUC denied Cal-Am’s application and rejected the settlement agreement. The Supreme Court set aside the PUC decisions rejecting Cal-Am’s application for authorization to collect the District’s user fee, holding that the PUC did not have the power to regulate the District’s user fee. View "Monterey Peninsula Water Mgmt. Dist. v. Pub. Utils. Comm’n" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, conspiracy to commit murder, and as an accessory after the fact. After a penalty phase trial, the jury returned a verdict of death. The Supreme Court affirmed the judgment, holding (1) sufficient evidence supported the first degree murder verdict based on the theory of lying in wait; (2) the lying-in-wait special circumstances satisfies the requirements of the Eighth Amendment; (3) the trial court did not err in instructing the jury; (4) the trial court did not err in allowing the prosecutor to present victim impact evidence relating to noncapital crimes; (5) Defendant forfeited his claim that the prosecutor committed misconduct during closing remarks at the penalty phase by addressing his argument to jurors individually; and (6) Defendant’s challenges to the constitutionality of California’s death penalty law were without merit. View "People v. Johnson" on Justia Law