Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree murder, with the special circumstance of torture, false imprisonment by violence, and conspiracy to commit murder. The jury recommended a sentence of death, and the trial court imposed that sentence. The Supreme Court affirmed the convictions but reversed the penalty judgment, holding that, during the penalty phase, the court violated Defendant’s federal constitutional rights to due process by excluding expert testimony about prison security measures for those sentenced to life without possibility of parole because Defendant was deprived of the opportunity to counter aggravating evidence and argument suggesting that he would be a dangerous life prisoner. View "People v. Smith" on Justia Law

Defendant, a second-strike offender, was convicted of eleven offenses arising from sexual assaults on two separate victims. At issue in this appeal was the trial court’s imposition of an alternative sentence under the One Strike law. The court sentenced Defendant to twenty-five years to life for each of his two rape convictions then doubled the minimum terms for the life sentences pursuant to the Three Strikes Law and added five-year prior serious felony enhancements to both. On the remaining counts, the court imposed determinate terms of seventeen years each - the sum of the middle term of six years, doubled pursuant to the Three Strikes Law - plus a five-year prior serious felony enhancement. Defendant’s alternative sentence totaled 229 years to life, which the court stayed in light its sentence original of 495 years to life. The Supreme Court granted review to determine whether the prior serious felony enhancement may be applied to the term imposed for each offense or only once to the determinate portion of the overall sentence. The Supreme Court vacated Defendant’s stayed sentence of 229 years to life and remanded for resentencing, holding that the prior serious felony enhancement may be added only once to multiple determinate terms imposed as part of a second-strike sentence. View "People v. Sasser" on Justia Law

In 2000, California voters enacted Proposition 39, which provides that school districts must share their facilities with charter schools so that charter school students have access to facilities “reasonably equivalent” to facilities available to other public school students. Two years later, the State Board of Education issued regulations on how to implement this requirement. This action concerned the meaning of a Board regulation that governs the allocation of classrooms to charter schools. In allocating classrooms to charter schools, the Los Angeles Unified School District used “norming ratios,” which purported to establish throughout the District a uniform student/teacher ratio in a given grade level. The California Charter Schools Association (CCSA) sought declaratory relief, contending that the District violated the regulation governing the allocation of classrooms to charter schools by, inter alia, using these norming ratios rather than counting classrooms in comparison group schools to determine the allocation of classroom facilities. The Supreme Court agreed with CCSA and held that the District’s use of norming ratios, rather than counting classrooms in comparison group schools, violated the applicable regulation. In responding to future facilities requests, the District must count classrooms in a manner that conforms to the regulation. View "Cal. Charter Schs. Ass’n v. L.A. Unified Sch. Dist." on Justia Law

After a jury trial, Defendant was found guilty of one count of willful, deliberate, and premeditated attempted murder and three counts of threatening to commit a crime resulting in death or great bodily injury. During trial, the court admitted certain out-of-court statements made by Defendant that formed the basis of the prosecution for making criminal threats. Defendant appealed, arguing that the trial court erred by not instructing the jury to consider Defendant’s out-of-court statements with caution, despite Defendant’s failure to request such an instruction. The Court of Appeal affirmed, concluding that any error in omitting the instruction was harmless in light of other instructions the jury received and the evidence presented. The Supreme Court affirmed, holding (1) the cautionary instruction is applicable when the out-of-court statements at issue are criminal threats, and the trial court is not required to give such an instruction sua sponte; and (2) the omission of the cautionary instruction in this case was harmless. View "People v. Diaz" on Justia Law

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