Justia California Supreme Court Opinion Summaries

Cal. Penal Code former section 1202.2(a) provided that the revocation of probation, "summary or otherwise, shall serve to toll the running of the probationary period." At issue in this case was whether, once probation has been summarily revoked, this tolling provision permits a trial court to find a violation of probation and then reinstate or terminate probation based solely on conduct that occurred after the court-imposed period of probation has elapsed. In this case, a three-year probation period was imposed on Defendant in 2000. In 2001, Defendant's probation was summarily revoked based on failure to report. Defendant failed to report or appear in court because he had been deported. The trial court later extended Defendant's probation as of 2007, after the expiration of the original three-year probationary period. In 2009, the court extended Defendant's probation and imposed a prison sentence based on conduct that occurred later in 2009. The court of appeal upheld the trial court's orders. The Supreme Court reversed, holding that section 1203.2(a)'s tolling provision preserves the trial court's authority to adjudicate, in a subsequent formal probation violation hearing, whether the probationer violated probation during, but not after the court-imposed probationary period. View "People v. Leiva" on Justia Law

Defendant was charged with sexually molesting two victims. A jury convicted Defendant of some counts involving one victim but deadlocked on all counts involving the other victim. Nevertheless, the jury returned a true finding on an allegation that Defendant had committed offenses against multiple victims. Believing the jury's true finding was in error, the trial court ordered further deliberations. The jury eventually returned with a blank verdict form and indicated it had deadlocked on the multiple victim allegation. A mistrial was declared, and Defendant was retried. A second jury convicted Defendant of counts involving the other victim and found true the multiple victim allegation. The court reversed the second jury's true finding on the multiple victim allegation, concluding that double jeopardy principles barred Defendant's retrial on the multiple victim allegation. The Supreme Court reversed, holding that because the first jury had no authority to decide or even to consider the multiple victim allegation after it deadlocked on the counts involving the other victim, no valid verdict could have been rendered on that allegation, and thus double jeopardy did not bar retrial on that allegation. View "People v. Carbajal" on Justia Law

Defendant was convicted of robbery and kidnapping for purposes of robbery on evidence from which a jury could have determined an accomplice, rather than Defendant, personally performed the act of asportation necessary to the offense of kidnapping. Defendant appealed, contending that the trial court erred in failing to instruct, sua sponte, on the law of accomplice liability. The court of appeal affirmed, holding that the trial court was obliged to instruct in principles of accomplice liability as to the kidnapping charge, but the error was harmless. The Supreme Court affirmed, holding (1) the trial court was required to instruct on aiding and abetting liability as a general legal principle raised by the evidence and necessary for the jury's understanding of the case; but (2) the error was harmless, as no reasonable probability existed of a more favorable outcome had accomplice liability instructions been given. View "People v. Delgado" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder with personal use of a firearm. After a penalty trial, the jury returned a verdict of death. The trial court denied the automatic motion to modify the verdict and imposed that sentence. The Supreme Court affirmed, holding (1) the trial court did not prejudicially err in any of its jury selection rulings; (2) the trial court did not prejudicially err in its guilt phase rulings; (3) the trial court did not prejudicially err in its penalty phase rulings; and (4) California's death penalty law and related instructions are constitutional. View "People v. Pearson" on Justia Law

Upon the State's petition to commit Defendant as a sexually violent predator (SVP) under the Sexually Violent Predator Act (SVPA), the trial court allowed the disclosure of Defendant's psychological records and determined that Defendant's therapist could testify at the SVPA trial. After a jury trial, Defendant was found to be an SVP and was committed to the State Department of Mental Health. The court of appeal reversed. The Supreme Court reversed, holding (1) the trial court erred in permitting disclosure of Defendant's psychological records and in admitting his former therapist's testimony in reliance upon the dangerous patient exception to the psychotherapist-patient privilege; (2) however, the court of appeals erred in determining that this error constituted an error of federal constitutional dimension, and the error must properly be evaluated under the prejudicial error standard; and (3) applying that standard, the trial court error was not prejudicial and did not require reversal. View "People v. Gonzales" on Justia Law

After a jury trial, Defendant was convicted of first degree murder under a felony-murder theory that the victim was killed during the commission of a burglary. During trial, the court instructed the jury that in order for the felony-murder rule to apply, the burglary and the act causing the death must be part of one "continuous transaction." The court refused Defendant's request that the jury be instructed that, for purposes of felony murder, the felony continues only until the perpetrator has reached a place of temporary safety. The court of appeal found no error in the trial court's refusal to instruct the jury on the "escape rule" and affirmed. The Supreme Court reversed, holding that it was prejudicial error to refuse the instruction on the escape rule. Remanded. View "People v. Wilkins" on Justia Law

In 1983, Petitioner was convicted of numerous violent felonies and sentenced to life in prison with the possibility of parole, consecutive to a determinate term of thirty-seven years. In 2008, California voters approved Marsy's Law, which increased the period of time between parole hearings. In 2009, the Board of Parole Hearings found Petitioner unsuitable for parole and concluded he should be denied another parole hearing for five years. Petitioner filed a writ of habeas corpus, contending that application of the new parole procedures to prisoners who committed their crimes prior to the enactment of Marsy's Law violated the ex post facto clauses of the federal and state Constitutions. The court of appeals agreed and vacated the Board's order in part. The Supreme Court reversed, thus rejecting Petitioner's constitutional challenges to Marsy's Law, holding (1) the changes to the parole process effected by Marsy's Law do not, on their face, create a significant risk that life prisoners' incarceration will be prolonged; and (2) Marsy's Law is valid as applied to Defendant. The Court declined to address whether Marsy's Law violated ex post facto principles as applied to life prisoners whose commitment offenses occurred before the passage of Marsy's Law. View "In re Vicks" on Justia Law

Plaintiffs, including a California corporation (Corporation), filed a lawsuit for property damage against Defendants. Before trial, Defendants learned the state had suspended Corporation's corporate powers for nonpayment of taxes. A jury returned a verdict in favor of Defendants. Plaintiffs, including Corporation, appealed. On December 1, 2011, Defendants filed separate motions to dismiss Corporation's appeals because its corporate powers were still suspended. Corporation presented documentation showing its corporate powers had been revived on December 8, 2011 and argued that this revival made its appeal effective. The court of appeals denied the motions. Defendants petitioned for review. At issue was whether a corporation that files notices of appeal while its corporate powers are suspended may proceed with the appeals after those powers have been revived, even if the revival occurs after the time to appeal has expired. Relying on precedent, the Supreme Court affirmed, holding that the appeals may proceed. View "Bourhis v. Lord" on Justia Law

Plaintiffs filed a complaint for personal injuries and loss of consortium against Defendant corporation and other entities, alleging injuries from exposure to asbestos. Defendant demurred, alleging that more than three years before Plaintiffs filed their complaint, it had obtained a corporate dissolution pursuant to the laws of Delaware, Defendant's state of incorporation. Accordingly, Defendant argued, it lacked the capacity to be sued pursuant to Delaware's three-year survival statute. In opposition, Plaintiffs argued their action was permitted under California's own survival statute, which they asserted took precedence over Delaware law in this situation. The trial court sustained the demurrer and dismissed Plaintiffs' complaint, ruling that California's survival statute did not apply to foreign corporations, and hence Delaware's corresponding statute applied to Defendant. The court of appeal affirmed. The Supreme Court affirmed, holding (1) California's survival statute does not apply to foreign corporations; and (2) North American Asbestos Corp. v. Superior Court was disapproved of to the extent it held otherwise. View "Greb v. Diamond Int'l Corp." on Justia Law

Defendant was convicted of two counts of first degree murder. Defendant was sentenced to death. The Supreme Court affirmed the judgment, holding (1) the trial court's excusal of a prospective juror for cause was not prejudicial error; (2) the trial court did not prejudicially err in the guilt phase of the proceedings; (3) the trial court did not prejudicially err in the penalty phase of the proceedings; (4) no error, either alone or in conjunction with others, prejudiced Defendant; and (5) California's death penalty does not violate the Eighth Amendment or international law, including the International Covenant on Civil and Political Rights. View "People v. Williams" on Justia Law