Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of committing lewd acts on a child under the age of fourteen and one misdemeanor count of annoying or molesting a child under the age of eighteen. During trial, the prosecutor used a diagram showing the boundaries of California to illustrate the standard of proof and urged the jury to convict based on a “reasonable” view of the evidence. Defense counsel did not object to the prosecutor’s argument. The Supreme Court reversed, holding (1) there was a reasonable probability that the prosecutor’s argument caused one or more jurors to convict Defendant based on a lesser standard than proof beyond a reasonable doubt; and (2) defense counsel’s failure to object to the alleged prosecutorial misconduct violated Defendant’s constitutional right to the effective assistance of counsel. View "People v. Centeno" on Justia Law

The Riverside County Sheriff’s Department fired Deputy Kristy Drinkwater for falsifying her payroll forms. On administrative appeal, Drinkwater sought discovery of redacted records from personnel investigations of eleven other Department employees who were disciplined, but not fired, for similar acts of misconduct. The administrative hearing officer granted the motion. The Department sought a writ of administrative mandate, arguing that only judicial officers could grant Pitchess motions, which are discovery motions for officer personnel records. The superior court agreed and granted mandate. The Court of Appeal reversed. The Supreme Court affirmed, holding that when hearing an administrative appeal from discipline imposed on a correction officer, an arbitrator may rule upon a Pitchess motion. View "Riverside County Sheriff's Dep’t v. Stiglitz" on Justia Law

After a jury trial, Defendant, a member of a violent criminal street gang, was convicted of the murders of two of his fellow gang members even though he neither personally killed them nor desired their deaths. Defendant was convicted of the murders on the theory that he aided and abetted the persons who actually shot the victims in committing the target crimes of disturbing the peace and assault or battery and that the murders were “a natural and probable consequence” of the target crimes. The court of appeal affirmed the murder convictions. The Supreme Court affirmed, holding that, under the peculiar circumstances of this case, a reasonable jury could find that Defendant aided and abetted the target offenses and that defendant was guilty of the nontarget murders because they were the natural and probable consequence of the target offenses. View "People v. Smith" on Justia Law

In 1996, Petitioner was convicted of making a criminal threat and sentenced to a total term of twenty-five years to life pursuant to the Three Strikes Law. In 2012, Petitioner filed a petition for recall of his sentence, arguing that he was eligible for resentencing because his current offense of making a criminal threat had not been categorized as a serious felony at the time of his original conviction. The trial court denied the petition, finding that Petitioner was ineligible because his current offense was now defined as a serious felony. Petitioner appealed. The Court of Appeal treated Petitioner’s appeal as a petition for writ of mandate and denied the petition, concluding that the trial court’s denial of the petition for recall was not appealable because the trial court’s threshold eligibility determination was not a postjudgment order affecting Petitioner’s substantial rights. The Supreme Court reversed, holding that the trial court’s denial of the petition for recall was an appealable order, and the court of appeal erred in holding otherwise. View "Teal v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of two counts of conspiracy. Based on the insufficiency of the evidence, the trial court granted Defendant’s motion for a new trial and dismissed the two conspiracy counts. The court of appeal reversed, reinstated the jury’s verdict, and ordered that the trial court, upon remittitur issuance, could consider Defendant’s remaining grounds for a new trial but that double jeopardy protections prevented Defendant from being retried. The Supreme Court reversed the judgment of the court of appeal to the extent that it barred Defendant from being retried, holding that, if the trial court grants Defendant a new trial on any of his remaining claims, he may be retried. View "People v. Eroshevich" on Justia Law

After a jury trial, Defendant was convicted of three counts of first-degree murder, attempted murder, and carjacking. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no prosecutorial misconduct during the guilt phase, and any improper conduct by the prosecutor during the penalty phase was not prejudicial; (2) there was no error in the jury instructions; (3) the admission of Defendant’s uncharged violent criminal conduct was relevant to the jury’s penalty determination and did not render Defendant’s trial constitutionally unfair; (4) there was no cumulative effect of error requiring reversal of the judgment; and (5) Defendant’s challenges to the death penalty failed. View "People v. Adams" on Justia Law

Defendant was charged with oral copulation of an unconscious person (count 1) and oral copulation of an intoxicated person (count 2), based on the same act. A jury convicted Defendant of both charges. The court of appeal vacated the conviction on count 2 upon its understanding that the Supreme Court’s decision in People v. Craig precluded multiple convictions under these circumstances. The Supreme Court reversed, holding (1) Craig is distinguishable; and (2) Defendant may properly be convicted of, although not punished for, both oral copulation of an unconscious person and oral copulation of an intoxicated person. View "People v. Gonzalez" on Justia Law

After a jury trial, Defendant was convicted of several offenses, including robbery and theft. The convictions stemmed from Defendant's acquisition of gift cards through his false representation that he was using valid payment cards to purchase the gift cards. Defendant challenged his robbery convictions, contending that the type of theft that constitutes a "felonious taking," an element of robbery, was theft by larceny only and not theft by false pretenses, the type of theft that Defendant committed. The court of appeal affirmed Defendant's robbery convictions, holding that theft by false pretenses can satisfy the "felonious taking" requirement of robbery. The Supreme Court reversed, holding that theft by false pretenses cannot satisfy the "felonious taking" element of robbery. Remanded.View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. The jury also found true the special circumstance allegations of burglary-murder and torture-murder. After the jury was unable to agree on a sentence, the trial court declared a mistrial. At the second penalty phase trial, the trial court entered a judgment of death. The Supreme Court affirmed, holding (1) the trial court did not commit prejudicial error in its rulings regarding pretrial issues; (2) the trial court did not prejudicially err in its rulings during the guilt phase of trial; and (3) the trial court did not prejudicially err in its rulings during the second penalty phase.View "People v. Edwards" on Justia Law

Kevin Reilly was originally committed as a sexually violent predator (SVP) in 2000. In 2008, the Secretary of the Department of Corrections and Rehabilitation sought a petition for recommitment. Two evaluators evaluated Reilly under the Sexually Violent Predator Act (SVPA) and concluded he was an SVP. The Office of Administrative Law subsequently determined that the initial evaluations supporting the petition were conducted under an assessment protocol that amounted to an invalid regulation. The evaluators subsequently re-evaluated Reilly based on In re Ronje, this time concluding that he no longer met the criteria for commitment as an SVP. The court of appeal subsequently dismissed the SVPA commitment petition based on Ronje, which ordered replacement evaluations in these circumstances without requiring a determination that the underlying mistake in the assessment protocol amounted to material error. The Supreme Court reversed, holding (1) the Ronje decision was error; (2) an alleged SVP must show that any fault that did occur under the assessment protocol contained a material error; and (3) the court of appeal erroneously dismissed the petition against Reilly without requiring a finding of material error.View "Reilly v. Superior Court of Orange County" on Justia Law