Justia California Supreme Court Opinion Summaries

Petitioner was charged with three counts of first degree murder and related charges. Petitioner filed a motion to recuse the lead prosecutor on the case on grounds that the prosecutor allegedly knew one of the victims in the case, that two of the prosecutor’s adult children knew Petitioner and would be called as witnesses by the defense at the penalty phase if Petitioner was found guilty, and that the prosecutor’s daughter dated Petitioner’s friend, a proposed prosecution and defense penalty phase witness. The trial court denied Petitioner’s request for an evidentiary hearing and denied his motion to recuse the prosecutor. The Supreme Court reversed, holding that the trial court abused its discretion by denying Petitioner’s request for an evidentiary hearing on the ground that Petitioner had failed to make a prima facie showing that recusal was warranted, as a hearing was necessary to determine whether the conflict in this case would render it unlikely that Petitioner would receive a fair trial if the prosecutor was not recused as lead prosecutor in the case. View "Packer v. Superior Court" on Justia Law

After a jury trial, Defendants were convicted of kidnapping, first degree murder, and torture. Defendants filed a motion for new trial, asserting that that the jurors improperly discussed and considered during their deliberations Defendants’ decisions not to testify. The Court of Appeal reversed the convictions and ordered a new trial, concluding that the discussion of Defendants’ decisions not to testify constituted misconduct and the misconduct was categorically prejudicial, even assuming the foreperson had promptly and correctly reminded the jury of the court’s instructions to disregard Defendants’ decisions not to testify. The Supreme Court reversed, holding that the Court of Appeal erred in finding the presumption of prejudice could not be rebutted even if the jurors had been reminded of the court’s instructions not to consider that issue and no objective evidence indicted the reminder would have been ineffective. Remanded to the trial court to determine the nature and scope of the misconduct and the existence and timing of any reminder of the court’s instructions to disregard Defendants’ decisions not to testify. View "People v. Lavender" on Justia Law

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