Justia Constitutional Law Opinion Summaries

In September 2022, Antoine Leon Richardson had an altercation with Mckyla Middleton at a liquor store in Lancaster, California. Richardson accused Middleton of cutting him off, threatened her, and flashed a gun at her from a satchel. In November 2022, police searched Richardson’s home and found ammunition but no firearms. Richardson admitted to brandishing the gun during the altercation and owning the ammunition.The Los Angeles County Superior Court charged Richardson with being a felon in possession of a firearm, being a felon in possession of ammunition, and misdemeanor exhibiting a concealable firearm in public. The jury found Richardson guilty on all counts and confirmed his prior felony convictions. The court sentenced him to three years and eight months in prison for the firearm and ammunition charges, with a concurrent 364-day term for the misdemeanor.The California Court of Appeal, Second Appellate District, reviewed the case. Richardson argued that his convictions for firearm and ammunition possession violated the Second Amendment, citing New York State Rifle & Pistol Association, Inc. v. Bruen. The court disagreed, stating that the Second Amendment protects law-abiding citizens, not felons. The court also found that substantial evidence supported the trial court’s finding that Richardson had separate objectives for possessing and exhibiting the firearm, thus allowing multiple sentences under Penal Code section 654.The Court of Appeal affirmed the trial court’s judgment, upholding Richardson’s convictions and sentences. View "People v. Richardson" on Justia Law

Michael Lovelace was charged with multiple felonies, including rape and aggravated kidnapping, along with special sentencing enhancements and aggravating factors under California Rules of Court, rule 4.421(c). Lovelace challenged the constitutionality of the rule 4.421(c) residual clause, which allows for consideration of any other factors that reasonably relate to the defendant or the circumstances under which the crime was committed. He argued that this clause violated the separation of powers and due process principles.The trial court denied Lovelace's motion to set aside the information, leading him to seek interlocutory review by petition for a writ of prohibition. The Court of Appeal of the State of California, First Appellate District, Division Four, issued an order to show cause and held oral arguments. Following the Supreme Court's decision in People v. Lynch, which provided guidance on the interpretation and application of Senate Bill 567 amendments to section 1170, subdivision (b)(2), the court took supplemental briefing.The Court of Appeal granted writ relief, holding that the rule 4.421(c) residual clause is unconstitutionally vague and exceeds the Judicial Council’s delegated authority to adopt rules promoting uniformity in sentencing. The court found that the clause grants prosecutors and juries open-ended power to define sentencing criteria on an ad hoc basis, violating the separation of powers clause of the California Constitution. The court directed the trial court to vacate its order denying Lovelace's section 995 motion and to enter a new order sustaining the motion to the extent it seeks to invalidate the residual clause. The court prohibited the trial court from allowing a jury to consider any findings based on the rule 4.421(c) residual clause. View "Lovelace v. Superior Court" on Justia Law

A bakery refused to sell a predesigned white cake to a same-sex couple for their wedding reception, citing a policy against providing cakes for same-sex weddings based on the owner's religious beliefs. The California Civil Rights Department (CRD) filed a lawsuit on behalf of the couple, alleging discrimination under the Unruh Civil Rights Act (UCRA). The trial court ruled in favor of the bakery, finding no violation of the UCRA because the CRD failed to prove intentional discrimination and concluded that referring the couple to another bakery constituted full and equal access under the UCRA. The trial court also considered the bakery's First Amendment defenses, concluding that the UCRA compelled the bakery to speak a message about marriage to which they objected.The CRD appealed, challenging the trial court's interpretation and application of the UCRA and its conclusions regarding the bakery's affirmative defenses. The California Court of Appeal reviewed the case and determined that the bakery's policy was not facially neutral and misconstrued the intentional discrimination standard. The court found that the policy was inherently discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court also concluded that referring the couple to another bakery did not satisfy the UCRA's full and equal access requirement.The court further analyzed the bakery's First Amendment defenses, determining that the cake in question did not constitute pure speech or expressive conduct protected by the First Amendment. The court found that the cake was a generic, multi-purpose product and that its preparation and delivery did not convey any particularized message about marriage. Additionally, the court concluded that the UCRA is a neutral and generally applicable law that satisfies rational basis review and does not violate the bakery's free exercise of religion under the federal or state constitutions.The California Court of Appeal reversed the trial court's judgment and remanded the case for further proceedings consistent with its opinion. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

The Coachella Valley Water District (Water District) appealed a judgment finding that the rates it charged for Coachella Canal water violated Article XIII C of the California Constitution. The Water District argued that the rates were lawful and that no refund remedy was authorized. The court rejected both arguments, finding the rates unlawful and that a refund remedy was constitutionally mandated.In the lower court, the Superior Court of Riverside County ruled that the Water District's Canal Water rates and the Irrigation Water Availability Assessment (IWAA) violated Proposition 218. The court found that the Water District's historical priority argument was not persuasive and that the Water District had made no attempt to show that the rates complied with the California Constitution. The court deferred ruling on remedies and later awarded Class 2 customers approximately $17.5 million in refunds and interest for invalid charges from March 2018 through June 2022.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that Howard Jarvis Taxpayers Association (Howard Jarvis) had standing to challenge the Class 2 rates because domestic customers paid the rates indirectly. The court found that the Class 2 rates were taxes under Article XIII C and did not fall under any exceptions. The court rejected the Water District's arguments that the rates were justified based on historical priority and that they were expenditures of funds. The court also found that the IWAA was an assessment under Proposition 218 and that the Water District failed to show it was proportional to the benefits conferred on the properties.The court affirmed the lower court's ruling on liability and the amount of refund relief awarded. However, the court found that the injunction in the judgment was overbroad and modified the judgment to strike the paragraph enjoining the Water District from imposing any future Canal Water rates and charges that did not comply with Proposition 218. As modified, the judgment was affirmed, and Howard Jarvis was awarded its costs on appeal. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

Christopher Hamilton was convicted of federal felony possession of child pornography. After a federal district court terminated his federal sex offender registration requirement, the California Attorney General notified him of his lifetime obligation to register under California law, pursuant to Penal Code section 290.005(a). The Attorney General determined that the state law equivalent of Hamilton’s federal offense required lifetime registration, placing him in the highest tier of California’s three-tier scheme.Hamilton petitioned the Superior Court of Los Angeles County to terminate his state registration requirement. The Superior Court denied his petition and a subsequent amended motion. Hamilton appealed the denials, arguing violations of equal protection and due process.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the Attorney General’s classification of Hamilton’s offense as a felony with a lifetime registration requirement did not violate equal protection. The court reasoned that the federal offense’s classification as a felony, based on custodial exposure, justified the equivalent state offense’s classification as a felony. Additionally, the court found that the federal offense’s requirement of interstate or foreign commerce provided a rational basis for the different treatment.The court also rejected Hamilton’s due process challenge, concluding that he received notice and had opportunities to contest his tier designation through his petition and amended motion. Lastly, the court dismissed Hamilton’s vagueness challenge, finding that the term “equivalent” in section 290.005(a) was sufficiently clear when considered in context with other statutory provisions.The Court of Appeal affirmed the Superior Court’s orders denying Hamilton’s petition and amended motion. View "People v. Hamilton" on Justia Law

Trevon Bey was convicted by a jury of possession of a firearm by a felon and carrying a loaded firearm in public. The trial court dismissed a prior strike conviction and sentenced Bey to three years for each count, to be served concurrently. Bey appealed, arguing that the trial court improperly revoked his self-representation status, that his conviction for possession of a firearm by a felon violated his Second Amendment rights, and that California's concealed carry laws were unconstitutional under a recent Supreme Court decision.The Superior Court of Los Angeles County initially allowed Bey to represent himself but later revoked this status due to his disruptive behavior and failure to follow court rules. Bey repeatedly challenged the court's authority, disrespected the court, and disrupted proceedings, despite multiple warnings. The court appointed standby counsel to represent him, citing his inability to adhere to courtroom protocol.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the trial court did not abuse its discretion in revoking Bey's self-representation status due to his continuous disruptive conduct. The court also found that Bey's conviction for possession of a firearm by a felon did not violate his Second Amendment rights, referencing recent Supreme Court decisions that upheld prohibitions on firearm possession by felons. Additionally, the court rejected Bey's challenge to California's concealed carry laws, noting that the unconstitutional "good cause" requirement was severable from the rest of the licensing scheme.The Court of Appeal agreed with both parties that the sentence for carrying a loaded firearm in public should be stayed under Penal Code section 654, as it was based on the same act as the possession charge. The court modified the judgment to stay the sentence on count 2 and affirmed the judgment as modified. View "People v. Bey" on Justia Law

Two defendants, Martin Field and John Asher, were found to be sexually violent predators (SVPs) by separate juries and committed indefinitely to a state hospital. They were compelled to testify against themselves during their commitment trials. Both argued on appeal that they were similarly situated to individuals found not guilty by reason of insanity (NGIs), who are not required to testify against themselves at their commitment trials. They claimed this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, previously found merit in Field's equal protection argument and remanded the case to the Superior Court of San Bernardino County for an evidentiary hearing. The same conclusion was reached for Asher's case by Division Three of the Fourth Appellate District. The trial court held an evidentiary hearing and determined that the People had not met their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated and ordered new commitment trials for both Field and Asher.The People appealed the new trial orders, arguing that the trial court erred in finding that the disparate treatment of SVPs was not justified. The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court's orders. The appellate court held that the People had not demonstrated that the testimony of SVPs was more necessary than that of NGIs to justify the disparate treatment under the strict scrutiny standard. The court emphasized that there were sufficient records and other means to evaluate SVPs without compelling their testimony, and thus, the equal protection violation was not justified. View "P. v. Field" on Justia Law

Santa Rita Holdings, Inc. applied for a conditional use permit (CUP) from the County of Santa Barbara to cultivate cannabis on a 2.54-acre parcel owned by Kim Hughes. The only access to the parcel is through a private easement over land owned by JCCrandall, LLC. The County's fire and public works departments deemed the road adequate for the project. Despite JCCrandall's objections, the County granted the CUP, and the Board of Supervisors upheld this decision.JCCrandall petitioned for a writ of administrative mandate, arguing that the use of the easement for cannabis activities was prohibited by the easement deed and federal law, that state law required their consent for such activities, and that the road did not meet County standards. The trial court denied the petition, applying the substantial evidence standard and finding the County's decision supported by substantial evidence.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court determined that the trial court erred in applying the substantial evidence standard instead of the independent judgment standard, as JCCrandall's right to exclude unauthorized persons from their property is a fundamental vested right. The appellate court held that under federal law, cannabis is illegal, and thus, the use of the easement for cannabis transportation exceeds the scope of the easement. The court also found that the County's reliance on Civil Code section 1550.5, subdivision (b), which deems cannabis activities lawful under California law, defies the Supremacy Clause of the U.S. Constitution. Consequently, the judgment was reversed, and costs were awarded to JCCrandall. View "JCCrandall v. County of Santa Barbara" on Justia Law

Appellant M.T., a transgender woman, petitioned to legally change her name and gender in 2017, which was granted by the Stanislaus Superior Court in 2018. In 2023, M.T. requested the court to seal the entire record of her name change and gender marker correction, citing harassment and threats after being "outed" on social media. The trial court denied the request to seal the entire record but sealed the application to seal, its supporting documentation, and a physician's letter attached to the initial petition.The trial court found that M.T. had not shown an overriding interest that would overcome the right of public access to the records. The court noted that California's liberal name change policy presumes name changes should be public to prevent fraud and ensure creditors and others can locate individuals who have changed their names. The court also found insufficient evidence that the harassment M.T. experienced was directly linked to the public availability of her court records.The California Court of Appeal, Fifth Appellate District, reviewed the case and concluded that M.T. had demonstrated an overriding privacy and safety interest in sealing her records. The court found that the harassment and threats M.T. experienced were likely linked to the public availability of her records and that there was a substantial probability of future harm if the records remained unsealed. The appellate court determined that M.T.'s privacy and safety interests outweighed the public's right of access to the records and that sealing the entire record was necessary to protect those interests.The appellate court reversed the trial court's order denying the request to seal the entire record and remanded the case with instructions to seal all records that reveal M.T.'s name change or gender marker correction. View "In re M.T." on Justia Law

Cristian Omar Martinez successfully moved to vacate his conviction and withdraw his plea under Penal Code section 1473.7. He then filed a motion to dismiss the charges against him, which the trial court denied. Martinez appealed, arguing that section 1473.7 does not allow the trial court to reinstate the original charges and that doing so violates the double jeopardy clause of the Fifth Amendment. The Attorney General contended that the order denying Martinez’s motion to dismiss is not appealable and that the trial court did not err in denying the motion.The Santa Clara County Superior Court initially granted Martinez’s motion to vacate his conviction and withdraw his plea. However, when Martinez subsequently moved to dismiss the charges, the trial court denied the motion, stating that section 1473.7 does not provide for dismissal after a plea is set aside.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court agreed with the Attorney General that the order denying the motion to dismiss is not appealable. However, the court exercised its discretion to treat the appeal as a petition for writ of mandate. Upon examining the merits, the court concluded that section 1473.7 does not mandate the dismissal of charges after a conviction is vacated and a plea is withdrawn. The court also found that section 1203.4, which provides for the dismissal of charges upon successful completion of probation, does not preclude the refiling of charges once a conviction is vacated under section 1473.7. Additionally, the court held that the original charges could be reinstated as felonies despite their prior reduction to misdemeanors. The court denied the petition for writ of mandate and directed the parties to proceed on the reinstated information. View "Martinez v. Super. Ct." on Justia Law