Justia California Supreme Court Opinion Summaries

At issue in this case was the adequacy of an environment impact report certified by the California Department of Fish and Wildlife (DFW) for a land development in northwest Los Angeles County. Plaintiffs challenged DFW’s actions by a petition for writ of mandate, raising several claims under the California Environmental Quality Act. The superior court granted the petition. The Court of Appeal reversed. The Supreme Court reversed, holding (1) the environmental impact report did not validly determine that the development would not significantly impact the environment by its discharge of greenhouse gases; (2) the report’s mitigation measures adopted for protection of a freshwater fish, a fully protected species under the Fish and Game Code, constituted a prohibited taking of the fish under the Code; and (3) Plaintiffs exhausted their administrative remedies regarding certain claims of deficiency. Remanded. View "Ctr. for Biological Diversity v. Cal. Dep’t of Fish & Wildlife" on Justia Law

A private citizen called a 911 operator to report an incident of suspected child abuse during the child’s visit with his father. A deputy sheriff, who was dispatched to investigate the report, determined that the child was not a victim of child abuse. Neither the officer nor the Sheriff’s Department cross-reported the initial 911 report to the child welfare agency. Less than four weeks later, the child suffered extensive head injuries during a visit with his father. The child, through a guardian ad litem, sued the county and the deputy sheriff for failing to cross-report the initial child abuse allegations to the county child welfare agency, in violation of the Child Abuse and Neglect Reporting Act. The trial court granted summary judgment for Defendants. The Court of Appeal affirmed. The Supreme Court reversed in part and affirmed in part, holding (1) the Sheriff’s Department had a mandatory and ministerial duty to cross-report the child abuse allegations made to the 911 operator to the child welfare agency, and the failure to cross-report can support a finding of breach of a mandatory duty; but (2) the officer had no duty to report the child abuse allegations and her investigative findings to the child welfare agency. View "B.H. v. County of San Bernardino" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the delay in bringing charges against Defendant did not violate his due process rights; (2) the trial court did not commit prejudicial error in its evidentiary rulings during the guilt phase of trial; (3) the prosecutor did not commit misconduct during the guilt phase closing argument; (4) the trial court did not commit prejudicial error in its evidentiary rulings during the penalty phase of trial; (5) the trial court properly instructed the jury during the penalty phase; and (6) the remainder of Defendant’s claims have already been rejected by the Court. View "People v. Cordova" on Justia Law

At issue in this case was whether Cal. Labor Code 4458.2, which provides workers’ compensation benefits to certain peace officers injured in the line of duty, applies to both volunteer peace officers and to regularly sworn, salaried officers. While employed as a police officer by the City of Marysville, John Larkin sustained injuries in the course of duty. A workers’ compensation judge determined that Larkin was entitled to workers’ compensation benefits but not to the maximum indemnity levels available under section 4458.2 because section 4458.2 did not apply to regularly sworn, salaried officers like Larkin. The Workers’ Compensation Appeals Board denied Larkin’s petition for reconsideration. The Court of Appeal affirmed. The Supreme Court affirmed, holding that a review of the legislative history governing the relevant statutory provisions of section 4458.2 leads to the conclusion that the statute does not extend maximum disability indemnity levels to regularly sworn, salaried peace officers. View "Larkin v. Workers’ Comp. Appeals Bd." on Justia Law

After a jury trial, Defendant was convicted of violating Cal. Penal Code 451(b), which forbids arson of “an inhabited structure or inhabited property.” Specifically, the jury found Defendant guilty of “arson of an inhabited structure as charged.” The prosecution did not charge Defendant with arson of property, but the court instructed the jury on it. In accordance with the trial court’s instructions, the jury did not return a verdict on the lesser crimes, including arson of property. The Court of Appeal reversed, finding the evidence insufficient to sustain the conviction, which precludes retrial of that charge. The Supreme Court reversed, holding that, under the circumstances, the lesser offense of arson of property was prosecuted in a single proceeding along with the section 451(b) charge, and therefore, Cal. Penal Code 654, as interpreted in Kellett v. Superior Court, does not prohibit retrying Defendant for that lesser offense. View "People v. Goolsby" on Justia Law

Defendant was charged with attempted murder and assault with a firearm. The prosecution alleged that these offenses were committed for the benefit of a criminal street gang and were thus subject to a sentence enhancement under Cal. Penal Code 186.22(f). The jury convicted Defendant of the lesser included offense of attempted voluntary manslaughter and of assault with a firearm. The jury found true that Defendant committed the offenses for the benefit of a criminal street gang. The Court of Appeal sustained Defendant’s sentence enhancement under section 186.22. The Supreme Court reversed the judgment as to Defendant’s sentence, holding (1) section 186.22(f)’s definition of a “criminal street gang” - and, in particular, its requirement of an “ongoing organization, association, or group” - calls for evidence that an organizational or associational connection unites the group members; (2) where, as in this instance, the prosecution’s case positing the existence of a single criminal street gang turns on the existence of gang subsets, the prosecution must show some associational or organizational connection uniting those subsets and also that the gang those subsets comprise is the same gang the defendant sought to benefit; and (3) the decision below was not consistent with this standard. Remanded. View "People v. Prunty" on Justia Law

Defendants Orlando Gene Romero and Christopher Self were convicted of three counts of first-degree murder, four counts of premeditated attempted murder, and numerous other crimes. The trial court entered judgments of death. The Supreme Court (1) reversed Self’s conviction for the robbery of Albert Knoefler on the basis that the testimony of an accomplice that Self robbed Knoefler was not corroborated; (2) vacated five multiple-murder special-circumstance findings for each defendant, holding that the trial court erred in instructing the jury to make two multiple-murder special-circumstance findings as to each count of murder; and (3) otherwise affirmed the judgments, holding that no other prejudicial error occurred. View "People v. Romero" on Justia Law

After a jury trial, Defendant was convicted of attempted robbery and first degree murder, among other charges. The jury returned a verdict of death for the murder, and the trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion when it ordered the use of leg restraints during trial; (2) the trial court did not abuse its discretion in dismissing one juror during trial and another juror during deliberations; (3) the trial court did not err in instructing the jury; (4) the trial court’s responses to the jury’s requests for clarification regarding the law of conspiracy was not in error; (5) Defendant’s claim that the jury was coerced into reaching a verdict was without merit; (6) no prejudicial error occurred during the penalty phase; (7) Defendant’s challenge to California’s death penalty statute failed; and (8) Defendant’s claim that the trial court improperly imposed restitution without considering his ability to pay failed. View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. Defendant was sentenced to death for the murder. While this appeal was pending, the United States District Court for the Central District of California issued its opinion in Jones v. Chappell, which held that systemic delays in implementing the California death penalty law rendered it unconstitutional under the Eighth Amendment. The Supreme Court affirmed the guilt and penalty phase judgments in their entirety, holding (1) any evidentiary errors did not require reversal under either state law or federal law; (2) Defendant’s claim of judicial misconduct was forfeited for appeal; (3) certain of Defendant’s claims of prosecutorial misconduct during the guilt phase were forfeited, other prosecutorial misconduct claims were without merit, and while the prosecutor committed misconduct in other instances, the misconduct was harmless; (4) the jury instructions were not in error; (5) no prejudicial misconduct occurred during the penalty phase; (6) a Jones claim has not been proved here; and (7) Defendant’s constitutional challenges to California’s death penalty statute failed. View "People v. Seumanu" on Justia Law

The supervisor of Plaintiff, a firefighter, maintained a “daily log” regarding the employees he supervised. The daily log consisted of notes that memorialized the supervisor’s thoughts and observations of employees, which he used as a memory aid in preparing performance plans and reviews. Plaintiff and the Orange County Professional Firefighters Association filed suit seeking to require Defendants to comply with Cal. Gov't Code 3255 before including adverse comments in Plaintiff’s personnel files. Specifically at issue was whether section 3255, which gives a firefighter the right to review and respond to any negative comment entered into his or her personnel file “or any other file used for any personnel purposes by his or her employer,” gave Plaintiff the right to review and respond to negative comments in the supervisor’s daily log. The Court of Appeal concluded that section 3255 required that Plaintiff be given an opportunity to respond to the negative comments in the log before they were made known to the employer. The Supreme Court reversed, holding that because the log was not shared with or available to anyone other than the supervisor who wrote the log, it did not constitute a file “used for any personnel purposes by his or her employer,” and therefore, section 3255 did not apply. View "Poole v. Orange County Fire Auth." on Justia Law