Justia California Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of three counts of first degree murder with a multiple-murder special circumstance, one count of attempted murder, and firearm enhancements for the shootings and attempted shootings of staff members at a hospital. After two penalty trials that resulted in hung juries, the third penalty jury returned a verdict of death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court’s denial of Defendant’s motion to recuse the district attorney’s office was not an abuse of discretion; (2) the trial court erred in its instructions to the jury, but the error was harmless; (3) retrial did not violate Defendant’s rights to due process and equal protection and the prohibition against cruel and unusual punishment; (4) Defendant was not deprived of the right to equal protection and trial by a representative jury because the jury included no Vietnamese-Americans; (5) although the prosecutor engaged in misconduct during the penalty phase, the improper questions did not influence the verdict; and (6) Defendant’s allegations of error in post-trial issues were without merit. View "People v. Trinh" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted premeditated murder, two counts of second degree robbery and arson causing great bodily injury. The jury returned a verdict of death. The Supreme Court vacated Defendant’s arson-murder special-circumstance finding but otherwise affirmed the judgment in its entirety, holding (1) the trial court did not err in restricting Defendant’s counsel’s questioning of prospective jurors during voir dire; (2) the evidence was insufficient to support the arson-murder special circumstance because the arson did not involve an inhabited structure or property; (3) the trial court did not abuse its discretion in dismissing a juror during the trial; (4) the trial court did not prejudicially err in its instructions to the jury; (5) the trial court did not err in refusing to declare a mistrial after the penalty jury initially declared it was deadlocked; and (6) Defendant’s challenges to the constitutionality of California’s death penalty scheme were without merit. View "People v. Debose" on Justia Law

Defendant was found guilty of failing to stop at a red traffic light at an intersection. Defendant's conviction was based on evidence generated by an automated traffic enforcement system (ATES), otherwise known as a red light traffic camera. Defendant’s conviction was upheld on appeal. At issue before the Supreme Court was whether the trial court properly admitted the ATES evidence over Defendant’s objections of inadequate foundation and hearsay. The Supreme Court affirmed, holding (1) sufficient evidence was submitted for the court to sustain a finding that the ATES evidence was adequately authenticated; and (2) ATES evidence does not constitute hearsay. View "People v. Goldsmith" on Justia Law

After a jury trial, Defendant was found guilty of first degree willful, deliberate and premeditated murder on the theory that the Defendant either directly aided and abetted the murder or that Defendant aided and abetted the target offense of assault or disturbing the peace, the natural consequence of which was murder. The court of appeal reversed Defendant’s first degree murder conviction, holding that the trial court erred in failing to instruct the jury that it must find first degree premeditated murder, rather than first degree murder, was the natural and probable consequence of either target offense and that the error was not harmless. The Supreme Court affirmed the court of appeal but on different grounds, holding (1) an aider and abetter may not be convicted of first degree premeditated murder under the natural and probable consequences doctrine; rather, his liability for that crime must be based on direct aiding and abetting principles; and (2) because the jury in this case may have based its verdict of first degree premeditated murder on the natural and probable consequences theory, the first degree murder conviction must be reversed. View "People v. Chiu" on Justia Law

If a defendant commits a killing out of an unreasonable belief in the need for self-defense, he or she may be convicted of voluntary manslaughter but not murder. After a jury trial in this case, Defendant was convicted of first degree murder. On appeal, the court of appeal rejected Defendant’s argument that the trial court erred in failing to instruct the jury on unreasonable self-defense, concluding that the doctrine does not apply when belief in the need for self-defense arises solely from the defendant’s delusional mental state. The Supreme Court affirmed, holding (1) at a trial on the question of guilt, the defendant may not claim unreasonable self-defense based on insane delusion, and a purely delusion belief in the need to act in self-defense may be raised as a defense, but that defense is insanity; and (2) because Defendant’s claim of unreasonable self-defense was based entirely on a delusional mental state that amounted to legal insanity, the trial court properly denied Defendant’s request for an instruction on unreasonable self-defense. View "People v. Elmore" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, sodomy, and forcible lewd act on a minor. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in failing to exclude expert testimony that the victim died by drowning in association with sexual assault; (2) the trial court did not err in the remainder of its evidentiary rulings; (3) the evidence was sufficient to support the convictions; (4) defense counsel provided constitutionally effective assistance; (5) the trial court did not err by accepting Defendant’s waiver of his right to present mitigating evidence; (6) Defendant’s voluntary absence during trial did not violate the federal Constitution; and (7) Defendant’s constitutional challenges to the death penalty law and related jury instructions were without merit. View "People v. Brown" on Justia Law

The Los Angeles Times asked the City of Long Beach to release the names of the police officers involved in certain shootings. The Long Beach Police Officers Association (“Union”) sought injunctive relief against the City, attempting to prevent release of the names to the Times. The Times subsequently intervened, seeking disclosure of the names. The City supported the Union’s request for injunctive relief and opposed disclosure. The trial court denied the Union’s request for a preliminary or permanent injunction. The court of appeal upheld the denial. The Supreme Court affirmed, holding that the particularized showing necessary to outweigh the public’s interest in the disclosure of the names of peace officers involved in the on-duty shootings was not made in this case. View "Long Beach Police Officers Ass’n. v. City of Long Beach" on Justia Law

Loan officers for U.S. Bank National Association (USB) sued USB for unpaid overtime, asserting that they made been misclassified as exempt employees under the outside salesperson exemption. The trial court certified a class of plaintiffs and then determined the extent of USB’s liability to all class members by extrapolating from a random sample. The jury returned a verdict of approximately $15 million, resulting in an average recovery of more than $57,000 per person. The court of appeal reversed the trial court’s judgment and ordered the class decertified. The Supreme Court affirmed the court of appeal’s judgment in its entirety, holding that the trial court’s particular approach to sampling in this case was profoundly flawed and prevented USB from showing that some class members were entitled to no recovery. Remanded for a new retrial on both liability and restitution. View "Duran v. U.S. Bank Nat’l Ass’n" on Justia Law

This appeal centered on the Realignment Act, which changed the punishment for some felony convictions. The Legislature provided that the sentencing changes “shall be applied prospectively to any person sentenced on or after October 1, 2011.” At issue in this case was whether the Act applies to defendants, such as the defendant in this case (Defendant), whose state prison sentences were imposed and suspended prior to October 1, 2011. The court of appeal determined that the trial court did not err in directing that Defendant’s sentence should be served in county jail rather than in state prison. The Supreme Court reversed, holding (1) the Act is not applicable to defendants who have had a state prison sentence imposed and suspended prior to October 1, 2011; and (2) therefore, upon revocation and termination of Defendant’s probation, the trial court erred, when ordering execution of Defendant’s previously imposed sentence, in committing Defendant to the county jail under the terms of the Act rather than to state prison according to the terms of the original sentence. View "People v. Scott" on Justia Law

Before Husband and Wife separated, Husband used community property funds from a joint bank account to buy an insurance policy on his life, naming Wife as the sole owner and beneficiary. At the parties’ marital dissolution proceeding, the trial court ruled that the insurance policy was community property, awarded the policy to Husband, and ordered him to buy out Wife’s interest in the policy by paying her one-half of the policy’s cash value at the time of trial. The court of appeal reversed, concluding that the trial court erred in characterizing the policy as community property and that the insurance policy was Wife’s separate property. The Supreme Court reversed, holding that, unless the statutory transmutation requirements have been met, the life insurance policy is community property. Remanded. View "In re Marriage of Valli" on Justia Law