Justia California Supreme Court Opinion Summaries

Defendant was charged with driving under the influence of alcohol and driving with a blood-alcohol concentration of 0.08 percent or more. During the trial proceedings, the trial court excluded expert witness testimony challenging the reliability of the breach-alcohol testing machines used on Defendant. The jury was unable to reach a verdict on the generic charge but found Defendant guilty of driving with 0.08 percent or more of alcohol in his blood. The court of appeals reversed, concluding that the trial court committed prejudicial error in excluding the challenged expert testimony. The Supreme Court reversed and affirmed Defendant's conviction, holding that the trial court properly excluded the challenged expert testimony, holding that the fundamental reliability of a federally approved, properly calibrated and employed breath-testing machine used in the application and enforcement of a per se statute is a matter that has been determined as policy by the Legislature, and a defendant's expert witness may not invite a jury to nullify that determination in the manner at issue here. View "People v. Vangelder" on Justia Law

At issue in this case was the section of the Labor Code (article 2.3) that establishes a process for employees who dispute the diagnosis or treatment provided by a medical provider network (MPN). Petitioner was injured when she fell at work. Petitioner began treatment with a physician in Employer's MPN, but later undertook treatment with a doctor outside the network, Dr. Nario. Thereafter, Petitioner applied for temporary disability benefits, relying on reports by Dr. Nario. Employer argued that reports from non-MPN doctors were inadmissible under Cal. Labor Code 4616.6, an article 2.3 provision, for purposes of the disability hearing. The workers' compensation judge (WCJ) overruled the objection, concluding that reports from all treating doctors were admissible. The Workers' Compensation Appeals Board (Board) rescinded the WCJ's decision, holding that section 4616.6 precluded the admission of reports from any doctor outside the MPN. The court of appeal annulled the Board's decisions. The Supreme Court affirmed, holding that section 4616.6 restricts the admission of medical reports only in proceedings under article 2.3 to resolve disputes over diagnosis and treatment within an MPN. View "Valdez v. Workers' Comp. Appeals Bd." on Justia Law

Appellant was convicted of battery with serious bodily injury and sentenced to two years in prison. Before Appellant was released on parole he was required to accept treatment as a mentally disordered offender (MDO). The Board of Parole Hearings affirmed Appellant's certification as an MDO. The superior court determined that Appellant met the criteria of an MDO and ordered him to be committed to the State Department of State Hospitals for an additional year. The court of appeal reversed the judgment classifying Appellant as an MDO and ordered a new hearing, concluding that insufficient evidence supported the finding that Appellant had been evaluated and certified by the personnel specified in Cal. Penal Code 2962, which requires civil commitment of a state prisoner during and after parole if certain criteria are met. The Supreme Court reversed, holding that the evaluation and certification provisions of section 2962 specify the procedures by which an MDO determination is initiated but do not constitute the statutory criteria by which the trier of fact at a hearing decides whether a prisoner is or is not an MDO. Remanded. View "People v. Harrison" on Justia Law

Developer sought to build ninety-six condominiums, but as a condition of obtaining a permit to do so, City required Developer to set aside ten condominium units as below market rate housing and make a substantial payment to a city fund. Developer challenged these requirements but did so while proceeding with construction. At issue before the Supreme Court was whether Cal. Gov't Code 66020, which permits a developer to proceed with a project while also protesting the imposition of "fees, dedications, reservations, or other exactions," applied in this case. The lower courts held that section 66020 did not apply, and thus, the action was untimely. The Supreme Court reversed, holding that even if the requirements at issue in this case were not "fees" under section 66020, they were "other exactions," and accordingly, Developer was permitted to challenge the requirements while the project proceeded. View "Sterling Park, LP v. City of Palo Alto" on Justia Law

Plaintiff filed an action against Defendant for breach of fiduciary duty and defamation, among other claims. Defendant cross-complained for defamation. Plaintiff later conceded he could not proceed on his cause of action for breach of fiduciary duty. The parties agreed to dismiss as well their respective defamation claims without prejudice and to waive operation of the statute of limitations on the defamation claims. The trial court ordered Plaintiff's action dismissed with prejudice with the exception of the defamation cause of action, which, together with Defendant's cross-complaint, the court dismissed without prejudice. The court then entered judgment in favor of Defendant. The court of appeal held the judgment final and appealable, reasoning that because the defamation counts had been dismissed, they were no longer pending between the parties and the trial court lacked jurisdiction to proceed further on any cause of action. The Supreme Court reversed, holding that, under Don Jose's Restaurant, Inc. v. Truck Ins. Exchange, the trial court's judgment was interlocutory, and therefore, not appealable. View "Kurwa v. Kislinger" on Justia Law

Defendant was arrested and charged for unlawful transportation of marijuana and unlawful possession of marijuana for purposes of sale. In his defense, Defendant claimed he possessed the marijuana lawfully for purposes of medical treatment. After a jury trial, Defendant was convicted as charged. Defendant appealed, arguing that the evidence at trial was insufficient to establish his intent to sell because the expert who gave his opinion at trial lacked experience distinguishing between lawful possession for medical use and unlawful possession for purposes of sale. The Supreme Court affirmed, holding (1) Defendant forfeited his argument that the expert's opinion was inadmissible because the witness was unqualified by failing to object at trial to the witness's qualifications; and (2) the evidence was sufficient to sustain Defendant's convictions. View "People v. Dowl" on Justia Law

Defendant was charged with murder and use of a deadly weapon. The trial court gave instructions on first and second degree murder, as well as voluntary manslaughter based upon a sudden quarrel or heat of passion. The jury found Defendant guilty of second degree murder with a use enhancement. The court of appeal reversed Defendant's conviction, concluding that the voluntary manslaughter instruction was prejudicially erroneous. The Supreme Court reversed after clarifying what kind of provocation will suffice to constitute heat of passion and reduce a murder to manslaughter, holding (1) provocation is adequate only when it would render an ordinary person of average disposition "liable to act rashly or without due deliberation and reflection, and from this passion rather than judgment; and (2) although the jury instruction properly conveyed the standard for determining heat of passion, the argument of counsel may have introduced ambiguity, but the jury asked a clarifying question, and the trial court's response dispelled any confusion. Remanded. View "People v. Beltran" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, unlawful taking of a vehicle, and arson. The jury returned a verdict of death. The trial court sentenced Defendant to death on the murder count and imposed a determinate sentence on the remaining counts and enhancements. The Supreme Court affirmed, holding, (1) the trial court properly denied Defendant's motions for a change of venue; (2) the trial court did not err in its rulings regarding the selection of the jury; (3) the trial court did not prejudicially err in its decisions during the guilt phase of trial; (3) the trial court did not prejudicially err in its decisions during the penalty phase of trial; and (4) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Harris" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, two counts of attempted murder, and of committing forcible rape, sodomy, and oral copulation. Following a penalty trial, Defendant was sentenced to death. The Supreme Court affirmed in all respects, holding (1) the trial court did not err in its pretrial rulings contested by Defendant; (2) the trial court did not err in its rulings made during the guilt phasel; (3) the trial court did not err when instructing the jury during the guilt phase; (4) the trial court did not err during the penalty phase of the trial; and (5) having found no legal error, Defendant's claim that the cumulative effect of all errors required reversal was rejected. View "People v. Jones" on Justia Law

After a jury-waived trial, Defendant was convicted of first degree murder. The court found true the special circumstance that the killing was intentional and that Defendant knew or should have known the victim was a peace officer engaged in the performance of duty. After a penalty jury returned a death verdict, Defendant was sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) Defendant's counsel did not labor under a conflict of interest or provide ineffective assistance; (2) the evidence supporting the special circumstance finding that Defendant intentionally killed a police officer engaged in the performance of duty was legally sufficient; (3) a certain juror was not biased on the issue of penalty; (4) substantial evidence supported the race-neutral reasons given by the prosecutor for his excusal of African-American prospective jurors; (5) the trial procedures did not deny Defendant reliable determinations of death eligibility and of the appropriate penalty; and (6) California's death penalty statute is not unconstitutional. View "People v. Mai" on Justia Law