Justia California Supreme Court Opinion Summaries

A trust and an amendment to the trust both contained no contest clauses. In 2009, two of the trust’s beneficiaries filed a safe harbor proceeding seeking a determination that the petition they proposed to file challenging trustee conduct would not trigger the no contest clauses of the trust’s amendment. The probate court concluded the proposed petition did not constitute a contest. At issue on appeal was whether the no contest clause law that became operative in 2010, while the beneficiaries’ application was pending, or the no contest clause law in effect at the time the beneficiaries filed their application applied to the beneficiaries’ proposed petition. The court of appeal held (1) the former no contest law applied, and (2) the beneficiaries’ challenge constituted a contest. The Supreme Court reversed, holding (1) safe harbor proceedings filed before 2010 were not affected by the repeal of the former law, which previously authorized safe harbor applications, and therefore, the probate court correctly ruled on the beneficiaries’ application; (2) the current law governed the question of whether the beneficiaries’ proposed claims triggered the no contest clauses; and (3) under the current law, the no contest clauses in the amended trust were unenforceable against the beneficiaries’ proposed petition. View "Donkin v. Donkin" on Justia Law

After a jury trial, Defendant was convicted of lewd conduct. Defendant appealed, arguing that the trial court had a sua sponte duty to instruct the jury on battery as a lesser and necessarily included offense of lewd conduct. The court of appeal affirmed the judgment. The Supreme Court affirmed the court of appeal, holding (1) battery is not a lesser included offense of lewd conduct; (2) accordingly, if only lewd conduct is charged, the trial court has no duty to instruct on battery as a lesser included offense; and (3) therefore, the trial court in this case did not err in its judgment. View "People v. Shockley" on Justia Law

Jeffrey Burum and James Erwin were charged with aiding and abetting the receipt of bribes by members of a County Board of Supervisors and with conspiring with the supervisors to have them accept the bribes. The People's theory was that Burum, the payor of the bribes, and Erwin, who acted as Burum's agent, used threats and coercion to encourage the Supervisors to accept the illegal payments. Defendants demurred to all of the counts against them. The trial court sustained the demurrers in part. The court of appeals affirmed in part, concluding (1) the payor of a bribe, as a matter of law, cannot aid and abet the receipt of the same bribe or conspire to commit that offense; and (2) the payor's agent stood in the payor's shoes. The Supreme Court reversed, holding (1) the status of being the offeror or payor of a bribe does not disqualify that person, as a matter of law, from complicity in the offense of receiving the bribe; and (2) being the offeror or payor of a bribe does not disqualify that person, as a matter of law, from culpability for participating in a conspiracy to accept that same bribe. View "People v. Biane" on Justia Law

Plaintiffs were five independent retail pharmacies licensed in California, and Defendants were prescription drug claims processors. In 2002, Plaintiffs filed a federal class action suit alleging that Defendants failed to comply with Cal. Civil Code 2527, which requires prescription drug claims processors to compile and summarize information on pharmacy fees and transmit that information to their clients. The district court dismissed the cases for lack of standing without reaching the merits. On appeal, the Ninth Circuit Court of Appeals concluded that Plaintiffs had standing, reversed the district court, and remanded. On remand, Defendants moved for judgment on the pleadings, contending that section 2527 unconstitutionally compels speech in violation of the California and U.S. Constitutions. The district court denied the motions. On appeal, the Ninth Circuit asked the California Supreme Court to answer a question of state law. The Supreme Court answered by holding (1) section 2527 implicates the right to free speech guaranteed by the California Constitution and is subject to rational basis review; and (2) the statute satisfies that standard because the compelled factual disclosures are reasonably related to the Legislature's legitimate objective of promoting informed decisionmaking about prescription drug reimbursement rates. View "Beeman v. Anthem Prescription Mgmt." on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder and related crimes. Following a penalty phase trial, the jury returned a verdict of death. The Supreme Court affirmed the judgment, holding, among other things, that (1) Defendant's rights to a speedy trial were not violated; (2) Defendant's Sixth Amendment rights of self-representation and to the assistance conflict-free counsel were not violated during trial; (3) the prosecution did not violate Defendant's due process rights under Brady v. Maryland; (4) the trial court did not improperly admit "inflammatory and damning evidence" that compromised Defendant's ability to receive a fair trial; (5) the prosecutor did not engage in improper misconduct; and (6) the trial court did not prejudicially err in its penalty phase rulings. View "People v. Williams" on Justia Law

Plaintiffs requested that the State Bar of California provide them access to certain information contained in the State Bar's admissions database, including applicants' grade point averages, race or ethnicity, and bar exam scores. Plaintiffs sought the information to conduct research on racial and ethnic disparities in bar passage rates and law school grades. The State Bar rejected the request. Plaintiffs then filed a petition for writ of mandate in the superior court, seeking to compel the State Bar to provide the records. The trial court concluded that there was no legal basis for requiring disclosure of the admissions database and denied the petition without reaching any issues regarding the privacy of the applicants. The court of appeal reversed. The Supreme Court affirmed and remanded, holding that under the common law right of public access, the State Bar was required to provide access to the information contained in the admissions database if the information could be provided in a form that protected the privacy of applicants and if no countervailing interest outweighed the public's interest in disclosure. View "Sander v. State Bar of Cal." on Justia Law

Michael Garcia received special education services during his school years. Before Garcia turned sixteen, he was arrested on felony charges and transferred to the Los Angeles County Jail to await trial. At that point, Garcia stopped receiving special education services. The issue of whether Garcia was entitled to special education services in the county jail was raised in several proceedings, including an action before the Office of Administrative Hearings, Special Education Division (OAH). The OAH concluded that Cal. Educ. Code 56041 applied, and because Garcia's mother resided within the boundaries of the Los Angeles Unified School District (L.A. Unified), L.A. Unified was responsible for Garcia's special education while he was incarcerated in county jail. L.A. Unified sought relief from the OAH's decision with the federal district court, which affirmed. On appeal, the court of appeals asked the California Supreme Court to decide a question of state law. The Supreme Court answered that Cal. Educ. Code 56041 - which provides generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for special education services - affixes responsibility for providing special education to a qualifying individual who is incarcerated in a county jail. View "Los Angeles Unified Sch. Dist. v. Garcia" on Justia Law

After a jury trial, Defendant was convicted of first degree felony murder and robbery. The jury also sustained a special circumstance allegation of murder in the commission of a robbery. After a penalty trial, the court pronounced a death judgment for the special circumstance murder. Defendant appealed, alleging several trial errors. The Supreme Court affirmed, holding that the trial court did not commit prejudicial error in, among other things, selecting the jury, making its evidentiary rulings, and instructing the jury during both the guilt phase and the penalty phase. The Court also rejected Defendant's attack on California's death penalty law, finding it to be constitutional. View "People v. Contreras" on Justia Law

Defendant pled no contest to possession of methylenedioxymethamphetamine. As part of the plea proceeding, Defendant waived a preliminary hearing and a probation report. After the prosecutor conducted a voir dire of Defendant, defense counsel stipulated to the existence of a factual basis for Defendant's plea without referring to any document to support the stipulation. The trial court accepted the plea. Defendant appealed, contending the trial court failed to establish a factual basis for his plea under Cal. Penal Code 1192.5. The court of appeals affirmed. The Supreme Court affirmed, holding that because Defendant acknowledged in the plea colloquy that he had discussed the elements of the crime and any defenses with his counsel and was satisfied with her advice, the trial court did not err in finding a factual basis for Defendant's no contest plea based on counsel's stipulation. View "People v. Palmer" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder and one count each of attempted murder, aggravated mayhem, and second degree attempted robbery. The trial court sentenced Defendant to death for the two murder convictions. The Supreme Court affirmed, holding (1) the trial court did not err in allowing a certain juror to remain on the jury despite her alleged fear for her safety; (2) Defendant's arguments that the trial court should have granted a new trial and a new penalty phase trial in light of alleged juror misconduct failed; (3) the trial court did not err in excusing for cause three prospective jurors and in failing to remove five prospective jurors for cause; (4) the prosecution did not impermissibly use peremptory challenges to excuse prospective jurors for discriminatory reasons; (5) the trial court did not violate Defendant's constitutional rights by ordering him to wear an electric shock belt during trial; (6) the evidence was sufficient to sustain Defendant's aggravated mayhem conviction; and (7) the trial court did not prejudicially err in instructing the jury. View "People v. Manibusan" on Justia Law