Justia California Supreme Court Opinion Summaries

At issue in this criminal case was whether the prosecution’s obligation under Brady v. Maryland and its progeny would be satisfied if it simply informs the defense that the confidential personnel records of police officers might contain Brady material, which would allow the defense to decide for itself whether to seek discovery of that material pursuant to statutory procedures. The superior court denied the prosecution’s motion asking the court to review in camera the personnel records of two San Francisco police officers, potentially important witnesses in this criminal case, to determine whether they contained any material exculpatory information under Brady v. Maryland that was subject to disclosure. The Court of Appeal concluded that the prosecution may and, before the court becomes involved, should itself review the personnel files of peace officer witnesses for Brady material. The Supreme Court reversed, holding (1) the prosecution must follow the same procedures that apply to criminal defendants, i.e., make a Pitchess motion, in order to seek information in the confidential personnel records of police officers who are potential witnesses in criminal cases; and (2) the prosecution fulfills its Brady duty if it informs the defense of what the police department informed it, namely, that the specified records might contain exculpatory information. View "People v. Superior Court" on Justia Law

In two separate cases in 1998, Defendants were convicted of criminal offenses. The jury sentenced them under the Three Strikes Law. In 2012, the electorate passed Proposition 36, which authorizes prisoners serving third-strike sentences whose current offense is not a serious or violent felony to petition for recall of the sentence and for resentencing as a second-strike case. Defendants petitioned for recall of their sentences. In one case, the trial court denied the petition. The court of appeal affirmed, concluding that a prison whose current offense was a serious or violent offense on the effective date of Proposition 36 is not eligible for resentencing. In the second case, the trial court denied the petition on the ground that Defendant’s conviction for a serious felony rendered him ineligible for resentencing with respect to his conviction which was not serious or violent. The Supreme Court affirmed in both cases, holding (1) when a court resentences a third-strike defendant the classification of an offense as serious or violent is based on the law as of the effective date of Proposition 36; and (2) the presence of a current offense that is serious or violent does not disqualify an inmate from resentencing with respect to a current offense that is neither serious nor violent. View "People v. Johnson" on Justia Law

After a bench trial, Defendant was convicted of the first degree murders of three victims. A jury was sworn for the penalty phase and returned a verdict of death. The trial court sentenced Defendant to death for the three first degree murders with special circumstances. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no abuse of discretion in the use of physical restraints during Defendant’s transit through the hallways of the courthouse; (2) the trial court did not violate Defendant’s rights to due process and a fair trial when it excluded him from numerous pretrial proceedings and the guilt phase of his trial; (3) Defendant’s waiver of a guilt phase jury was knowing, intelligent, and voluntary; (4) Defense counsel provided effective assistance; (5) the trial court did not err in its evidentiary rulings; (6) there was no prejudicial error committed during jury selection; (7) the trial court did not err in denying Defendant’s automatic application for modification of the death verdict; (8) Defendant’s sentence was not disproportionate; and (9) Defendant’s challenges to the constitutionality of California’s death penalty scheme failed. View "People v. Cunningham" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder, sixteen counts of robbery, and three counts of assault with a deadly weapon, and related charges. The jury sentenced Defendant to death. Defendant appealed, arguing, among other things, that the trial court improperly excluded three prospective jurors based on their death penalty views. The Supreme Court (1) reversed the judgment of death and remanded the matter for a new penalty determination, holding that written and oral voir dire responses of the three excused panelists did not give the trial court sufficient information to conclude that they were incapable of performing their duties as capital jurors, and therefore, the record did not support the jurors’ dismissals; and (2) affirmed the judgment in all other respects. View "People v. Leon" on Justia Law

Defendant was convicted of three first degree murders and of conspiracy to participate in a criminal street gang and to commit murder and assault with a deadly weapon. The jury found true several enhancements. Defendant was sentenced to 100 years to life in prison. Before trial, Defendant moved to exclude his admissions of gang membership during booking and classification interviews at a county jail, asserting a Miranda violation. The trial court held that Defendant’s statements about his gang membership were admissible under Miranda’s booking exception. The Supreme Court affirmed, holding (1) the questions posed to Defendant while he was being processed into jail exceeded the scope of the booking exception, and while the officers were permitted to ask these questions for institutional security purposes, Defendant’s un-Mirandized responses were inadmissible against him during the case-in-chief; but (2) the erroneous admission of Defendant’s challenged statements was harmless beyond a reasonable doubt because Defendant’s gang affiliation was amply established by independent and uncontradicted evidence. View "People v. Elizalde" on Justia Law

At issue in this case were devices that resemble traditional casino-style slot machines in certain respects and offer users the chance to win sweepstakes prizes. The five Defendants in this ran businesses using devices that employed modern technology to run sweepstakes computer games. The Kern County District Attorney’s Office filed separate civil actions against each of the Defendants, alleging that Defendants had violated antigambling provisions of the Penal Code in operating their businesses and seeking injunctive and other relief. The superior court granted preliminary injunctions prohibiting each defendant from operating any business that includes any type of “sweepstakes,” “slot machines,” or “lottery” feature. The Court of Appeal affirmed, concluding that the sweepstakes operations were illegal slot machines. The Supreme Court affirmed, holding that Defendants’ devices were unlawful slot machines under Cal. Penal Code 330b. View "People ex rel. Green v. Grewal" on Justia Law

After a jury trial in 1989, David Welch was found guilty of six counts of first degree murder and two counts of attempted murder. The trial court sentenced Welch to death. The Supreme Court affirmed on appeal. Welch later filed a habeas corpus petition, alleging, among other claims, juror misconduct and ineffective assistance of counsel at the penalty phase. The Supreme Court issued to the Director of the Department of Corrections an order to show cause why it should not grant Welch relief on his jury misconduct and ineffective assistance of counsel claims. An appointed referee conducted an evidentiary reference hearing and filed a report with recommendations. The Supreme Court then discharged the order to show cause, holding that Defendant failed to establish that he was entitled to habeas corpus relief on his claims of juror misconduct and ineffective assistance of trial counsel for not investigating and presenting certain mitigating evidence at the penalty phase of his capital trial. View "In re Welch" on Justia Law

At issue in this case was whether Cal. Penal Code 1170.1(f) precludes a trial court from imposing both a firearm enhancement under Cal. Penal Code 12022.5, former subdivision (a)(1), and a gang enhancement under Cal. Penal Code 186.22(b)(1)(B), in connection with a single offense, when the offense is a “serious felony” under section 186.22(b)(1)(B) and involved the use of a firearm. Defendants Eric Hung Le and Down George Yang were convicted for their part of a street gang’s drive-by shooting. As to Defendant Yang’s conviction for assault with a semiautomatic firearm, the jury found true that Defendant committed the assault while personally using a firearm under former section 12022.5(a)(1) and committed the assault for the benefit of a street gang under section 186.22(b)(1).The trial court stayed any sentence enhancement under section 12022.5(a), concluding that it could not impose terms for both enhancements. The Court of Appeal affirmed. The Supreme Court affirmed, holding that because both enhancements depend upon a defendant’s firearm use, section 1170.1(f) bars the imposition of both enhancements. View "People v. Le" on Justia Law

In 2010, the City of San Jose enacted an inclusionary housing ordinance that requires all new residential development projects of twenty or more units to sell at least fifteen percent of the for-sale units at a price affordable to low or moderate income households. California Building Industry Association (CBIA) filed this lawsuit, arguing that the San Jose ordinance was invalid on its face because the conditions imposed by the ordinance constituted “exactions” under the takings clauses of the state and federal Constitutions. The superior court agreed with CBIA and enjoined the City from enforcing the ordinance. The Court of Appeal reversed, concluding that the superior court erred in interpreting the controlling constitutional principles and the decision in San Remo Hotel v. City and County of San Francisco as limiting the conditions that may be imposed by such an ordinance to only those conditions that are reasonably related to the adverse impact the development projects that are subject to the ordinance themselves impose on the City’s affordable housing problem. The Supreme Court affirmed, holding that the conditions that the San Jose ordinance imposes on future developments do not impose “exactions” upon the developers’ property. View "Cal. Bldg. Indus. Ass’n v. City of San Jose" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, rape, and sodomy. Defendant also pleaded guilty to charges arising from separate burglaries committed after the charged murder. The trial court sentenced him to death. Defendant appealed, arguing, among other things, that the prosecutor violated Batson v. Kentucky and People v. Wheeler by peremptorily excusing two African American prospective jurors. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court correctly concluded that Defendant failed to make out a prima facie case of discrimination as to either strike; (2) the trial court did not abuse its discretion in denying Defendant’s pretrial motion to sever the homicide charges from the burglary charges; and (3) any remaining errors or assumed errors were not prejudicial. View "People v. Scott" on Justia Law