Justia California Supreme Court Opinion Summaries

Sheriff's deputies came to the home of Shane Hayes in response to a call from a neighbor. When the deputies arrived, Hayes's girlfriend informe them that Hayes was suicidal. The deputies then entered the house, where Hayes came toward them with a large knife raised in his right hand. The deputies simultaneously drew their guns and fired at Hayes, who died from the gunshot wounds. Hayes's daughter filed a complaint in federal district court against the County of San Diego and the deputies, alleging three federal law claims and two state law claims. The district court granted summary judgment for Defendants on all claims, finding that the deputies owed Plaintiff no duty of care with respect to their preshooting conduct. The Ninth Circuit Court of Appeals asked the California Supreme Court to answer a question of state law. The Court answered by holding that, under California negligence law, liability can arise from tactical conduct and decisions employed by law enforcement preceding the use of deadly force if the conduct and decisions leading to the use of deadly force show, as part of the totality of the circumstances, that the use of deadly force was unreasonable.View "Hayes v. County of San Diego" on Justia Law

A male supervisor employed by a franchisee allegedly subjected a female subordinate to sexual harassment while working together at the franchisee’s pizza store. Plaintiff, the victim, sued the franchisor, the franchisee, and the harasser, arguing that the franchisor could be held vicariously liable for the harasser’s misconduct. The trial court granted summary judgment in favor of the franchisor, concluding that the requisite employment and agency relationship did not exist between the franchisor and franchisee in this case. The court of appeals reversed. The Supreme Court reversed and granted summary judgment in the franchisor’s favor, holding that, under the circumstances of this case, the franchisor did not stand in an employment or agency relationship with the franchisee and its employees for purposes of holding it vicariously liable for workplace injuries allegedly inflicted by the victim's supervisor. View "Patterson v. Domino’’s Pizza, LLC " on Justia Law

After a jury trial, Defendant was convicted of attempted criminal threat. Defendant appealed, arguing that the trial court erred in failing to instruct the jury that the crime of attempted criminal threat requires a finding that the intended threat reasonably could have caused sustained fear under the circumstances. The court of appeals affirmed the convictions, concluding that an attempted criminal threat does not require such a reasonableness element. The Supreme Court affirmed, holding (1) a defendant who utters words to a victim with a subjective intent to threaten may only be convicted of the crime of attempted criminal threat if there is sufficient proof that the intended threat under the circumstances was sufficient to cause a reasonable person to be in sustained fear; and (2) Defendant’s threats under the circumstances were sufficient to cause a reasonable person to be in sustained fear. View "People v. Chandler" on Justia Law

In assessing the value of electric power plants for purposes of property taxation, assessors may not include the value of intangible assets and rights in the value of taxable property. An electric company purchased "emission reduction credits" (ERCs), which the company had to purchase to obtain authorization to construct an electric power plant and to operate it at certain air-pollutant emission levels. These ERCs constituted intangible rights for property taxation purposes. In assessing the value of the power plant using the replacement cost method, the State Board of Equalization (Board) estimated the cost of replacing the ERCs. In also using an income approach in assessing the plant, the Board failed to attribute a portion or the plant's income stream to the ERCs and to deduct that value from the plant's projected income stream prior to taxation. In analyzing the Board's valuation of the power plant, the Supreme Court held (1) the Board improperly taxed the power company's ERCs when it added their replacement cost to the power plant's taxable value; and (2) the Board was not required to deduct a value attributable to the ERCs under an income approach. Remanded.View "Elk Hills Power, LLC v. Bd. of Equalization" on Justia Law

Public school students with diabetes who cannot self-administer insulin are entitled under federal law to have it administered to them during the school day at no cost. In 2007, the State Department of Education (Department) issued a legal advisory authorizing unlicensed school personnel to administer insulin. The American Nurses Association and other trade organizations representing registered and school nurses (collectively, Nurses) challenged the document by filing this action seeking declaratory relief and a writ of mandate, asserting that the Department's advice condoned the unauthorized practice of nursing. The superior court declared the advisory invalid to the extent it authorized unlicensed school personnel to administer insulin. The Supreme Court reversed, holding that California law expressly permits trained, unlicensed school personnel to administer prescription medications such as insulin in accordance with the written statements of a student's treating physician and parents and expressly exempts persons who thus carry out physicians' medical orders from laws prohibiting the unauthorized practice of nursing.View "Am. Nurses Ass'n v. Torlakson" on Justia Law

A jury convicted Defendants Stanley Bryant, Donald Franklin Smith, and Leroy Wheeler were convicted of various crimes relating to the fatal shooting of four individuals. Bryant and Wheeler were convicted of four counts of first degree murder and one count of attempted murder, and Smith was convicted of two counts of first degree murder, two counts of second degree murder, and one count of attempted murder. The jury returned verdicts of death. The Supreme Court affirmed the judgments, holding that any error or any error assumed for the sake of argument that occurred during the pretrial proceedings, the guilt phase, or the penalty phase were harmless. View "People v. Bryant" on Justia Law

Pursuant to the terms of a plea bargain, Defendant, who was an eighteen-year-old citizen of Mexico at the time, pleaded guilty to the sale or transportation of marijuana. After completing his probation, Defendant sought an adjustment in status to lawful permanent residency. Defendant's application was denied because of his conviction, and removal proceedings were initiated against him. Defendant filed a motion to vacate his conviction pursuant to Cal. Penal Code 1016.5, asserting that had he known the immigration consequences of pleading guilty, he would have rejected the plea offer. The only issue adjudicated at the hearing on Defendant's motion was whether he would have received a more favorable outcome had he rejected the plea bargain. The trial court denied the motion without considering the possibility Defendant might have rejected the plea bargain even if it were not reasonably probable he would have received a more favorable outcome. The Supreme Court reversed, holding (1) relief is available under section 1016.5 if the defendant establishes he would have rejected the existing bargain to accept or attempt to negotiate another; and (2) the trial court applied the incorrect test for prejudice in this case. Remanded. View "People v. Martinez" on Justia Law

After a jury trial, Defendant, an alleged member of the Mexican Mafia, was convicted of the first degree murders of three adults and two children. The jury also found true multiple-murder special-circumstance and weapon use sentence enhancement allegations. Defendant was sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in its rulings and decisions prior to trial; (2) the evidence was sufficient to support Defendant's convictions and the multiple-murder special-circumstance true finding; (3) the trial court did not err in the remainder of its rulings during the guilt phase of Defendant's trial; (4) the trial court did not engage in judicial misconduct during either the guilt phase or the penalty phase; (5) the prosecutor did not commit prejudicial misconduct during closing argument; (6) the trial court did not err in the remainder of its rulings during the penalty phase; and (7) California's death penalty statute is not constitutionally invalid.View "People v. Maciel" on Justia Law

After a jury trial, Defendant was found guilty of three counts of first degree murder, one count of attempted murder, and two counts of kidnapping. The jury found, among other things, that Defendant personally used a knife during each crime and inflicted great bodily injury on the kidnapping victims. The jury returned a verdict of death following the penalty phase of the trial. The trial rendered judgment on the verdict and sentenced Defendant to death. The Supreme Court affirmed the judgment, holding that there was no prejudicial error during pretrial proceedings, the guilt phase, or the penalty phase. View "People v. Lucas" on Justia Law

Pursuant to the California Environmental Quality Act (CEQA), the Exposition Metro Line Construction Authority (Expo Authority) approved a project to construct a light-rail line from Culver City to Santa Monica. Plaintiffs, Neighbors for Smart Rail, petitioned for a writ of mandate, alleging that Expo Authority's approval of the project violated CEQA in several respects. The superior court denied the petition, and the court of appeal affirmed. The Supreme Court affirmed, holding (1) the Expo Authority abused its discretion by examining certain environmental impacts only on projected future conditions, and not on existing environmental conditions, but the abuse of discretion was non prejudicial; and (2) the Expo Authority's mitigation measure adopted for possible impacts on street parking near planned transit stations satisfied CEQA's requirements. View "Neighbors for Smart Rail v. Exposition Metro Line Constr. Auth. " on Justia Law