Justia California Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of one count of first degree murder and two counts of second degree murder. There were four penalty trials in this case, and the fourth penalty trial jury returned a verdict of death. The trial court denied the automatic application to modify the verdict and sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted Defendant’s jailhouse letter under the adoptive admission exception to the hearsay rule; (2) prosecutorial misconduct did not require reversal of Defendant’s convictions and sentence; (3) the jury was properly instructed regarding motive, consciousness of guilt, and adoptive admissions; (4) the trial court did not abuse its discretion by granting the prosecution’s motion for a fourth penalty trial; (5) any error in the exclusion of testimony from Defendant’s relatives that his family did not wish to have the death penalty imposed on him was harmless; and (6) Defendant’s challenges to the death penalty failed. View "People v. Charles" on Justia Law

Before Gilton Pitre was paroled from state prison the State Department of Mental Health (DMH) assessed whether he should be civilly committed under the Sexually Violent Predators Act (SVPA). The DMH ultimately did not request a petition for commitment. Four days after Pitre was paroled, he raped and murdered Plaintiff’s fifteen-year-old sister. Plaintiff sued DMH and two of its acting directors (collectively, Defendants) claiming that her sister’s death was caused by Defendants’ failure to discharge a mandatory duty imposed by the SVPA. Defendants demurred, arguing that Plaintiff failed to state a cause of action and that they were immune from liability. The demurrer was overruled, and Defendants petitioned for a writ of mandate. The Court of Appeal directed the superior court to sustain the demurrer, concluding that the SVPA imposed a mandatory duty on Defendants but that Plaintiff could not establish that the breach of that duty was the proximate cause of her sister’s death. The Supreme Court affirmed, holding that the Court of Appeal did not err in its conclusions. View "State Dep’t of State Hosps. v. Superior Court" on Justia Law

After a jury trial in 1999, Defendant was convicted of first degree murder, second degree murder, and second degree robbery. Defendant stipulated to a 1971 prior second degree murder conviction alleged as a special circumstance. As to both murder counts, the jury found true the special-circumstance allegation of multiple murder. The trial court imposed a sentence of death that was supported by the multiple murder special-circumstance finding. The Supreme Court reversed the judgment of conviction for second degree murder and reversed the penalty judgment, holding (1) Defendant’s 1971 second degree murder conviction was obtained in violation of the double jeopardy clause, and therefore, this special-circumstance finding must be set aside; (2) the trial court erred by allowing the prosecution to refile the second degree murder charge, which had previously been dismissed; (3) the multiple murder special circumstance is vacated because it was based in part on the invalid second degree murder conviction; and (4) therefore, the judgment of death must be reversed. Remanded for resentencing. View "People v. Trujeque" on Justia Law

Defendant pleaded no contested in a negotiated disposition to felony hit and run. The plea agreement provided that Defendant would pay restitution directly to any victim. Defendant was later placed on probation and directed to pay fines and restitution in the amount of $12,465 for the victim’s medical expenses. The trial court reserved jurisdiction to determine the amount of additional restitution. The restitution hearing was continued several times, and Defendant’s term of probation eventually expired. The court determined that it had jurisdiction to order the full amount of restitution and confirmed that the restitution amount was $275,017. The Court of Appeal affirmed, holding that the trial court retained jurisdiction to award additional restitution without regard to the expiration of Defendant’s probation. The Supreme Court affirmed, holding that, by agreeing to a continuance of the restitution hearing to a date after his probationary term expired, Defendant impliedly consented to the trial court’s continued exercise of jurisdiction and was therefore estopped from challenging it. View "People v. Ford" on Justia Law