Justia California Supreme Court Opinion Summaries

During the course of one evening, Defendant and another man burglarized two businesses, robbing several people inside, and killing off-duty peace officer Shayne York. After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a peace officer in retaliation for the performance of his duties and of murder during the commission of robbery and burglary. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed Defendant’s convictions, holding (1) the trial court did not err in its evidentiary rulings or in instructing the jury during the guilt phase; (2) sufficient evidence supported the finding that Defendant intentionally killed York in retaliation for the lawful performance of his duties, and the special circumstance allegation was constitutional; (3) Defendant’s challenges to the robbery-murder and burglary-murder special circumstances were unavailing; (4) Defendant’s Sixth Amendment right to self-representation was not violated at the penalty phase; (5) any error in the instructions during the penalty phase was harmless; and (6) Defendant’s death sentence was proportional and constitutional. View "People v. Boyce" on Justia Law

Plaintiff, who formerly worked for Time Warner Cable, Inc. as a commissioned salesperson, filed a class action suit against Time Warner, alleging wage and hour violations. Time Warner paid Plaintiff through biweekly paychecks, which included hourly wages in every pay period and commission wages approximately every other pay period. Time Warner removed the matter to federal court and sought summary judgment. The district court granted summary judgment, concluding that Time Warner could attribute commission wages paid in one biweekly pay period to other pay periods for the purpose of satisfying California’s compensation requirements. The Court of Appeals for the Ninth Circuit’s asked the Supreme Court to consider the issue. The Supreme Court answered the Ninth Circuit’s question in the negative, holding that an employer may not attribute commission wages paid in one pay period to other pay periods in order to satisfy California’s compensation requirements. View "Peabody v. Time Warner Cable, Inc." on Justia Law

The assumption under the Three Strikes law is that a defendant has had two prior opportunities to reform before being found incorrigible and receiving a life sentence. At issue in this case was whether an offender’s two previous qualifying felony convictions that are closely connected in their commission can nevertheless constitute two separate strikes under the Three Strikes law. Here, Defendant’s two prior felony convictions were tried in the same proceeding, committed during the same course of criminal conduct, based on the same act, and committed as the same time and against the same victim. The trial court concluded that Defendant fell “squarely within the spirit of [Three] Strikes” and denied Defendant’s motion to dismiss one of the prior convictions. The Supreme Court vacated the judgment, holding that the trial court was required to dismiss one of the prior convictions because failure to do so would be inconsistent with the spirit of the Three Strikes law. Remanded. View "People v. Vargas" on Justia Law

Defendants Reynaldo Junior Eid and Alaor Docarmo Oliveira were charged in an amended information with two counts of kidnapping for ransom, which is punishable by life in prison. A jury found Defendants guilty of the lesser included crimes of attempted extortion and misdemeanor false imprisonment. The trial court sentenced Defendants to four years and six months in custody. Defendants argued on appeal that they could not be convicted of two lesser included offenses of a single greater offense. The court of appeals agreed with Defendants and struck Defendants’ convictions for misdemeanor false imprisonment, thus reducing each Defendant’s sentence to two years and six months. The Supreme Court reversed, holding that the jury may convict on more than one uncharged lesser included offense of a single charged greater offense. View "People v. Eid" on Justia Law

Under 28 U.S.C. 1367 federal courts may assume supplemental jurisdiction over related state claims that form part of the same case or controversy. If the federal basis for jurisdiction dissolves but supplemental claims remain, the federal court may dismiss the supplemental claims, requiring them to be refiled in state court. In this event, the limitations is “tolled while the claim is pending and for a period of thirty days after it is dismissed” pursuant to section 1367(d). At issue in this appeal was whether the statute affords parties a grace period or suspends the limitations clock. In the instant case, seventy-eight days after the plaintiff’s supplemental claims were dismissed by a federal court, the plaintiff refiled suit in state court. The court of appeal concluded that the suit was timely, reasoning that section 1367(d) suspended the statute of limitations and tacked on any unexpired time beginning thirty days after dismissal. The Supreme Court reversed, holding that section 1367(d) provides only a thirty-day grace period in which to refile otherwise expired claims. View "City of Los Angeles v. County of Kern" on Justia Law

Plaintiff prevailed at trial in an action for financial abuse of an elder or dependent adult. The judgment was affirmed on appeal. After judgment, Plaintiff brought a separate action seeking to prevent or reverse Defendant’s transfer of real property to third persons. Plaintiff subsequently dismissed the fraudulent transfer action pursuant to an agreement with Defendant. Thereafter, Plaintiff moved for costs and attorney fees incurred both on appeal from the elder abuse judgment and in the fraudulent transfer action. The court of appeals concluded that the fees and costs motion was untimely under Cal. Code Civ. Proc. 685.040. The Supreme Court reversed in part, holding (1) as to attorney fees on appeal from the elder abuse judgment, the motion was not subject to section 685.080 because Plaintiff’s efforts in opposing Defendant’s appeal were not undertaken to enforce the judgment but to defend it against reversal or modification; and (2) Plaintiff’s motion was untimely as to fees incurred enforcing the judgment through the separate fraudulent transfer action because the fees incurred in that action could only be recovered under section 685.040. View "In re Conservatorship of McQueen" on Justia Law

One of the jurors in Defendant’s criminal case prematurely decided to vote guilty, repeatedly talked about the case outside deliberations, prematurely reached a conclusion regarding the veracity of certain testimony, and adopted the mantle of an advocate, repeatedly telling the other jurors that Defendant was guilty. The trial court found that the juror engaged in serious misconduct but that Defendant did not suffer prejudice. Defendant appealed his conviction of two counts of first degree murder and death sentence on the basis of juror misconduct. The Supreme Court reversed, holding that, under the facts of this case, the People did not discharge their burden of establishing that there was no substantial likelihood that the juror was actually biased against Defendant. View "People v. Weatherton" on Justia Law

An employee (Claimant) was asked by his employer to sign a written disciplinary notice regarding Claimant’s alleged misconduct. Claimant refused to sign the notice, claiming that he wished to consult with his union first and that he believed that signing would constitute an admission of guilt. Based on this incident, the employer terminated Claimant for insubordination. The Employment Development Department denied Claimant’s application for unemployment benefits, determining that Claimant’s refusal to sign the disciplinary notice constituted misconduct. The Unemployment Insurance Appeals Board reversed, finding that Claimant’s failure to sign the notice was “an instance of poor judgment” that did not disqualify Claimant from receiving benefits. The Supreme Court affirmed, holding that, even if Claimant’s refusal to sign the disciplinary notice justified his termination, Claimant did not commit misconduct within the meaning of California’s Unemployment Insurance Code. View "Paratransit, Inc. v. Unemployment Ins. Appeals Bd." on Justia Law

Defendants, two architectural firms, were the sole entities that provided architectural services for a collection of condominium units in San Francisco. The homeowners association sued several parties involving in the construction of the condominiums, including Defendants, alleging that negligent architectural design work performed by Defendants resulted in several defects. The trial court sustained a demurrer in favor of Defendants, determining that because the final decision regarding how the homes would be built rested with the owner, Defendants owed no duty to the future condominium owners. The court of appeal reversed, concluding that, under both the common law and the Right to Repair Act, Defendants owed a duty of care to the homeowners in this case. The Supreme Court affirmed, holding (1) an architect owes a duty of care to future homeowners in the design of a residential building where the architect is a principal architect on the project, and the duty of care extends to such architects even when they do not actually build the project or exercise ultimate control over construction; and (2) the complaint int his case sufficiently alleged the causal link between Defendants’ negligence and the condominium association’s injury. View "Beacon Residential Cmty. Ass’n. v. Skidmore, Owings & Merrill" on Justia Law

After a jury trial, Defendant was convicted of murder, rape, and kidnapping and sentenced to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in finding that Defendant was competent to stand trial; (2) the prosecutor did not improperly exercise a peremptory challenge to a prospective juror based on race; (3) during the guilt phase of trial, the trial court did not abuse its discretion in admitting crime scene and autopsy photographs and in instructing the jury; (4) no prejudicial error occurred during the penalty phase of trial; (5) the trial court did not err in denying Defendant’s motion for a new trial; and (6) Defendant’s challenges to California’s death penalty statute failed. View "People v. Sattiewhite" on Justia Law