Justia Constitutional Law Opinion Summaries

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

The defendant, Freddy Rivera Corbi, was bullied by gang members in his community for years. In July 2019, he was seriously injured by a gang member. A month later, Corbi encountered another gang member, Lazaro Orozco, and fatally shot him during an argument. At trial, the main issue was whether the shooting was in self-defense or an act of revenge. The jury convicted Corbi of second-degree murder.The Superior Court of San Diego County allowed the prosecution’s gang expert to testify about the significance of Corbi following Orozco before the shooting. Corbi argued on appeal that this testimony was speculative and prejudicial. He also claimed that the prosecutor violated the California Racial Justice Act of 2020 by highlighting his interest in white women during closing arguments. Additionally, Corbi contended that the trial court erred in considering whether to dismiss a firearm enhancement at sentencing.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court found that while the gang expert’s testimony exceeded the proper scope of expert testimony, it was not prejudicial enough to affect the outcome. The court also determined that Corbi forfeited his Racial Justice Act claim by failing to raise it in the trial court. Finally, the court held that the trial court did not err in imposing the firearm enhancement, as it had the discretion to impose or dismiss the enhancement and had considered the relevant mitigating factors.The judgment of the Superior Court was affirmed. View "P. v. Corbi" 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 that this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, had previously determined that Field’s equal protection argument had merit 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 found that the People had not satisfied their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated by requiring Field and Asher to testify during their commitment trials and ordered new commitment trials for both.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 orders for new trials were affirmed. 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. JCCrandall objected to the use of its easement for cannabis transportation. Despite the objection, the County granted the CUP, and the County’s Board of Supervisors upheld the decision, finding the road adequate for the project.JCCrandall petitioned for a writ of administrative mandate, challenging the County’s determination. JCCrandall argued that the use of the easement for cannabis activities was prohibited by the easement deed and federal law, required JCCrandall’s consent under state law, and violated County standards for private roads. 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 held 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 its property is a fundamental vested right. The appellate court also found 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 concluded that the County’s reliance on Civil Code section 1550.5, subdivision (b) was misplaced, as it defies the Supremacy Clause of the U.S. Constitution. The judgment was reversed, and costs were awarded to JCCrandall. View "JCCrandall v. County of Santa Barbara" on Justia Law

The case involves a dispute between a taxpayers' association and a water district over the imposition of groundwater replenishment charges. The taxpayers' association alleged that the water district's charges violated constitutional provisions and unfairly benefited large agricultural businesses. The association sought a writ of mandate to stop the collection of these charges and to vacate the resolutions imposing them. They also claimed conversion, civil conspiracy, aiding and abetting, and violations of the Unfair Competition Law (UCL) against the water district's board members, general manager, and consulting firms.The Superior Court of Riverside County denied the defendants' anti-SLAPP motion, which sought to strike several causes of action on the grounds that they arose from protected activities. The court found that the public interest exemption to the anti-SLAPP statute applied. Additionally, the court sustained the defendants' demurrer to the first amended petition and complaint, finding the claims time-barred under the validation statutes. The court also awarded over $180,000 in attorney's fees to the plaintiffs, deeming the anti-SLAPP motion frivolous.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the public interest exemption did not apply because the relief sought could only be provided by the water district, not the individual defendants. The court found that the anti-SLAPP motion should have been granted for most causes of action, except for conversion and the writ of mandate against the general manager. Consequently, the fee award was reversed. The court also affirmed the demurrer ruling, as the claims against the individual defendants were not legally sufficient. The case was remanded for further proceedings consistent with these findings. View "Howard Jarvis Taxpayers Assn. v. Powell" on Justia Law

The case involves a challenge to the adequacy of an Environmental Impact Report (EIR) prepared for a project proposing significant changes to the California State Capitol. The Department of General Services (DGS) and the Joint Committee on Rules of the California State Senate and Assembly (Joint Rules Committee) prepared both an EIR and a revised EIR under the California Environmental Quality Act (CEQA). The project includes demolishing the existing Capitol Annex, constructing a new attached Annex, building an underground visitor center, and constructing a new underground parking garage.The Superior Court of Sacramento County initially rejected challenges to the EIR brought by Save Our Capitol! and Save the Capitol, Save the Trees. On appeal, the Court of Appeal found certain aspects of the EIR flawed and remanded the case. After DGS revised the EIR and reapproved the project without the visitor center, the trial court discharged the writ. Save the Capitol, Save the Trees appealed, arguing the trial court prematurely discharged the writ. The Court of Appeal agreed and reversed the trial court's decision. Save Our Capitol! then filed a new petition challenging the revised EIR, which the trial court also rejected.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court's decision. The court held that recent legislation, Senate Bill No. 174, exempts the Capitol Annex Project from CEQA’s requirements. The court found that Senate Bill 174, which took effect immediately, dictates that all work performed under the Annex Act is exempt from CEQA. Consequently, Save Our Capitol!'s claims that DGS violated CEQA were rejected. The court also addressed and dismissed Save Our Capitol!'s argument that Senate Bill 174 is unconstitutional under article IV, section 28 of the California Constitution, finding that the bill explicitly bars funds from being used inconsistent with this constitutional provision. View "Save Our Capitol! v. Dept. of General Services" on Justia Law

In the 1980s, Robert Edward Maury was convicted of multiple crimes, including three counts of first-degree murder and forcible rape. A jury sentenced him to death in 1989. The California Supreme Court affirmed his conviction and death sentence in 2003, and his initial state habeas corpus petition was denied in 2011. In 2021, Maury filed a second state habeas corpus petition, which the Shasta County Superior Court dismissed as procedurally barred. Maury appealed, focusing on a claim under McCoy v. Louisiana, arguing that his Sixth Amendment rights were violated when his counsel presented mitigating evidence against his wishes during the penalty phase.The Shasta County Superior Court dismissed Maury’s second habeas petition, finding it untimely and successive. The court did not address the merits of Maury’s McCoy claim, which argued that his counsel violated his Sixth Amendment rights by presenting mitigating evidence over his objection, thus conceding guilt. Maury also claimed that the trial court erred in denying his motions to represent himself during the penalty phase, which he argued forced him to proceed with counsel burdened by an irreconcilable conflict of interest.The California Court of Appeal, Third Appellate District, reviewed the case and found no McCoy error. The court concluded that Maury’s counsel did not concede guilt over his objection but instead presented mitigating evidence and argued for life without parole while maintaining Maury’s innocence. The court also found that any error in presenting a defense against Maury’s wishes was harmless, as Maury achieved his objective of obtaining a death verdict by personally addressing the jury. The court affirmed the trial court’s order denying Maury’s second habeas corpus petition, concluding that Maury failed to demonstrate prejudice or an actual conflict of interest that adversely affected his counsel’s performance. View "In re Maury" on Justia Law

In this case, the defendant was convicted of multiple sexual offenses against his two stepdaughters, L.C. and M.C., when they were under ten years old. The jury found him guilty of thirteen counts, including nine counts of lewd acts. The court sentenced him to 145 years to life under California’s “One Strike” law, which mandates severe penalties for certain sexual offenses involving multiple victims.The Superior Court of San Diego County admitted evidence of both charged and uncharged sexual offenses committed by the defendant. The court conducted a pretrial analysis under Evidence Code section 352 to determine the admissibility of this evidence. The jury was instructed that it could consider this evidence as indicative of the defendant’s propensity to commit sexual offenses. The defendant appealed, arguing that the trial court erred by not conducting a separate section 352 analysis before instructing the jury and that his sentence violated constitutional guarantees of equal protection and prohibitions against cruel and unusual punishment.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the trial court did not err in its handling of the section 352 analysis, as it had implicitly conducted this analysis pretrial. The appellate court also found that the defendant’s equal protection claim was foreclosed by the California Supreme Court’s decision in People v. Williams, which upheld the constitutionality of excluding One Strike offenders from youthful offender parole consideration. Additionally, the court concluded that the defendant forfeited his claim regarding cruel and unusual punishment by not raising it at trial and that the claim lacked merit regardless.The Court of Appeal affirmed the judgment of the Superior Court, upholding the defendant’s conviction and sentence. View "P. v. Ellis" on Justia Law

The defendant was convicted of felony vehicle burglary, being a felon in possession of tear gas, and misdemeanor receiving stolen property. During jury selection, the defendant, who was in jail, did not appear in court. The bailiff reported that the defendant refused transport, leading the court to find his absence voluntary and proceed with jury selection. The defendant missed another day but was present for the rest of the trial. He was sentenced to two years and eight months in county jail, with part of the sentence suspended for mandatory supervision.The Superior Court of the City and County of San Francisco handled the initial trial. The defendant argued that his constitutional right to be present was violated due to insufficient evidence of voluntary absence and the denial of a continuance. The court found substantial evidence of voluntary absence based on the bailiff's testimony and denied the continuance. The defendant was convicted on most counts, and the court later modified his sentence.The California Court of Appeal, First Appellate District, reviewed the case. The court held that substantial evidence supported the finding that the defendant was voluntarily absent, including the bailiff's report and jail procedures. The court also ruled that the trial court did not abuse its discretion in denying the continuance, considering the potential manipulation by the defendant and the inconvenience to jurors and court resources. The appellate court affirmed the trial court's decisions but accepted the Attorney General's concession that the defendant was entitled to four additional days of presentence custody credits. View "People v. Hersom" on Justia Law