Justia California Supreme Court Opinion Summaries

After four chemical tests were administered to Plaintiff revealing her blood-alcohol concentration to be between 0.08 to 0.096 percent, Plaintiff’s license was suspended, and she was charged with drunk driving. Plaintiff requested an administrative hearing. During the hearing, Plaintiff’s expert witness suggested her BAC was below the 0.08 percent threshold at the time Plaintiff was driving. The Department of Motor Vehicles, and later the trial court, discounted the expert testimony in part by relying on arrest reports, which described other circumstantial evidence of intoxication. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in rejecting the expert’s testimony and placing primary emphasis on the chemical tests showing that Plaintiff’s BAC met or exceeded the statutory threshold at the time she was driving; and (2) both the trial court and the DMV hearing officer reasonably relied on circumstantial evidence of Plaintiff’s intoxication to support the accuracy of the chemical tests and to reject the expert’s view of the evidence as unduly speculative. View "Coffey v. Shiomoto" on Justia Law

Defendant pleaded guilty to violating Cal. Ins. Code 11880(a) and admitted various enhancements. Defendant was sentenced to six years imprisonment. Approximately one and a half years into the sentence, the Secretary of the California Department of Corrections and Rehabilitation (CDCR) recommended that Defendant’s sentence be recalled pursuant to Cal. Penal Code 1170(e) and that he be granted compassionate release due to his medical condition. The trial court ultimately denied the CDCR’s recommendation to recall Defendant’s sentence, finding an insufficient basis for compassionate release under section 1170(e). The Court of Appeal dismissed Defendant’s appeal, finding that the trial court’s denial of the CDCR’s recommendation for compassionate release was a nonappealable order. The Supreme Court reversed, holding that Defendant’s appeal was authorized by Cal. Penal Code 1237(b). View "People v. Loper" on Justia Law

A homeowners association and some of its individual members (collectively, “Plaintiffs”) filed this suit against a homeowner alleging (1) their housing development tract, which included the homeowner’s property, was a common interest development within the meaning of the Davis-Sterling Common Interest Development Act (“CID Act”); and (2) pursuant to the CID Act, the homeowner violated valid applicable restrictions through his ongoing remodeling. The trial court rendered judgment in favor of Defendants, concluding that the tract did not constitute a common interest development. The court awarded awarded attorney fees to Defendants. The Court of Appeal (1) affirmed the judgment in favor of Defendants on the merits; but (2) reversed the award of attorney fees, concluding that because the courts had found the CID Act was not applicable, attorney fees were improperly awarded under former Cal. Civil Code 1354(c), a provision of the CID Act. The Supreme Court reversed the portion of the Court of Appeal’s judgment insofar as it reversed the attorney fee award, holding (1) the award of attorney fees was supported by the language of the statute; and (2) denying Defendants an award under the statute when they were the prevailing party would defeat the legislative intent underlying the statute. View "Tract 19051 Homeowners Ass’n v. Kemp" on Justia Law

The City of Berkeley approved a permit application to build a 6,478-square-foot house with an attached 3,394-square-foot garage. In approving the permit, the City relied on two class exemptions making the project exempt from the restrictions set forth in the California Environmental Quality Act (CEQA). The Court of Appeal invalidated the permit approval, concluding that the proposed project may have a significant environmental impact, and therefore, the exemptions the City invoked did not apply under the Guidelines for Implementation of CEQA section 15300.2(c). Section 15300.2(c) provides: “A categorical exemption shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances.” The Supreme Court reversed, holding (1) a proposed project’s potential significant effect on the environment is not alone sufficient to trigger the unusual circumstances exception; and (2) remand for application of the standards the Court announced today was necessary. View "Berkeley Hillside Preservation v. City of Berkeley" on Justia Law

Defendant engaged in conduct that led to a charge of committing a lewd act on a child. The jury convicted Defendant of the lesser misdemeanor offense of simple assault. The sentencing court exercised its discretion to order Defendant to register as a sex offender. The order included registered sex offender residency restrictions imposed by Jessica’s Law. The Court of Appeal struck the order from Defendant’s conviction, concluding that the registration order was invalid under Apprendi v. New Jersey because the trial judge and not a jury made the predicate factual findings. The Supreme Court reversed, holding that Apprendi did not invalidate Defendant’s registration order, as (1) the post-Apprendi decision, Oregon v. Ice, stated that Apprendi has no application to sentencing decisions in which juries played no fact-finding role at common law; (2) the residency restrictions do not constitute a penalty for purposes of Apprendi; and (3) even if the residency restrictions of Jessica’s Law did require jury findings under Apprendi, there is no reason why the nonpunitive registration order should not survive in this case. View "People v. Mosley" on Justia Law

Petitioners in this consolidated habeas corpus proceeding were registered sex offenders on active parole in San Diego County against whom Cal. Pen. Code 3003.5(b) was applied. Section 3003.5(b) imposed mandatory residency restrictions against paroled registered sex offenders. The trial court concluded that the mandatory residency restrictions were unconstitutional as applied to all registered sex offenders on parole in San Diego County and enjoined enforcement of the statute in the county. The Court of Appeal affirmed. The Supreme Court affirmed, holding (1) section 3003.5(b)’s residency restrictions are unconstitutional as applied to petitioners and similarly situated registered sex offenders on parole in San Diego County; but (2) as the lower courts made clear, the California Department of Corrections and Rehabilitation retains the statutory authority to impose special restrictions on registered sex offenders, including residency restrictions, so long as they are based on the specific circumstances of each individual parolee. View "In re Taylor" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, first degree burglary, first degree robbery, and carjacking. The jury returned a verdict of death, and the trial court imposed that sentence. The Supreme Court affirmed, holding (1) the trial judge’s failure to disqualify himself because of his relationship with the prosecutor did not violate Defendant’s constitutional rights; (2) the trial judge did not prejudicially err in denying Defendant’s motion to change venue; (3) the evidence was sufficient to support the carjacking conviction; (4) the trial court adequately instructed the jury regarding victim impact evidence; (5) the trial court did not err in its treatment of one of Defendant’s prior crimes; and (6) Defendant’s challenges to California’s death penalty law were without merit. View "People v. Johnson" on Justia Law

Under the Freeway Service Patrol (FSP) Act, motorists receive emergency roadside assistance on California’s highways. The FSP program is administered by, among other agencies, the Department of the California Highway Patrol (CHP). Local agencies then contract with privately owned tow services, which provide trucks dedicated to the FSP program. One local agency contracted with California Coach Orange, Inc. for FSP tow services and also contracted with CHP for field supervision and program management. Joshua Guzman, a California Coach FSP tow truck driver, hit a car on an interstate highway, injuring Plaintiff. Plaintiff sued CHP, among other defendants, seeking recovery on the theory that CHP was Guzman’s “special employer.” The trial court denied CHP’s motion for summary judgment. The Court of Appeal reversed, ruling that CHP cannot be the special employer of an FSP tow truck driver as a matter of law. The Supreme Court reversed, holding (1) the Court of Appeal erred by ruling that FSP statutes categorically bar CHP from acting as a special employer; and (2) the language of the statutory scheme does not support a finding that CHP is the special employer of FSP tow truck drivers, but this conclusion does not eliminate the possibility that CHP might act as a special employer in particular circumstances. View "State ex rel. Dep’t of Cal. Highway Patrol v. Superior Court" on Justia Law

The Center for Investigative Reporting filed a Public Records Act request for copies of all citations issued by the Department of Public Health (DPH) to the long-term health care facilities the Center was investigating. The DPH disclosed heavily redacted copies of the citations it had issued to the facilities, asserting that Cal. Welf. & Inst. Code 5328 obligated it not to release confidential information obtained in the course of providing services to mentally ill and developmentally disabled individuals. The trial court determined that the Long-Term Care, Health, Safety, and Security Act's mandate that DPH citations be made public with minimal redaction trumped section 5328’s confidentiality provisions. The Court of Appeal vacated the judgment of the trial court and ordered DPH to disclose such information as the Court of Appeal deemed consistent with the common purpose of both statutes while permitting DPH to redact such information as the court deemed inconsistent with that common purpose. The Supreme Court reversed and remanded with instructions for the Court of Appeal to deny the petition, holding that DPH citations issued under the Act are public records and must be disclosed to the Center subject only to the specific redactions mandated by the Act. View "State Dep’t of Pub. Health v. Superior Court" on Justia Law

Defendant was convicted of three counts of gross vehicular manslaughter, one count each for the three persons who died in the incident. The trial court enhanced Defendant’s sentence for “personally inflicting great bodily injury” on a fourth victim, who was injured in the accident but survived. The Court of Appeal upheld the enhancement as to the surviving victim but reversed the enhancements as to the manslaughter victims, concluding generally that Defendant’s manslaughter conviction was subject to any great bodily injury enhancement. The Supreme Court reversed, holding that the sentence for manslaughter may not be enhanced for the infliction of great bodily injury as to anyone. View "People v. Cook" on Justia Law