Justia California Supreme Court Opinion Summaries

Plaintiff filed an action to quiet title to a parcel of real property, alleging he owned the property because he had been the highest bidder at a trustee's sale. After Plaintiff gave the auctioneer his cashier's check at the sale, the trustee told Plaintiff the sale was void. The trustee based its refusal on its discovery that it had mistakenly communicated to the auctioneer an incorrect opening bid by the lender that was less than ten percent of the actual amount of the bid. After the trustee refused to tender the deed to Plaintiff, Plaintiff filed this action. The trustee moved for summary judgment on the ground that it had properly set aside the foreclosure sale due to a significant procedural irregularity in the statutory foreclosure process coupled with an inadequate sales price. The trial court ultimately granted the motion. The court of appeals reversed, holding that the trustee's error was not a procedural irregularity in the statutory foreclosure process and that the trustee therefore had no discretionary authority to void the foreclosure sale. The Supreme Court reversed, holding that, under the circumstances here, the trustee acted within its discretion authority in declaring the sale void. View "Biancalana v. T.D. Serv. Co." on Justia Law

After a jury trial, Defendant was found guilty of attempted voluntary manslaughter and assault with a firearm. Defendant waived a jury trial on the prior conviction allegations and admitted having suffered a prior serious felony conviction. Defendant informed the court, however, that the prior conviction had been reduced to a misdemeanor. The court sentenced Defendant to a total term of twenty-four years, which included a five-year sentence enhancement under Cal. Penal Code 667(a) based on Defendant's previously having been convicted of a serious felony. The court of appeal upheld imposition of the five-year enhancement, concluding that the prior assault remained a serious felony conviction for purposes of section 667(a), notwithstanding its having been reduced to a misdemeanor pursuant to Cal. Penal Code 17(b)(3) in 2006 and thereafter dismissed altogether. The Supreme Court reversed the judgment of the court of appeal insofar as it upheld imposition of a five-year sentence enhancement pursuant to section 667(a), holding that when the court in the prior proceeding reduced the assault conviction to a misdemeanor, that offense no longer qualified as a prior serious felony within the meaning of section 667(a), and could not be used to enhance Defendant's sentence. Remanded for resentencing. View "People v. Park" on Justia Law

Defendant (Father) was the father of two daughters and three sons. The juvenile court found that Father sexually abused one of his daughters, I.J., over a three-year period, but there was no evidence or claim that Father sexually abused or otherwise mistreated his three sons. The juvenile court then declared all the children dependents of the court. The court of appeal held that the evidence was sufficient to support the juvenile court's declaration of I.J. and her sister to be dependents of the court but divided on the question of whether the abuse also warranted the court's further declaring I.J.'s brothers to be dependents of the court. At issue before the Supreme Court was whether Father's sexual abuse of I.J. supported a determination that his sons were juvenile court dependents when there was no evidence that Father sexually abused or otherwise mistreated the boys and the boys were unaware of their sister's abuse before this proceeding began. The Supreme Court affirmed, holding that when a father severely sexually abuses his own child, the juvenile court may assume jurisdiction over, and take steps to protect, the child's siblings. View "In re I.J." on Justia Law

After a jury trial, Defendant was found guilty of two first degree murders and two counts of second degree robbery. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) the trial court did not commit prejudicial error in pretrial proceedings, including its denial of three Batson/Wheeler motions; (2) the trial court did not commit prejudicial error during the guilt phase of the trial, including its upholding of the prosecutor's objection to defense counsel's questioning of an accomplice; (3) the trial court did not commit prejudicial err during the penalty phase of the trial; (4) Defendant failed to demonstrate he was prejudiced by trial counsel's assistance, and the remainder of Defendant's ineffective assistance of counsel claims could only be addressed in a habeas corpus petition; and (5) California's death penalty law is constitutional. View "People v. Williams" on Justia Law

The City of Riverside declared, by zoning ordinances, that medical marijuana dispensaries were prohibited within the City. Invoking these provisions, the City brought a nuisance action against a facility operated by Defendants. The trial court issued a preliminary injunction against the distribution of marijuana from the facility. The court of appeal affirmed. Defendants appealed, arguing that the Compassionate Use Act (CUA) and the Medical Marijuana Program (MMP) preempted the City's total ban on facilities that cultivated and distributed medical marijuana in compliance with the CUA and MMP. The Supreme Court affirmed, holding that California's medical marijuana statutes do not expressly or impliedly preempt the authority of California cities and counties, under their traditional land use and police powers, to allow, restrict, limit, or entirely exclude facilities that distribute medical marijuana, and to enforce such policies by nuisance actions. View "City of Riverside v. Inland Empire Patients Health & Wellness Ctr., Inc." on Justia Law

This dispute arose out of a class action lawsuit filed by Plaintiff, a resident of Defendant City, challenging the City's telephone users tax (TUT) and seeking refund of the taxes paid. The trial court ruled that class claims for a refund were barred under Woosley v. State and dismissed the case. The court of appeal reversed in part, holding that Plaintiff could file a class claim for a TUT refund under the recently decided Ardon v. City of Los Angeles. In Ardon, the Supreme Court held that the Government Claims Act (Act) permits a class action claim by taxpayers against a local government entity for the refund of an unlawful tax in the absence of a specific tax refund procedure set forth in an applicable governing claims statute. The City appealed, asserting that its municipal code contained an "applicable governing claims statute" barring class action claims for a tax refund. The Supreme Court affirmed, holding that a local ordinance is not a "statute" within the meaning of the Act. View "McWilliams v. City of Long Beach" on Justia Law

After a jury trial, Defendant was convicted of being an accessory for intentionally aiding a parolee in absconding from parole supervision. Defendant appealed, arguing that the act of assisting a parolee abscond from supervision did not satisfy the statutory definition of being an accessory. The court of appeal disagreed and affirmed her conviction. The Supreme Court affirmed, holding (1) Defendant assisted a parolee in absconding from parole because, under the relevant statute, Defendant aiding a principal in a felony with the intent that the principal could escape punishment; and (2) the court of appeal properly found substantial evidence supported Defendant's conviction. View "People v. Nuckles" on Justia Law

Defendant pleaded no contest to being a convicted felon in possession of a firearm and admitted a prior prison term allegation. The trial court imposed the stipulated prison sentence of four years and ordered Defendant to pay a jail booking fee. Defendant appealed, arguing (1) the statute authorizing the court to impose the booking fee required the court to determine if Defendant was able to pay it, and (2) Defendant was entitled to challenge this fee order for sufficiency of the evidence for the first time on appeal. The court of appeal affirmed the trial court's booking fee order. The Supreme Court affirmed, holding that a defendant who fails to contest the booking fee when the court imposes it forfeits the right to challenge it on appeal. View "People v. McCullough" on Justia Law

Defendant was charged with an assortment of felony and misdemeanor charges, mostly theft related. Over the prosecution's objection, Defendant pleaded no contest to all charges and was sentenced to five years in prison. The court of appeal held that the five-year sentence was the product of an unlawful judicial plea bargain and vacated Defendant's pleas and admissions. The Supreme Court affirmed in part, holding that the record was ambiguous as to whether the sentence proposed by the trial court reflected what the court believed was the appropriate punishment for Defendant and his offenses, regardless of whether Defendant was convicted by plea or following trial, or instead reflected what the court believed was necessary to induce Defendant to enter a plea. Remanded to the trial court to clarify the ambiguity. View "People v. Clancey" on Justia Law

After a jury trial, Defendant was found guilty of making a criminal threat, assault with a deadly weapon, and brandishing a weapon. Defendant was sentenced to a prison term of four years eight months. Defendant appealed, arguing that her state constitutional right to a unanimous jury verdict was violated because the court failed to ask the jury foreperson or the jurors to affirm their verdict as required by Cal. Penal Code 1149. The appeals court agreed, concluding that the error was structural and, thus, reversible per se. The Supreme Court reversed the court of appeal's judgment and affirmed the judgment of the trial court, holding (1) the error was not structural and instead was procedural error subject to harmless error review; and (2) the trial court's failure to follow section 1149's requirement was harmless in this case. View "People v. Anzalone" on Justia Law