Justia California Supreme Court Opinion Summaries

Plaintiff filed a class action lawsuit against the City of Los Angeles challenging the validity of a certain tax and seeking a refund of taxes. In 2007, during discovery proceedings in the underlying litigation, the trial court determined that certain documents the City possessed were privileged under either the the attorney-client privilege or the privilege for attorney work product. In 2013, Plaintiff filed a request under the California Public Records Act seeking to obtain copies of documents relating to the tax at issue. The City’s administrative office, in response, inadvertently provided Plaintiff with some of the privileged documents. The City filed a motion for an order compelling the return of the privileged material. The trial court denied the motion, concluding that the production of the documents under the Public Records Act had waived any privilege. The Court of Appeal affirmed. The Supreme Court reversed, holding that Cal. Gov’t Code 6254.5, which generally provides that “disclosure” of a public record waives any privilege, applies to an intentional, not an inadvertent, disclosure. Remanded. View "Ardon v. City of Los Angeles" on Justia Law

Charges that Defendants committed attempted murder were twice dismissed. Thereafter, the People charged Defendants with conspiracy to commit murder based on the same underlying facts as the dismissed charges. At issue in this case was whether Cal. Penal Code 1387, which generally permits a felony charge to be dismissed and refiled once but not twice barred Defendants’ prosecution for conspiracy to commit murder. Defendants moved to dismiss the complaint under section 1387. The magistrate denied the motion. Defendants then filed a petition for writ of habeas corpus. The superior court granted the petition and dismissed the case. The Court of appeal reversed, concluding that conspiracy to commit murder is not the “same offense” as attempted murder under section 1387, and thus the statute did not bar prosecution for that crime. The Supreme Court reversed, holding that because the conspiracy to commit murder charges, as pleaded, contain all of the elements of the previously dismissed attempted murder charges, they are the same offenses as the previous charges under section 1387. View "People v. Juarez" on Justia Law

At issue in this case was whether a plaintiff who voluntarily dismisses an action after entering into a monetary settlement is a “prevailing party” for purposes of Cal. Civ. Proc. Code 1032(a)(4) and thus entitled to recover costs in an action or proceeding. After the parties in this case entered into a settlement, Plaintiff voluntarily dismissed two causes of action against Defendant. The trial court adjudged that Plaintiff recover nothing from Defendant. The court of appeal reversed, concluding that Plaintiff had obtained a “net monetary recovery” under section 1032(a)(4) and was therefore the prevailing party. The Supreme Court affirmed, holding (1) a dismissal pursuant to a monetary settlement is not a dismissal in the defendant’s “favor” as that term is used in section 1032(a)(4); and (2) a plaintiff that enters into a stipulated judgment to be paid money in exchange for a dismissal has obtained a “net monetary recovery” within the meaning of section 1032(a)(4), regardless of whether the judgment mentions the settlement. View "DeSaulles v. Cmty. Hosp. of the Monterey Peninsula" on Justia Law

Defendant entered a commercial store with the intent to commit a robbery inside. After accomplishing the robbery, Defendant took a store employee to a bathroom in the back of the business, bound her hands, and raped her. After a jury trial, Defendant was convicted of aggravated kidnapping, forcible rape, and two burglaries. The verdict reflected the jury’s determination that Defendant committed two burglaries first when he entered the store, and then when he entered the bathroom, with the intent to commit a felony inside each space. The court of appeal affirmed. The Supreme Court reversed the court of appeal’s judgment upholding Defendant’s two burglary convictions, holding that the fact that a defendant has committed two entries with felonious intent into a structure and a room within that structure does not, by itself, permit multiple burglary convictions. View "People v. Garcia" on Justia Law

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