Justia Constitutional Law Opinion Summaries

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

Robert Mann, a taxpayer, filed a lawsuit against the State of California and the California Highway Patrol (CHP), challenging CHP’s vehicle impound policies. Mann argued that the impoundment of vehicles without a warrant and inadequate notice procedures constituted illegal expenditures of public funds. He sought declaratory and injunctive relief to prevent what he characterized as wasteful, unlawful, and unconstitutional law enforcement policies. The trial court granted a permanent injunction requiring CHP to consider vehicle owners’ ability to pay towing and storage fees during impound hearings and vehicle release procedures, and to revise its notice form to advise owners of procedures for retrieving impounded vehicles.The Superior Court of Los Angeles County initially reviewed the case. At the close of the plaintiffs’ case, the trial court granted a motion for judgment against Youth Justice Coalition and entered judgment in favor of defendant Warren A. Stanley, who had retired before the trial. The court found that Stanley, as a former public officer, was no longer a proper defendant. The trial court issued a permanent injunction requiring CHP to revise its vehicle impound procedures, including considering the ability to pay and revising notice forms.The Court of Appeal of the State of California, Second Appellate District, Division Two, reviewed the case. The court reversed the trial court’s judgment, holding that the injunction improperly required CHP to contravene valid statutes, relied on inapplicable case law, conflicted with the existing statutory scheme, and mandated unnecessary revisions to its notice procedures. The appellate court concluded that the trial court erred in requiring CHP to conduct ability-to-pay hearings and revise its notice forms, as these requirements were not mandated by due process and conflicted with statutory provisions. The judgment was reversed, and costs on appeal were awarded to the appellant. View "Mann v. State of Cal." on Justia Law

James Lamont Bagsby was convicted and sentenced to 107 years to life for violent crimes committed at age 15. After serving over 15 years, he petitioned for recall and resentencing under Penal Code section 1170(d), which applies to juveniles sentenced to life without parole. Bagsby argued his sentence was the functional equivalent of life without parole, citing People v. Heard, which held that denying such juveniles the opportunity to petition for resentencing violates equal protection. The trial court agreed, granted his petition, and ordered his release, but stayed the release pending appeal.The People appealed, asking the Court of Appeal to strike down the section 1170(d) resentencing provision or reconsider Heard. They also argued the trial court had jurisdiction to resentence Bagsby and erred in ordering his release. Bagsby cross-appealed the stay order.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court's orders. The court upheld Heard, finding no compelling reason to overturn it. The court rejected the People's arguments, noting that the Legislature had not repealed the section 1170(d) resentencing provision despite amendments to related laws. The court also found that the trial court correctly applied Proposition 57 and Senate Bill 1391 retroactively, making Bagsby's judgment nonfinal and placing him outside juvenile court jurisdiction.The court declined to reverse the stay order, noting it would expire upon remittitur, making Bagsby's release effective as of the original release date for custody credit purposes. The court presumed the California Department of Corrections and Rehabilitation would calculate Bagsby's custody credits correctly. View "People v. Bagsby" on Justia Law

The case involves 11 public charter schools (the Schools) seeking to overturn a decision by the Public Employment Relations Board (PERB). PERB found that the Schools violated section 3550 of the Prohibition on Public Employers Deterring or Discouraging Union Membership by sending e-mails that tended to influence employees' decisions regarding union representation by United Teachers Los Angeles (UTLA). The Schools argued that PERB's interpretation of section 3550 was erroneous and that the statute was unconstitutional as it violated free speech protections.The administrative law judge (ALJ) initially dismissed the allegations, finding that the e-mails did not contain threats or promises and thus did not violate the Educational Employment Relations Act (EERA). However, PERB, applying its new interpretation from Regents I and Regents II decisions, found that the e-mails violated section 3550 because they tended to influence employee choice regarding union membership. PERB rejected the Schools' defenses, including claims of business necessity and constitutional free speech rights.The California Court of Appeal, Second Appellate District, reviewed the case. The court upheld PERB's interpretation of section 3550, finding it not clearly erroneous. The court also rejected the Schools' constitutional claims, determining that section 3550 regulates only government speech, which is not protected by the First Amendment or the California Constitution. The court found that the Schools, as public employers, and their administrators and Alliance CMO, as agents, were engaged in government speech when communicating about union matters.The court concluded that substantial evidence supported PERB's findings that the Schools could be held responsible for the e-mails sent by Alliance CMO and the School administrators under theories of actual and apparent authority. The court affirmed PERB's decision and order. View "Alliance Marce & Eva Stern Math & Sci. High Sch. v. PERB" on Justia Law

A Black man, known for his career in the NFL, was accused by an intellectually disabled woman of raping her at gunpoint during a babysitting job interview at his home. The jury found him guilty of forcible rape, forcible oral copulation, and false imprisonment, with firearm use in the first two offenses. He was sentenced to 15 years to life in prison. The prosecution argued that the police did not search his house due to his fame and race, suggesting a search would have caused controversy.The trial began in March 2020 but was paused due to the COVID-19 pandemic, resuming three months later. The jury acquitted him on two counts related to the victim's incapacity to consent. The trial court sentenced him in October 2020. The defendant appealed, arguing that the prosecution's statements violated the California Racial Justice Act of 2020 by appealing to racial bias.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the prosecution violated the Racial Justice Act by explicitly asserting that the defendant's race influenced the police's decision not to search his house, implying he gained an undeserved advantage at trial because he was Black. The court concluded that the prosecution's statements constituted racially discriminatory language under Penal Code section 745, subdivision (a)(2). The court held that Penal Code section 745, subdivision (e)(2)(A) precludes harmless error analysis and mandates vacating the conviction and sentence. Consequently, the court reversed the judgment, vacated the conviction and sentence, and remanded for new proceedings consistent with the Racial Justice Act. View "P. v. Stubblefield" on Justia Law

In March 2011, Prentice Robinson was indicted by a grand jury for multiple criminal counts, including attempted murder, and admitted to using a firearm during the crime. He pleaded no contest to the charges and received a 22-year prison sentence. In January 2022, Robinson filed a petition for resentencing, arguing that the trial court erred in considering grand jury testimony. The People agreed that the grand jury testimony was inadmissible hearsay but disagreed on the proper remedy. The San Joaquin County District Attorney, as amicus curiae, argued that the grand jury transcripts were part of Robinson’s record of conviction and admissible under section 1172.6.The Superior Court of San Joaquin County denied Robinson’s petition for resentencing, finding that the grand jury transcripts were admissible and that Robinson was the direct perpetrator of the attempted murder. Robinson appealed, arguing that the trial court erred in admitting the grand jury testimony and that it violated his Sixth Amendment right to confrontation.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court’s decision. The court held that section 1172.6, subdivision (d)(3) created a hearsay exception for evidence previously admitted at any prior hearing or trial, including grand jury testimony. The court found that the grand jury proceedings were analogous to preliminary hearings and that the procedural safeguards in place ensured the reliability of the testimony. The court also held that the Sixth Amendment right to confrontation did not apply to section 1172.6 hearings, as they are postconviction collateral proceedings. The court concluded that Robinson’s due process rights were not violated, as he had the opportunity to present new evidence and challenge the grand jury testimony at the evidentiary hearing. View "People v. Robinson" on Justia Law

Jose Nunez-Dosangos filed a petition for a writ of habeas corpus challenging his ongoing detention in county jail pending trial on a charge of assault with a semiautomatic firearm. He was later released on his own recognizance after pleading guilty to a new charge of accessory after the fact, rendering his petition moot. However, the court decided to address the case due to its broad public interest and likelihood of recurrence. The petitioner had accrued presentence time-served and conduct credits exceeding the maximum potential sentence for the charged offense, and a probation report assessed him with a low risk of recidivism.The Superior Court of the City and County of San Francisco initially denied bail and set the case for a preliminary hearing. The magistrate judge found insufficient evidence to show the petitioner knew of his co-defendant's intent to use the firearm, leading to the dismissal of the murder charge against him. The People refiled the murder charge, which was again dismissed by the trial court. The petitioner filed multiple motions for release, arguing his prolonged detention violated due process, but the trial court denied these motions, citing public safety concerns and the possibility of refiling the murder charge.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and concluded that the petitioner's pretrial detention was excessive in relation to the government's public safety goals, constituting impermissible punishment in violation of due process principles. The court noted that the length of detention exceeded the maximum potential sentence and that the trial court erred in relying on the possibility of refiling the murder charge. The petition was ultimately dismissed as moot due to the petitioner's release. View "Nunez-Dosangos v. Superior Ct." on Justia Law

Robert Mann, a taxpayer, filed a lawsuit against the State of California and the California Highway Patrol (CHP), challenging CHP’s vehicle impound policies. Mann argued that the impoundment of vehicles without a warrant and inadequate notice procedures constituted illegal expenditures of public funds. He sought declaratory and injunctive relief to prevent what he characterized as wasteful, unlawful, and unconstitutional law enforcement policies. The trial court granted a permanent injunction requiring CHP to consider vehicle owners’ ability to pay towing and storage fees during impound hearings and vehicle release procedures, and to revise its notice form to advise owners of procedures for retrieving impounded vehicles.The Superior Court of Los Angeles County initially reviewed the case. At the close of the plaintiffs’ case, the trial court granted a motion for judgment against Youth Justice Coalition and entered judgment in favor of defendant Warren A. Stanley, who had retired before the trial. The court found that Stanley, as a former public officer, was no longer a proper defendant. The trial court issued a permanent injunction requiring CHP to revise its vehicle impound procedures, including considering the ability to pay and revising notice forms.The Court of Appeal of the State of California, Second Appellate District, Division Two, reviewed the case. The court reversed the trial court’s judgment, holding that the injunction improperly required CHP to contravene valid statutes, relied on inapplicable case law, conflicted with the existing statutory scheme, and mandated unnecessary revisions to its notice procedures. The appellate court concluded that the trial court erred in requiring CHP to conduct ability-to-pay hearings and revise its notice forms, as these requirements were not mandated by due process and conflicted with statutory provisions. The judgment was reversed, and costs on appeal were awarded to the appellant. View "Mann v. State" on Justia Law

In November 2021, Brendan Krepchin reported an armed robbery at his apartment. Upon investigation, the Mountain View Police Department found no evidence of a robbery but discovered a note suggesting potential violence, law enforcement equipment, and firearms. The police department sought and obtained an emergency gun violence restraining order (GVRO) from the Santa Clara County Superior Court, which was later extended to a three-year order after a hearing in January 2023.The trial court found clear and convincing evidence that Krepchin posed a significant danger of causing personal injury by possessing firearms. The court emphasized the note found in his apartment and his inability to explain it. Krepchin appealed, arguing that the GVRO violated his Second Amendment rights, was procedurally defective, and that the trial court erred in qualifying an officer as a threat assessment expert and admitting hearsay evidence.The California Court of Appeal, Sixth Appellate District, affirmed the trial court's decision. The appellate court held that the GVRO did not violate the Second Amendment, referencing the U.S. Supreme Court's decision in United States v. Rahimi, which upheld firearm restrictions for individuals posing a threat. The court also found no procedural defects in the GVRO's issuance and ruled that the trial court did not abuse its discretion in qualifying the officer as an expert or in admitting hearsay evidence. The court concluded that substantial evidence supported the trial court's findings, including the note and other evidence indicating Krepchin's potential for violence. View "Mountain View Police Dept. v. Krepchin" on Justia Law

A transgender woman, who had legally changed her name and gender marker in 2018, sought to have the entire record of her name change and gender marker correction sealed in 2023. She argued that the public availability of these records had led to harassment and threats after her transgender status was disclosed on social media, revealing her personal information and former name. The trial court denied her request to seal the entire record but did seal her application to seal, its supporting documentation, and a physician’s letter attached to her initial petition.The Superior Court of Stanislaus County initially granted her petition for a name and gender change in 2018 without any objections. In 2023, she filed an application to seal the entire record, citing harassment and threats due to the public availability of her records. The trial court denied the request to seal the entire record, reasoning that there was no evidence the harassment was initiated by the court’s records and that sealing the records would not necessarily solve the problem. The court also noted the strong presumption that name changes be public to prevent fraud and ensure creditors and others can locate individuals who have changed their names.The California Court of Appeal, Fifth Appellate District, reviewed the case and found that the trial court’s findings were not supported by substantial evidence. The appellate court concluded that the appellant’s privacy and safety interests in concealing her transgender identity outweighed the public’s right of access to the records. The court held that the entire record should be sealed to protect her privacy and safety, as there was no less restrictive means to achieve these interests. The appellate court reversed the trial court’s order and remanded the case with instructions to seal all records revealing the appellant’s name change or gender marker correction. View "In re M.T." on Justia Law