Justia California Supreme Court Opinion Summaries

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

Plaintiff was convicted of nonforcible oral copulation by an adult over twenty-one years with a person under sixteen years of age in violation of Cal. Penal Code 288a(b)(2). Plaintiff’s conviction resulted in mandatory sex offender registration under Cal. Penal Code 290. The Supreme Court subsequently issued its decision in People v. Hofsheier, which found an equal protection violation in section 290’s mandatory registration provision for a different subdivision of section 288a. Citing Hofsheier and its progeny, Plaintiff filed a petition for a writ of mandate in the superior court seeking his removal from the sex offender registry and relief from future registration obligations. The superior court denied the petition in reliance on People v. Manchel, a case that had rejected a Hofsheier claim by a defendant convicted of the same felony oral copulation offense at issue in this case. The Court of Appeal reversed, concluding that section 290’s registration requirement violated Plaintiff’s equal protection rights. The Supreme Court reversed, holding that Hofsheier’s constitutional analysis was faulty and therefore, Hofsheier is overruled. View "Johnson v. Dep’t of Justice" on Justia Law

An Employee was terminated for engaging in outside employment in violation of company policy during his absence on approved medical leave. The Employee sued, arguing that the Employer violated his right to reinstatement under the Moore-Brown-Roberti Family Rights Act (CFRA) and the federal Family and Medical Leave Act. The trial court granted the Employer’s motion to compel arbitration. The arbitrator relied on the federal “honest belief” defense and rejected Plaintiff’s contentions. The Court of Appeals vacated the award in the Employer’s favor, concluding that the arbitrator violated Plaintiff’s right to reinstatement under the CFRA when he applied the honest belief defense to Plaintiff’s claim. The Supreme Court reversed, holding that, although the arbitrator may have committed error in adopting the honest belief defense, any error did not deprive the Employee of an unwaivable statutory right because the arbitrator relied on the substantial evidence that the Employee violated his Employer’s written policy prohibiting outside employment while he was on medical leave. View "Richey v. Autonation, Inc." on Justia Law

After a jury trial, Defendant was convicted of one count of corporal injury on a spouse. The trial court placed Defendant on probation and, without objection, imposed various fees, including probation-related costs and an order for reimbursement of the fees paid to appointed trial counsel. On appeal, Defendant challenged the fees on the grounds that the trial court imposed the fees without making a finding of his ability to pay and that he was not advised of and did not waive his right to a court hearing on the probation supervision fee. The Supreme Court affirmed, holding (1) as established in the companion case of People v. Trujillo, the appellate forfeiture rule applies to challenges to fees imposed at sentencing; and (2) Defendant’s failure to object to the fees in the trial court precluded him from challenging the fees on appeal. View "People v. Aguilar" on Justia Law

After a jury trial, Defendant was found guilty of buying, receiving, concealing, or withholding stolen property. The trial court placed Defendant on probation and imposed probation supervision and presentence investigation fees. At trial, Defendant neither objected to the fees nor asserted an inability to pay them. The Court of Appeal reversed the order of payment and remanded with directions that the trial court follow the procedure prescribed in Cal. Penal Code 1203.1(b), which prescribes specific procedures for imposition of such fees. The Supreme Court reversed, holding (1) the appellate forfeiture rule applies in the context of an order that a defendant pay probation supervision and presentence investigation fees imposed under section 1203.1(b); and (2) Defendant, by her failure to object, was precluded from raising on appeal the issue of ability to pay the probation-related fees. View "People v. Trujillo" on Justia Law

Security guards employed by CPS Security Solutions, Inc. filed two class action lawsuits - which were later consolidated - alleging that CPS’s on-call compensation policy violated minimum wage and overtime obligations imposed by the applicable Industrial Welfare Commission (IWC) wage order and Labor Code statutes. Specifically, Plaintiffs challenged CPS’s policy of failing to compensate the guards for on-call time unless they were required to conduct an investigation. The trial court granted Plaintiffs’ motion for summary adjudication of the declaratory relief complaints, concluding that CPS’s compensation policy violated Wage Order 4. The Court of Appeal affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs’ on-call hours constituted compensable hours worked within the meaning of Wage Order 4 and were subject to the wage order’s minimum wage and overtime provisions; and (2) CPS could not exclude “sleep time” from Plaintiff’s twenty-four-hour shifts. View "Mendiola v. CPS Sec. Solutions" on Justia Law

Petitioner was found not guilty by reason of insanity of killing his father in 1981. Petitioner was committed to state hospital for a period reflecting the maximum term for voluntary manslaughter. In 2012, the district attorney petitioned to extend Petitioner’s commitment under Cal. Pen. Code 1026.5, which allows the commitment of a person found not guilty of a felony by reason of insanity to be extended for longer than the maximum prison sentence for the offense if, because of a mental disorder, the person represents a substantial danger to others. Petitioner filed a motion in limine to preclude his compelled testimony as a witness for the People. The trial court denied the motion. The Court of Appeal granted Petitioner’s petition for writ of mandate, concluding that section 1026.5(b)(7) unambiguously provided commitment extension respondents the right not to testify. The Supreme Court affirmed, holding that a person facing extended commitment has the right to testify at his or her not guilty by reason of insanity commitment extension hearing. View "Hudec v. Superior Court" on Justia Law