Justia California Supreme Court Opinion Summaries

Cal. Lab. Code 4558 contains a power press exception to the general rule that workers' compensation is the exclusive remedy of an injured worker against the employer. Employee was injured while operating a power press without a point of operation guard. Employee and his wife (Spouse) brought a civil suit against Employer under the power press exception that included a claim for loss of consortium on behalf of Spouse, predicated on the facts allegedly establishing a section 4558 violation. The trial court sustained Employer's demurrer to all of Spouse's causes of action except her claim for loss of consortium. The court of appeal disagreed with the trial court, concluding Spouse could plead a claim for damages for loss of consortium because such a claim fell outside the workers' compensation laws and hence was not barred by the exclusivity rule. The Supreme Court (1) reversed the portion of the judgment of the court of appeal as to Spouse's consortium claim, holding that where the worker's power press injuries do not prove fatal, the Legislature has restricted standing to bring the action at law authorized under section 4558 to the injured worker alone; and (2) affirmed in all other respects. Remanded. View "LeFiell Mfg. Co. v. Superior Court" on Justia Law

An owners association for a construction defect action against a condominium developer, seeking recovery for damage to its property and damage to the separate interests of the condominium owners who composed its membership. In response, the developer filed a motion to compel arbitration based on a clause in the recorded declaration of covenants, conditions, and restrictions providing that the association and the individual owners agreed to resolve any construction dispute with the developer through binding arbitration. The trial court determined that the clause embodied an agreement to arbitrate between the developer and the association but invalidated the agreement upon finding it marked by slight substantive unconscionability and a high degree of procedural unconscionability. The court of appeal affirmed. The Supreme Court reversed, holding that the arbitration clause bound the association and was not unconscionable. View "Pinnacle Museum Tower Ass'n v. Pinnacle Market Dev." on Justia Law

In 2007, sixteen-year-old Defendant opened fire on three teenage boys who were members of a rival gang. A jury convicted Defendant of three counts of attempted murder. The jury found true that Defendant personally and intentionally discharged a firearm and inflicted great bodily harm on one victim and that Defendant committed the crimes for the benefit of a criminal street gang. Defendant's total sentence was 110 years to life. The court of appeal affirmed. At issue before the Supreme Court was whether the sentence contravened the mandate in Graham v. Florida against cruel and unusual punishment of juveniles convicted of nonhomicide offenses and sentenced to life imprisonment without the possibility of parole. The Court reversed, holding that consistent with the U.S. Supreme Court's holding in Graham, sentencing a juvenile offender for a nonhomicide offense to a term of years with a parole eligibility date that falls outside the juvenile offender's natural life expectancy constitutes cruel and unusual punishment in violation of the Eighth Amendment. View "People v. Caballero" on Justia Law

After a jury trial, Defendant, who spoke Spanish, was convicted of first degree murder. At issue on appeal was whether, while Defendant was in custody and after a law enforcement officer read Defendant his Miranda rights, Defendant's response to whether a detective could speak to Defendant was sufficiently ambiguous to justify the officer in seeking to clarify whether Defendant was attempting to invoke his right to counsel, or whether he was desirous of waiving his Miranda rights and speaking with the detective without an attorney present. The trial court concluded that Defendant's waiver of Miranda rights was voluntary, knowing and intelligent. The court of appeals reversed. The Supreme Court reversed, holding (1) Defendant's reply to the officer's inquiry was sufficiently ambiguous to justify her seeking further clarification of his intent, consistent with the Court's holding in People v. Williams; (2) Defendant's responses made clear he was willing to speak with the detective at that time without an attorney present; and (3) therefore, under the totality of the circumstances, Defendant's waiver of Miranda rights, including his right to counsel, was voluntary, knowing, and intelligent. View "P. v. Sauceda-Contreras" on Justia Law

This case considered complex questions of insurance policy coverage interpretation in connection with a federal court-ordered cleanup of the state's Stringfellow Acid Pits waste site. The Supreme Court affirmed the court of appeal's judgment, holding (1) the "continuous injury trigger" and "all sums" rule announced in Montrose Chemical Corp. v. Admiral Ins. Co. and Aerojet-General Corp. v. Transport Indemnity Co. applied to the State's successive property or long-tail first party property loss, triggering the duty to indemnify here; and (2) the court of appeal correctly applied the "all-sums-with-stacking" allocation rule in allocating the indemnity duty among the insurers responsible for covering the property loss. View "State v. Cont'l Ins. Co." on Justia Law

A jury convicted Defendant Richard Valdez of five counts of first degree murder. As to each count, the jury found true special circumstance allegations of multiple murder and gang and weapon enhancement allegations. The evidence presented at trial established that Defendant was a member of the Sangra street gang. The jury returned a verdict of death as to each of the victims. The trial court denied the automatic application to modify the verdict and sentenced Defendant to death for the five murders. The Supreme Court affirmed, holding, among other things, that Defendant's claims alleging numerous errors in connection with protective orders the trial court issued delaying and limiting disclosure of the identities of certain prosecution witnesses failed, and that the trial judge did not prejudicially err in refusing to declare a mistrial after the jurors declared they were at an impasse and could not reach a unanimous verdict on any count. View "People v. Valdez" on Justia Law

Defendant, an ex-felon on probation, planted an object near a government building that resembled a bomb and that caused fear and disruption when discovered. Defendant was convicted of violating Cal. Penal Code 148.1(d), which allows misdemeanor or felony punishment for anyone who maliciously places a false bomb with the intent to cause another person to fear for his own safety or the safety of others. Defendant's sentence included a twenty-five-years-to-life three strikes term based on the section 148.1(d) felony count and his prior serious and violent felony convictions. The court of appeal reduced the section 148.1(d) conviction to a misdemeanor, finding that the felony provision under which Defendant was convicted and sentenced denied him equal protection of the law when compared to an entirely different statute, Cal. Penal Code 11418.1, which provides that anyone who places a WMD with the intent to cause fear in others can be convicted of a felony only if the perpetrator's conduct causes another person to be placed in sustained fear, an element not necessary under the false bomb statute. The Supreme Court reversed, holding that no equal protection violation occurred, as the challenged distinction was not irrational. View "People v. Turnage" on Justia Law

The Minor in this case was the subject of several delinquency petitions. Minor was eventually placed in foster care. Minor appealed, arguing the dispositional order placing him in foster care had to be reversed because the juvenile court had failed to comply with the notice requirements of the Indian Child Welfare Act (INCA). The court of appeals affirmed, holding notice was not required because federal law specifically excludes delinquency cases from ICWA, and any interpretation of California law that would expand ICWA's application to delinquencies would be invalid under federal preemption principles. The Supreme Court affirmed, holding (1) California law requires the court to inquire about a child's Indian status at the outset of all juvenile proceedings, but ICWA's additional procedures are not required in most delinquency cases; (2) a delinquency court must ensure that notice is given and other ICWA procedures are complied with only under certain circumstances; and (3) assuming Minor was an Indian child, the juvenile court did not err in failing to give notice under ICWA in this case. View "People v. W.B." on Justia Law

A jury convicted Defendant of the first degree murder of a Los Angeles County sheriff's deputy. The jury found true the special circumstance allegations that Defendant committed the murder to avoid a lawful arrest and that he knew or should have known that the victim was a peace officer performing his duties. The jury also found that Defendant was armed with and personally used a firearm during the offense. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment after examining (1) pretrial and guilt phase issues, (2) penalty phase issues, and (3) challenges to the death penalty law, holding that the trial court correctly convicted and sentenced Defendant. View "People v. Duenas" on Justia Law

A jury convicted Defendant of first degree murder and found true the robbery-murder and burglary-murder special circumstance allegations. The jury also convicted Defendant of first degree robbery, first degree burglary, and kidnapping for robbery, finding as to these counts that the victim was sixty-five years or older. The jury additionally convicted Defendant of two counts of second degree burglary. The trial court imposed a sentence of death for the murder. With respect to the remaining counts, the trial court imposed, among other things, the upper term of nine years for carjacking plus one year for the elderly victim enhancement. The Supreme Court affirmed the death judgment as modified, concluding that the judgment should be modified to stay the sentence on the carjacking count, as Defendant could not be punished for both carjacking and kidnapping for robbery because the prosecutor argued to the jury that the victim's car was the object of the robbery. View "People v. McKinzie" on Justia Law