Justia California Supreme Court Opinion Summaries

Plaintiff filed a complaint against Defendants, a hospital and doctors, alleging negligence. The hospital was owned by the County. The County filed a motion for summary judgment, alleging that Plaintiff failed to comply with the Government Claims Act (Act) because her claim was never presented to or received by a statutorily designated recipient. Plaintiff responded by arguing that she had substantially complied with the Act by delivering a letter of intent to the risk management department of the hospital and that the letter was received by the County risk management department. The trial court granted the County's summary judgment motion, holding that the County made a sufficient showing of noncompliance. The court of appeal reversed, holding (1) a claim may substantially comply with the Act, notwithstanding failure to deliver it to one of the statutorily specified recipients, if it is given to a department whose functions include the management or defense of claims against the defendant entity, and (2) Plaintiff had "substantially complied" with the presentation requirements of the Act. The Supreme Court reversed, holding (1) the court of appeals erred by judicially expanding the statutory requirements; and (2) a claim must satisfy the express delivery provisions language of the statute. View "DiCampli-Mintz v. County of Santa Clara" on Justia Law

This case involved the constitutional limits of a vehicle search based on a passenger's parole status. Here, an officer, aware that the front seat passenger was on parole, searched the back seat of Defendant's car and recovered drugs and drug paraphernalia from a chips bag and a pair of shoes. Defendant, the driver, sought to suppress that evidence. Defendant's suppression motion was denied, and Defendant pleaded guilty to four misdemeanor counts. The court of appeal reversed, holding that the search could not be justified on the basis of the front seat passenger's parole status. The Supreme Court reversed, holding that the search was reasonable under the Fourth Amendment where (1) the Constitutional permits a search of those areas of the passenger compartment where the officer reasoanbly expects that the parolee could have stowed personal belongings or discarded items when aware of police activity; and (2) additionally, the officer may search personal property located in those areas if the officer reasonably believes that the parolee owns those items or has the ability to exert control over them. View "People v. Schmitz" on Justia Law

Defendant and five others carried out the September 1985 murders of Vera and Gerald Woodman in California. In a federal prosecution against Defendant, a jury in 1991 convicted him of murder for hire, for which he was sentenced to life imprisonment. Thereafter, Defendant unsuccessfully requested the Los Angeles County Superior Court to dismiss the murder charges then pending against him in this case, asserting that Cal. Penal Code 656's prohibition against double jeopardy precluded the California prosecution because it was founded upon the same act that was the basis of his earlier conviction in federal court. A majority of the California Supreme Court upheld the trial court's rejection of Defendant's claims and affirmed Defendant's capital murder convictions, holding (1) unlike the preceding murder-for-hire federal prosecution, the California murder charges against Defendant included a lying-in-wait special-circumstance allegation, and thus, the California charges against Defendant required proof of conduct that was not required for conviction of the earlier federal charges; and (2) Defendant's remaining allegations of error did not result in prejudice to Defendant. View "People v. Homick" on Justia Law

Petitioner was convicted in 1997 for the murder of his wife. Petitioner subsequently sought habeas corpus relief, stating that his murder conviction was based on false evidence given at trial by the prosecution's dental expert. The dental expert stated that he had testified inaccurately at trial. Other dental experts agreed that the expert had testified inaccurately based on newly available computer technology. After an evidentiary hearing, the superior court granted habeas corpus relief. The court of appeals disagreed. At issue on appeal was whether a conviction is based on "false evidence" when it depends in part on the opinion of an expert witness, and posttrial advances in technology have raised doubts about the expert's trial testimony without conclusively proving that testimony to be untrue. The Supreme Court affirmed, holding (1) in such circumstances the expert's trial testimony was not shown to be "false evidence," but the information garnered from technological advances could be presented as newly discovered evidence in support of habeas corpus relief; and (2) habeas corpus relief should be granted only if the new evidence points unerringly to innocence or reduced culpability, a showing that Petitioner did not make. View "In re Richards" on Justia Law

This controversy arose after the City of Los Angeles refused to accept Pacific Palisades Bowl Mobile Estates's application to convert its 170-unit mobilehome park from tenant occupancy to resident ownership because Palisades Bowl had failed to include applications for a coastal development permit or for Mello Act approval. Palisades Bowl filed a petition for writ of mandate and a complaint for injunctive and declaratory relief. The trial court granted the relief, commanding the City to evaluate the application for approval without considering whether it complied with either the California Coastal Act or the Mello Act. The court of appeal reversed. The Supreme Court affirmed, holding that the requirements of the Coastal Act and the Mello Act apply to a proposed conversion, within California's coastal zone, of a mobilehome park from tenant occupancy to resident ownership. In so holding, the Court rejected the argument that such a conversion is not a "development" for the purposes of the Coastal Act and that Cal. Gov't Code 66427.5 exempts such conversion from the need to comply with other state laws, or precludes local governmental agencies from exercising state-delegated authority to require compliance with state laws such as the Coastal Act or the Mello Act. View "Pac. Palisades Bowl Mobile Estates, LLC v. City of Los Angeles" on Justia Law

A small dental implant company sued a university for breach of a contract for the university to clinically test a new implant the company had patented. The company sought damages for lost profits beginning in 1998, ranging from $200 million to over $1 billion. It claimed that, but for the university's breach of the contract, the company would have become a worldwide leader in the dental implant industry and made many millions of dollars a year in profit. Following an evidentiary hearing, the trial court excluded as speculative the proffered testimony of an expert to this effect. A jury found that USC had breached the contract and awarded the company $433,000 in compensatory damages. The court of appeal reversed, holding that the trial court erred in excluding the testimony. The Supreme Court reversed, holding that the expert testimony was speculative, and the trial court acted within its discretion when it excluded the testimony. View "Sargon Enters., Inc. v. Univ. of S. Cal." on Justia Law

Defendant was convicted on two counts of possessing a firearm after conviction of a felony in violation of Cal. Penal Code 12021(a)(1) and two counts of possession a firearm after conviction of a specified violent offense in violation of Cal. Penal Code 12021.1(a). All four counts were based on Defendant's simultaneous possession of two firearms. The court of appeal reversed Defendant's section 12021.1(a) convictions, finding that violent offender in possession under section 12021.1(a) was a necessarily included offense of offender in possession under section 12021(a)(1). The Supreme Court reversed, holding (1) Defendant was properly convicted of both offenses because neither section 12021.1(a) nor section 12021(a)(1) is a necessarily included offense of the other; and (2) Defendant may be separately punished for two violations of section 12021(a)(1) and of section 12021.1(a) based on his simultaneous possession of two firearms, but he may not also be separately punished for violations of section 12021(a)(1) and section 12021.1(a) based on possession of the same firearm. Remanded. View "People v. Sanders" on Justia Law

This case involved a dispute between Los Angeles County (County) and forty-seven cities (Cities) within County regarding how County calculated and imposed property tax administration fees on Cities for their share of County's costs in administering the property tax system. Cities petitioned the trial court for a writ of administrative mandate ordering County and its auditor-controller to reimburse Cities for the amount disputed in fiscal year 2006-2007. Following a trial, the referee ruled that County's method of calculating the disputed fee was consistent with legislative intent and did not violate Cal. Rev. & Tax. Code 97.75. The court of appeal reversed, relying almost exclusively on the plain meaning of section 97.75 to conclude that County's method of calculation was unlawful. The Supreme Court affirmed, holding that County's method of calculating property tax administration fees violated the statutory scheme. View "City of Alhambra v. County of Los Angeles" on Justia Law

While in Defendant's care, Defendant's young son died of shock and hemorrhage due to blunt force trauma. A jury convicted Defendant of involuntary manslaughter and assault on a child causing death. As relevant here, the court of appeal reversed the conviction upon finding the trial court erroneously failed to instruct the jury, sua sponte, on simple assault as a lesser included offense. The Supreme Court reversed and remanded with directions to reinstate the conviction, holding that the trial court had no sua sponte duty to instruct on that lesser offense, as (1) such instructions are required only when there is substantial evidence that, if the defendant is guilty at all, he is guilty of the lesser offense, but not the greater; and (2) here, it would be speculative at best to construe the trial evidence in this case as supporting a verdict of only simple assault. View "People v. Wyatt" on Justia Law

Prison regulations promulgated by the California Department of Corrections and Rehabilitation (CDCR) provide that validation of an inmate as a gang member or associate can result in the inmate's placement in a security housing unit. The current dispute arose when the CDCR validated Petitioner as a gang associate. Petitioner filed a petition for writ of habeas corpus, which the superior court denied. The court of appeal granted relief based on a disagreement with the CDCR over the interpretation of the CDCR's regulation. The Supreme Court reversed, holding that the court of appeal failed to accord due deference to the CDCR's interpretation of its own regulations. View "In re Cabrera" on Justia Law