Justia California Supreme Court Opinion Summaries

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

Under Cal. Code Civ. Proc. 580b, when an individual borrows money from a bank to buy a home and the bank forecloses on the home, the bank can collect proceeds from the foreclosure sale but may not obtain a deficiency judgment against the borrower. In this case, a Borrower arranged a short sale of her home and sold her home to a third party for an amount that fell short of her outstanding loan balance to a Bank. The Bank then demanded the balance remaining on the Borrower’s home. The Borrower brought this declaratory action, claiming that section 580b prohibited the Bank from collecting the deficiency. The trial court sustained the Bank’s demurrer. The court of appeals reversed, concluding that section 580b’s protections apply after a short sale, not just a foreclosure. The Supreme Court affirmed, holding that section 580b applies to short sales just as it does to foreclosure sales. View "Coker v. JPMorgan Chase Bank" on Justia Law

A grand jury returned an indictment against Defendant on charges of conspiracy to commit murder and active participation in a criminal street gang. The grand jury found reasonable cause to believe that Defendant came within the provisions of Cal. Welf. & Inst. Code 707(d)(4). Defendant initially pleaded not guilty but later demurred to the indictment, arguing that section 707(d)(4) requires a determination that a juvenile qualifies for prosecution in adult court, and because he was a juvenile at the time of the alleged offenses, the grand jury had no legal authority to inquire into the charged offenses. The trial court agreed with Defendant, allowed him to withdraw his plea, and sustained his demurrer. The court of appeal reversed. The Supreme Court affirmed, holding that section 707(d) allows prosecutors the option of filing charges against certain juveniles accused of specified offenses in criminal court by grand jury indictment. View "People v. Arroyo" on Justia Law

In 2014, the California Legislature sought to place on the general election ballot Proposition 49, a nonbinding advisory question that would have asked the electorate whether Congress should propose, and the Legislature ratify, a federal constitutional amendment overturning the U.S. Supreme Court’s decision in Citizens United v. Federal Election Commission. Petitioners filed an original emergency petition for writ of mandate in the Supreme Court seeking to prevent the Secretary of State from proceeding with placement of Proposition 49 on the November 2014 ballot. The Supreme Court issued an order to show cause and stayed the Secretary from taking further actions in connection with Proposition 49 until after a final decision, effectively removing the advisory question from the November 2014 ballot. Despite this case being moot, the Court resolved the merits of Proposition 49’s constitutionality. The Court denied the instant petition for a writ of mandate, holding that Proposition 49 is reasonably related to the Legislature’s authority to use advisory questions to inform the Legislature’s exercise of its powers under U.S. Const., art. V, and therefore, Proposition 49 is constitutional. View "Howard Jarvis Taxpayers Ass’n v. Padilla" on Justia Law

In 1974, the state of California joined the Multistate Tax Compact, which contained an apportionment formula and permitted a taxpayer election between the Compact’s formula and any other formula provided by state law. In 1993, the Legislature adopted a different apportionment formula by amending the Revenue and Taxation Code to provide that, notwithstanding the Compact’s provisions, the new apportionment formula “shall” apply. Between 1993 and 2005, six multistate corporations (Taxpayers) paid income tax calculated under the new formula but then sought a refund, contending that they remained entitled to elect between the new statutory formula and that contained in the Compact. The trial court concluded that the Legislature could, consistent with the Compact, eliminate the election provision. The court of appeal reversed. The Supreme Court reversed, holding that the Legislature may properly preclude a taxpayer from relying on the Compact’s election provision. View "Gillette Co. v. Franchise Tax Bd." on Justia Law

After a jury trial, Defendant was convicted of premeditated murder and attempted murder. The jury found that the murder was committed with the special circumstance that the victim was a peace officer engaged in the lawful performance of his duties and that it was committed by means of lying in wait for the purpose of preventing a lawful arrest. Defendant was sentenced to death. The Supreme Court reversed the special circumstance finding that Defendant committed the murder by means of lying in wait but otherwise affirmed, holding (1) Defendant was prejudiced by the trial court’s failure to sua sponte instruct on circumstantial evidence as it relates to the lying-in-wait special circumstance; and (2) no other prejudicial error occurred. View "People v. Sandoval" on Justia Law

In 2010, the Bar Area Air Quality Management District passed a resolution adopting new thresholds of significance for air pollutants and published new California Environmental Quality Act (CEQA) air quality guidelines. The California Building Industry Association (CBIA) filed a petition for writ of mandate challenging these thresholds. The superior court entered judgment in favor of CBIA, concluding that the District’s promulgation of the 2010 thresholds was a “project” subject to CEQA review, and the District was bound to evaluate the thresholds’ potential impact on the environment. The Court of Appeal reversed, concluding that the promulgation of the 2010 thresholds was not a project subject to CEQA review. The Supreme Court reversed, holding (1) CEQA does not generally require an agency to consider the effects of existing environmental conditions on a proposed project’s future users or residents except in specific instances; and (2) because the Court of Appeal’s analysis of CBIA’s petition for writ relief did not address potentially important arguments for and against such relief in light of CEQA’s requirements as interpreted in this opinion, this case is remanded so the court may have an opportunity to address those issues. View "Cal. Building Ind. Ass’n v. Bay Area Air Quality Mgmt. Dist." on Justia Law