Justia California Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of the first degree murder of Monique Cleveland, the willful, deliberate, and premeditated attempted murder of Robert Cleveland, and being a felon in possession of a firearm. After a penalty retrial, the jury returned a verdict of death on the murder conviction. The Supreme Court affirmed, holding that (1) any error on the trial court’s part in ordering Defendant to wear a stun belt during his trial was harmless because there was no reasonable possibility that Defendant would have received a more favorable verdict had the trial court not required him to wear a stun belt; (2) the evidence was sufficient to support Defendant’s convictions; and (3) the trial court did not commit reversible error in its rulings during the penalty retrial. View "People v. Jackson" on Justia Law

After a jury trial, Defendant was convicted of resisting an executive officer in the performance of his duties pursuant to Cal. Penal Code 69. Defendant appealed, arguing that the trial court erred by denying his request to instruct the jury that it could instead convict him of the lesser offense of resisting a public officer under Cal. Penal Code 148(a)(1). The Supreme Court affirmed, holding (1) section 148(a)(1) was a necessarily included lesser offense of section 69 as alleged in the amended information; but (2) because substantial evidence did not reveal Defendant violated section 148(a)(1) without also violating section 69, the trial court did not err in refusing to instruct the jury on section 148(a)(1). View "People v. Smith" on Justia Law

Defendants were part of a Bakersfield gang and were involved in various retaliatory shootings against perceived rivals. After a jury trial, Defendants were convicted of, inter alia, first degree murder with multiple-murder and gang-murder special circumstances, active gang participation, and conspiracy. The conspiracy count alleged that each Defendant had engaged in conspiracy to commit felony assault, robbery, murder, and gang participation. The court of appeals affirmed the conspiracy convictions, holding that conspiracy to actively participate in a criminal street gang did not qualify as a crime, but each conspiracy count was also based on the valid theory of conspiracy to commit murder. The Supreme Court reversed, holding that that a defendant may conspire to actively participate in a criminal street gang and may be separately charged once a conspirator has committed an overt act. Remanded. View "People v. Johnson" on Justia Law