Justia California Supreme Court Opinion Summaries

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

In 2008, Brandon Clark fell ten feet while working as a carpenter for Employer. Clark’s workers’ compensation doctor prescribed various drugs to treat Clark’s injuries, and Clark’s personal doctor prescribed additional drugs. In 2009, Clark died from the “combined toxic effects of the four sedating drugs detected in his blood with associated early pneumonia.” Clark’s family sought workers’ compensation death benefits, arguing that the medications Clark was prescribed for his work-related injuries caused his death. The workers’ compensation judge awarded death benefits to the family. The Court of appeal reversed, concluding that there was insufficient evidence that the drugs Clark was prescribed for his work injuries contributed to his death. The Supreme Court reversed, holding (1) the Court of Appeal wrongly applied a higher proximate cause standard to this wrongful death case than the Legislature intended; and (2) substantial evidence supported the WCJ’s finding that two drugs, prescribed by the workers’ compensation doctor for Clark’s industrial injury, contributed to his death. View "South Coast Framing v. Workers’ Comp. Appeals Bd." on Justia Law

Defendant was charged with felony infliction of corporal injury in violation of Cal. Penal Code 273.5(a). The information further alleged that Defendant had suffered a prior conviction under section 273.5. At trial, Defendant stipulated to the prior conviction. The trial court accepted stipulation without advising Defendant of any trial rights or eliciting his waiver of those rights. A jury subsequently convicted Defendant of violating section 273.5(a) and found true the allegation that Defendant suffered a prior conviction. In light of the prior conviction, the trial court sentenced Defendant to a maximum term of five years. Defendant appealed, arguing that his stipulation to the prior conviction was invalid because it had the direct consequence of subjecting him to a longer prison term. The Court of Appeal affirmed the sentence. The Supreme Court reversed in part, holding that Defendant’s stipulation must be set aside, as (1) Defendant was entitled to be advised of his right to a fair determination of the truth of the prior conviction allegation; and (2) because the record did not affirmatively show that Defendant was aware of his right to a fair determination of the truth of the prior conviction allegation, Defendant’s stipulation must be set aside. View "People v. Cross" on Justia Law

The District Attorney filed a petition to declare sixteen-year-old R.V. (“Minor”) a ward of the juvenile court. When the juvenile court determined there was substantial evidence raising a doubt regrading Minor’s competency to stand trial, the court suspended proceedings and appointed a forensic psychologist to evaluate Minor. The expert’s report concluded that Minor was not competent to stand trial. The court rejected the expert’s opinion and concluded that Minor was competent to stand trial. The Court of Appeal affirmed, concluding that the juvenile court’s reasons for declining to accept the expert’s opinion were supported by substantial evidence in the record. The Supreme Court reversed, holding (1) under Cal. Welf. & Inst. Code 709, a minor is presumed competent and bears the burden of proving otherwise by a preponderance of the evidence; (2) a claim of insufficient evidence to support a juvenile court’s determination in a competency proceeding is reviewed deferentially under the substantial evidence test; and (3) the juvenile court under the circumstances could not reasonably have rejected the qualified expert’s opinion that Minor was not competent to proceed to trial. View "In re R.V." on Justia Law

Bayer AG and Bayer Corporation (collectively, Bayer) marketed Cipro, an antibiotic. In 1987, Bayer was issued a United States patent on the active ingredient in Cipro. Twelve years before the expiration of the patent, Barr Laboratories, Inc. filed an application to market a generic version of Cipro. Bayer responded with a patent infringement suit, and Barr counterclaimed for a declaratory judgment that the patent was invalid. In 1997, Bayer and Barr entered into a settlement agreement under which Bayer agreed to make a “reverse payment” to Barr in exchange for Barr dropping its patent challenge and consenting to stay out of the market. The settlement produced numerous state and federal antitrust suits. This case arose from nine such coordinated class action suits brought by indirect purchasers of Cipro in California. The complaint alleged that the Bayer-Barr reverse payment settlement violated the Cartwright Act, unfair competition law, an common law prohibition against monopolies. The trial court granted summary judgment for Bayer and Barr. The Court of Appeal affirmed. The Supreme Court reversed, holding that parties illegally restrain trade when they privately agree to substitute consensual monopoly in place of potential competition that would have followed a finding of invalidity or noninfringement. View "In re Cipro Cases I & II" on Justia Law

Plaintiff, a firefighter, sued Defendant, his employer, alleging disability discrimination in violation of the California Fair Employment and Housing Act (FEHA). The trial court granted summary judgment in favor of Defendant. Without making any finding that Plaintiff’s action was frivolous, unreasonable, or groundless, the trial court awarded Defendant its court costs. The court of appeal affirmed. The Supreme Court reversed, holding (1) Cal. Gov’t Code 12965(b) governs cost awards in FEHA actions, allowing trial courts discretion in awards of both attorney fees and costs to prevailing FEHA parties; and (2) the standard set forth in Christiansburg Garment Co. v. EEOC applies to discretionary awards of both attorney fees and costs to prevailing FEHA parties under section 12965(b), but a prevailing defendant should not be awarded fees or costs unless the plaintiff brought or continued litigating the action without an objective basis for believing it had potential merit. View "Williams v. Chino Valley Indep. Fire Dist." on Justia Law

After a jury trial, Defendant was convicted of the first degree murders of Mary Kopatz and Carley Kopatz. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress evidence of his videotaped interview with the police; (2) the trial court did not err in admitting a deceased witness’s prior consistent statement; (3) the victim impact evidence was neither unduly prejudicial nor so inflammatory that it invited the jury to make its penalty determination on a purely irrational basis; (4) Defendant was not prejudiced by a multiple-murder special-circumstance instruction and attendant verdict forms; and (5) Defendant’s challenges to the death penalty law failed. View "People v. Kopatz" on Justia Law