Justia California Supreme Court Opinion Summaries

Defendants, Stephen Edward Hajek and Loi Tan Vo, were convicted of, among other crimes, the murder of Su Hung. The jury found true lying-in-wait and torture-murder special circumstances as to both defendants. The jury also found true firearm use allegations as to Hajek and deadly or dangerous weapon use as to Vo, in Defendants’ commission of the murder, attempted murder, kidnapping, and false imprisonment counts. The jury returned verdict of death as to each defendant. The Supreme Court affirmed the death judgments, reversed the lying-in-wait special circumstances findings as to both defendants, and ordered that the firearm use enhancements found true as to Hajek be struck and replaced with deadly or dangerous weapon use enhancements, holding (1) there was insufficient evidence to show that Defendants intentionally killed the victim while lying in wait, but the reversal of the lying-in-wait special-circumstance findings did not require reversal of Defendants’ death sentences; and (2) a change in the law excluding pellet guns from the definition of a firearm required that Hajek’s firearm use enhancements involving the use of a pellet gun be struck, but the jury’s true findings on the firearm use enhancements necessarily included true findings on deadly or dangerous weapon use enhancements. View "People v. Hajek" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted robbery, and second degree robbery. Following a retrial of the penalty phase trial, the jury sentenced Defendant to death for the murder conviction. The Supreme Court affirmed the judgment, including the death sentence, but ordered the clerk of the superior court to modify the abstract of judgment to reflect ninety-six days of conduct credit, holding that there was no reversible error in the jury selection and that the trial court did not err in its rulings during the guilt phase and the penalty phase, with the exception of denying Defendant presentence conduct credits. View "People v. Chism" on Justia Law

Defendants in these cases were both seventeen-year-old offenders who were convicted of special circumstance murder and sentenced to life imprisonment without the possibility of parole under Cal. Penal Code 190.5(b). After Defendants were sentenced, the U.S. Supreme Court decided Miller v. Alabama. On review, the California Supreme Court held (1) section 190.5(b), properly construed, confers discretion upon a trial court to sentence a juvenile convicted of special circumstance murder to life without parole, with no presumption in favor of life without parole; (2) Miller requires a trial court, in exercising its sentencing discretion, to consider the distinctive attributes of youth before imposing life without parole on a juvenile offender; (3) section 190.5(b) does not violate the Eighth Amendment to the U.S. Constitution because it authorizes and requires consideration of the distinctive attributes of youth highlighted in Miller, once the statute is understood not to impose a presumption in favor of life without parole; and (4) because the trial courts in these cases sentenced Defendants without awareness of the full scope of their discretion conferred by section 190.5(b) and without the guidance set forth in Miller, the cases must be remanded for resentencing. View "People v. Gutierrez" on Justia Law

Plaintiff-consumers brought an action against Defendant-retailer under two consumer protection statutes, alleging that Defendant improperly charged them sales tax reimbursement on sales of hot coffee sold “to go,” when, according to Plaintiffs, the tax code rendered such sales exempt from sales tax. Plaintiffs sought a refund of the asserted unlawful charges, damages, and an injunction forbidding collection of sales tax reimbursement for such sales. The trial court sustained Defendant’s demurrer, and the court of appeal affirmed. The Supreme Court affirmed, holding (1) the Revenue and Taxation Code provides the exclusive means by which Plaintiffs’ dispute over the taxability of a retail sale may be resolved, and Plaintiffs’ current lawsuit was inconsistent with tax code procedures; and (2) the consumer statutes under which Plaintiffs brought their action could not be employed to avoid the limitations and procedures set out in the tax code. View "Loeffler v. Target Corp." on Justia Law

After a jury trial in 1995, Defendant was convicted of twelve counts of first degree murder and one count of attempted murder. Defendant’s victims abused drugs and worked as prostitutes. The trial court sentenced Defendant to death with respect to each of the twelve murder convictions. The Supreme Court affirmed, holding (1) the trial court’s denial of Defendant’s motion for a change of venue based on the public’s knowledge of his case did not deprive Defendant of due process of law or a fair trial; (2) the trial court did not err in denying Defendant’s motion to suppress evidence obtained as a result of a traffic stop; (3) the trial court did not err in denying discovery concerning murders of prostitutes with which Defendant was not charged; (4) the trial court did not err in failing to exclude evidence obtained during police questioning of Defendant and in making its other evidentiary rulings; (5) the extent and nature of the victim impact evidence did not deprive Defendant of his rights to due process, a fair trial, and a reliable penalty determination; and (6) California’s death penalty scheme, jury instructions, and procedures are constitutional. View "People v. Suff" on Justia Law

After a jury trial, Petitioner and his codefendant were convicted of burglarizing the home of Bobby Hassan and of robbing and murdering Bobby and his son, Eric. Petitioner and his codefendant were sentenced to death in 1982. The Supreme Court affirmed on appeal. Petitioner later filed a petition for writ of habeas corpus, alleging that his trial attorney ineffectively represented him at the penalty phase of trial. In 2002, the Supreme Court issued an order to show cause based on Petitioner’s claim of ineffective assistance of counsel. The Court appointed a referee and directed him to take evidence and make findings of fact. In 2014, based on the referee’s findings, the Supreme Court denied relief, holding that Petitioner’s counsel did not provide incompetent representation at trial. View "In re Champion" on Justia Law

In 1986, Defendant, a native of Mexico and a lawful permanent resident of the United States, pled guilty to possessing a sawed-off shotgun. In 2010, Defendant moved to vacate his conviction, asserting that he had not been given the required immigration advisements when he entered his guilty plea. The trial court denied Defendant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a certificate of probable cause is not required to appeal a trial court’s denial of a motion to vacate a conviction under Cal. Penal Code 1016.5; (2) when proof of the required immigration advisements is not adequately shown on the record, the prosecution must prove by a preponderance of the evidence that the advisements were given; and (3) the evidence in this case supported the trial court’s finding that Defendant was told of the immigration consequences of pleading guilty. View "People v. Arriaga" on Justia Law

Alonzo J. was charged in a juvenile court delinquency petition with two felony counts of assault with a deadly weapon by means of force likely to produce great bodily injury. The juvenile court appointed attorney Jo Ann Harris to represent Alonzo on the charges. The prosecution offered a plea deal under which Alonzo could return home on probation if he admitted to committing one felony assault. Alonzo wanted to accept the offer, but Harris refused to consent. The juvenile court would not accept Alonzo’s admission of guilt without Harris’s consent, and, after a hearing, sustained all charges against Alonzo. The court then directed that Alonzo be placed in a foster or group home, a residential treatment center, or the home of a friend or relative. The court of appeal reversed, holding that although Harris’s consent was required for an admission of the charges, it was not required for a no contest plea, and the juvenile court should have allowed Alonzo to accept the plea offer by pleading no contest. The Supreme Court reversed, holding that, in a delinquency proceeding, the consent of the child’s attorney is required for a no contest plea, just as it is for an admission of the charging allegations. View "In re Alonzo J." on Justia Law

A Cal. Welf. & Inst. Code 602 wardship petition was filed alleging that D.B. committed a series of criminal offenses, including serious or violent offenses. A juvenile court found the allegations true, sustained the petition, and committed D.B. to the Department of Corrections and Rehabilitation, Division of Juvenile Facilities (DJF) for the maximum term. The court of appeal reversed, concluding that the plain language of Cal. Welf. & Inst. Code 733(c) prohibits a DJF commitment when the minor’s most recent offense is not listed in Cal. Welf. & Inst. Code 707(b) or Cal. Penal Code 290.008(c). The People appealed, arguing that the court of appeal’s interpretation could produce absurd consequences when a juvenile’s violent crime spree happens to end with a nonviolent offense. The Supreme Court affirmed, holding that the plain language of section 733(c) mandates that a minor may not be committed to DJF unless the most recently committed offense that is alleged in any wardship petition, then admitted or found true, is listed in section 707(b) or section 290.008(c). View "In re D.B." on Justia Law

After a jury trial, Defendant was convicted of two counts of animal cruelty. During voir dire, the trial court denied Defendant’s challenges to two prospective jurors on incompetence grounds, after which Defendant used two of his allotted peremptory challenges to remove the same jurors. Defendant subsequently exhausted his peremptory challenges and unsuccessfully requested that the trial court grant him extra peremptory challenges to remove other prospective jurors he deemed to be objectionable. On appeal, Defendant claimed he was entitled to reversal of the trial court’s judgment because one of the jurors he objected to sat on his case. The Supreme Court affirmed Defendant’s conviction, holding (1) Defendant cured any error that occurred when the trial court denied his for-cause challenges because those jurors were removed with Defendant’s peremptory challenges; (2) the trial court was under no obligation to grant Defendant extra peremptory challenges to remove additional, otherwise competent, jurors; and (3) because no incompetent juror who should have been dismissed for cause sat on Defendant’s case as a result of Defendant exhausting his peremptory challenges, Defendant was not entitled to reversal. View "People v. Black" on Justia Law