Justia Constitutional Law Opinion Summaries

The case involves an incident in which Alberto Jorge Barraza confronted Nikko G., a man known for his long hair and pride in his Native American heritage. Nikko had expressed plans to sell his hair to a company making wigs. After Barraza and associates perceived Nikko had stolen from them, they discussed cutting off his hair as punishment. Barraza approached Nikko while he was asleep in a car, attempted to cut off his hair with a knife, and when Nikko resisted, stabbed him in the leg, resulting in Nikko’s death due to a severed artery.Following these events, a jury in the Superior Court of San Diego County convicted Barraza of first degree felony murder, with the underlying felony being robbery, as well as assault with a deadly weapon. The jury found several enhancements true, including personal use of a deadly weapon and infliction of great bodily injury. The trial court sentenced Barraza to 25 years to life for murder, plus a consecutive term for the weapon enhancement, while staying the sentence for the assault conviction and related enhancements.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed whether the evidence supported the felony murder conviction, specifically whether forcibly cutting attached hair constitutes robbery under Penal Code section 211. The court held that growing human hair, still attached to a person’s head, is part of the human body and not personal property as required for robbery. Therefore, forcibly cutting attached hair does not satisfy the legal definition of robbery, and the evidence did not establish robbery or attempted robbery. The court reversed Barraza’s conviction for first degree felony murder. View "People v. Barraza" on Justia Law

The plaintiff, who was the CEO of a private company with government contracts and a security clearance, was arrested in December 2021 for felony domestic violence. Although no charges were filed, police prepared an investigative report. In February 2022, the San Francisco Superior Court ordered the arrest and related records sealed under California Penal Code sections 851.91 and 851.92. Despite this, the police department released the incident report to a third party without restriction, and it was later sent anonymously to an independent journalist who published articles about the plaintiff’s arrest online, including the report. The plaintiff sought to have the posts removed and subsequently sued the journalist, the platform hosting the articles, and another entity associated with the journalist, alleging multiple causes of action including privacy violations and statutory breaches.The San Francisco County Superior Court reviewed anti-SLAPP motions filed by all defendants, which argued the suit arose from constitutionally protected activity and was barred by the First Amendment and the Communications Decency Act (CDA). The court found that the plaintiff’s claims were based on the defendants’ speech—specifically, online publication in a public forum about a matter of public interest, given the plaintiff’s role and the company's government work. It also determined that statutory protections for sealing did not override constitutional protections, and rejected the argument that defendants’ actions were illegal as a matter of law. The court granted the anti-SLAPP motions and awarded attorney fees to the defendants.The Court of Appeal of the State of California, First Appellate District, Division Four affirmed the trial court’s orders. The main holding was that the First Amendment protects the lawfully obtained, truthful publication of information of public significance, even if the information was originally subject to statutory sealing, and that section 230(c)(1) of the CDA bars claims against interactive computer service providers for hosting such content. The attorney fee award was also affirmed. View "Blackman v. Substack" on Justia Law

TC Telephone participated as a provider in California’s LifeLine program, offering measured-rate telephone service to low-income customers. This service allowed subscribers 60 untimed local calls per month, for which TC Telephone incurred per-minute charges from other carriers. To recoup its costs, TC Telephone sought and received reimbursement from the California Public Utilities Commission (the Commission) based on the total minutes used, rather than per-call. Over several years, Commission staff approved these per-minute reimbursement claims and provided guidance that was ambiguous about the proper method for calculating reimbursements.The Commission began investigating TC Telephone’s reimbursement practices after concerns arose regarding claim amounts. In March 2020, the Commission issued a resolution clarifying that LifeLine providers should seek reimbursement on a per-call basis, not per-minute, and specified that this clarification applied prospectively. However, the Commission subsequently initiated proceedings to determine whether TC Telephone’s prior per-minute reimbursement claims violated program rules. In its initial decision, the Commission found that TC Telephone had improperly sought per-minute reimbursement and ordered it to repay over $8 million in funds received between January 2018 and March 2020, plus interest. TC Telephone’s petition for rehearing was denied.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the Commission’s decisions. The court held that prior to the Commission’s resolution, the reimbursement rules were unconstitutionally vague and failed to provide TC Telephone with fair notice that per-minute reimbursement was prohibited. Because even Commission staff did not know whether per-minute reimbursement was allowed, punishing TC Telephone for its claims violated due process. The court annulled the Commission’s decisions and remanded the matter for further proceedings. View "TC Telephone v. Pub. Utilities Com." on Justia Law

The defendant was convicted after jury trials in 2011 and 2012 of attempted murder, evading an officer, unlawfully taking a vehicle, and shooting at an inhabited dwelling. Each count included enhancements for gang involvement and firearm use, and he was sentenced to a total of 46 years and eight months to life in prison. Following direct appeal, the judgment was modified to reflect life with the possibility of parole on two counts, with a minimum parole eligibility of 15 years, and otherwise affirmed.Years later, the defendant filed a petition for recall and resentencing under California Penal Code section 1170, subdivision (d)(1), arguing that as a juvenile at the time of the offense and having served over 15 years, his lengthy sentence was effectively a life without parole (LWOP) term. He relied on appellate decisions holding that juvenile offenders sentenced to de facto LWOP terms should be eligible for relief under section 1170, subdivision (d)(1), on equal protection grounds. The Los Angeles County Superior Court reviewed the petition, considered recent appellate decisions and parties’ arguments, and denied the petition.The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. Applying de novo review, it held that the defendant’s sentence did not constitute the functional equivalent of LWOP, as he was eligible for youthful offender parole under section 3051 at age 41. The court determined that section 1170, subdivision (d)(1) only applies to explicit LWOP sentences for juveniles and does not violate equal protection by excluding those sentenced to lengthy indeterminate terms. It affirmed the trial court’s denial of the petition. View "People v. Cortez" on Justia Law

In 2003, Samuel Anthony Cruz and several other members of the 7th Street gang were involved in two separate shooting incidents that resulted in the deaths of rival gang members. Cruz was charged with two counts of murder but entered a plea agreement in which he pleaded guilty to two counts of voluntary manslaughter, along with enhancements and gang participation. He was sentenced to a negotiated term of 21 years and eight months.Many years later, Cruz filed a petition under California Penal Code section 1172.6, seeking to vacate his manslaughter convictions and be resentenced on the grounds that legal standards for murder liability had changed. The Superior Court of Orange County issued an order to show cause and held an evidentiary hearing. At this hearing, the prosecution introduced transcripts from the 2007 trial of Cruz’s codefendant, Juan Becerra. Cruz objected to the use of these transcripts on due process grounds but did not challenge the factual findings or dispute this court’s prior opinions allowing such evidence. The trial court denied Cruz’s petition, finding he was an actual shooter in one killing and a direct aider and abettor in the other.Upon appeal, the California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the trial court’s consideration of a codefendant’s trial testimony violated Cruz’s right to due process. The court held that admission of this testimony did not violate procedural due process because Cruz had a full and fair opportunity to contest the evidence: he could have subpoenaed witnesses, testified on his own behalf, or introduced new evidence. The court affirmed the trial court’s order denying Cruz’s petition for vacatur and resentencing. View "P. v. Cruz" on Justia Law

The case involves a defendant who was convicted of first degree murder and other crimes in 1996, with the jury finding special circumstances and imposing a death sentence. During jury selection at trial, the prosecutor used peremptory challenges to strike several Black and Latino jurors. The defendant’s counsel objected to these strikes, raising claims of racial discrimination under Batson v. Kentucky and People v. Wheeler. The trial court found a prima facie case of discrimination for most challenges, required race-neutral justifications from the prosecutor, and ultimately denied the motions. On direct appeal, the California Supreme Court affirmed the trial court’s rulings.Years later, the defendant sought postconviction discovery under Penal Code section 1054.9, including the prosecution’s jury selection notes. The Superior Court for the County of Riverside denied production of these notes, citing prior case law that required a prima facie showing of a Batson/Wheeler violation for postconviction access to jury selection notes. Shortly after this ruling, Assembly Bill No. 1036 was enacted, amending section 1054.9 to expressly include jury selection notes as discoverable material and shifting the burden to the prosecution to show good cause for withholding or redacting these notes.The California Court of Appeal, Fourth Appellate District, Division Two, held that the recent legislative amendments eliminate the requirement for a defendant to make a prima facie case of racial bias to obtain jury selection notes postconviction. Instead, a request for these notes now shifts the burden to the prosecution to demonstrate good cause for shielding or redacting the notes. The appellate court granted the petition for writ of mandate, directing the trial court to adjudicate the defendant’s request in accordance with the current law. View "Montes v. Superior Court" on Justia Law

After divorcing in 2022, Eric and Tiare experienced escalating harassment and abuse beginning in late 2023. Tiare repeatedly sent manipulative and threatening messages, made suicide threats, and harassed Eric’s new girlfriend. The harassment intensified, culminating in Tiare entering Eric’s property, physically attacking him, and being arrested for battery and unauthorized entry. Various protective orders were issued, including a temporary restraining order (TRO), an emergency protective order, and a criminal protective order. Despite these, Tiare violated the orders and continued contacting Eric.The Marin County Superior Court initially granted Tiare three continuances for the hearing on Eric’s petition for a domestic violence restraining order, citing reasons such as giving Tiare time to respond, her attorney’s absence, and her participation in residential treatment. At the fourth hearing, Tiare requested another continuance, arguing her Fifth Amendment right to remain silent due to pending criminal charges. The trial court denied this request, found that Eric had proven acts of abuse, and issued a three-year restraining order protecting both Eric and his girlfriend.The Court of Appeal of the State of California, First Appellate District, Division Three, reviewed the trial court’s denial of the fourth continuance. The appellate court held that respondents in Domestic Violence Prevention Act proceedings who intend to assert their Fifth Amendment right are not automatically entitled to a continuance. The trial court must balance the respondent’s Fifth Amendment interests against other interests, including those of the petitioner, judicial efficiency, nonparties, and the legislative purpose of prompt resolution. The appellate court found the trial court had properly weighed these competing interests and did not abuse its discretion in denying the request. Accordingly, the judgment was affirmed. View "Irvine v. Irvine" on Justia Law

The case involves a challenge to Proposition M, a San Francisco measure approved by voters in 2022 that imposed an annual “Empty Homes Tax” on owners of certain residential units kept vacant for more than 182 days in buildings with more than two units. The stated aim was to discourage prolonged vacancies and increase available housing. Plaintiffs included individuals and associations representing property owners, who argued that Proposition M violated statutory and constitutional protections, including property rights and familial relations, and was preempted by the Ellis Act, which protects property owners’ right to withdraw accommodations from the rental market.The San Francisco City & County Superior Court reviewed cross-motions for summary judgment. Plaintiffs submitted declarations detailing how Proposition M would force them to either rent out units against their wishes or pay substantial taxes, potentially resulting in financial hardship or effective eviction. The City argued plaintiffs lacked standing and that their legal claims failed as a matter of law. After briefing and a hearing, the Superior Court granted summary judgment for plaintiffs, holding that Proposition M violated the Takings Clause, was preempted by the Ellis Act, burdened fundamental liberty interests in familial relations, violated equal protection, and infringed upon the constitutional right to privacy. The court entered judgment prohibiting the City from administering or enforcing Proposition M.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the City’s appeal. The appellate court analyzed the measure’s conflict with the Ellis Act and concluded that Proposition M imposed a “prohibitive price” on owners’ right not to offer property for rent, directly contravening the Act’s protections. The court found that the Ellis Act preempts Proposition M and affirmed the trial court’s judgment, without reaching additional constitutional claims. The judgment prohibiting enforcement of Proposition M was thus upheld. View "Debbane v. City and County of San Francisco" on Justia Law

A woman brought a civil lawsuit against her uncle and godfather, alleging years of sexual abuse that began when she was a minor. The defendant was previously convicted in a criminal court for related offenses and was incarcerated. After his conviction, the plaintiff filed the civil suit seeking compensatory and punitive damages for personal injuries resulting from the abuse. The defendant initially had legal representation using personal funds, but those funds became inaccessible due to a blocked account ordered by a family court during concurrent divorce proceedings. When his accessible funds were depleted, the defendant began representing himself. He sought access to the blocked funds to retain new counsel but experienced significant delays in obtaining a family court order to release the money.The Superior Court of Alameda County presided over the civil trial, during which the defendant appeared remotely from prison. Despite repeated requests for continuances to secure counsel after finally gaining access to some funds, the trial court denied these requests. The trial proceeded, and a jury found the defendant liable for several torts, awarding the plaintiff substantial compensatory and punitive damages.Upon appeal, the California Court of Appeal, First Appellate District, Division Four, determined that the trial court abused its discretion and violated the defendant’s constitutional rights by denying his continuance requests, given his indigency, incarceration, and the fundamental right to meaningful access to the courts. The appellate court reversed the judgment and remanded the case for a new trial on all issues, including punitive damages. The court clarified that the plaintiff is entitled to retry all issues. The court did not address other trial errors or the excessiveness of damages due to its disposition. The appellate court also explained that the trial court did not err in admitting school photographs of the plaintiff, which may be relevant upon retrial. View "Mary D. v. McCauley" on Justia Law

A minor, N.S., attending a public middle school, made a comment to a school liaison officer that he had a weapon, specifically stating, "I have a Glock, too." The liaison officer, who was a Fullerton Police Officer assigned to the school, interpreted this statement as an indication that N.S. might possess a firearm on campus, which posed a potential threat to students. The officer directed N.S. to the principal's office to be searched. N.S. verbally refused to comply, left the office, and walked toward the parking lot. The officer followed and repeatedly ordered N.S. to return for the search. N.S. continued to refuse for approximately ten minutes, only agreeing after another officer arrived. He was subsequently searched, arrested, and booked into juvenile hall.A petition was filed by the Orange County District Attorney in the Superior Court of Orange County, alleging N.S. violated Penal Code section 148, subdivision (a)(1), by willfully resisting, delaying, or obstructing a peace officer. After a jurisdiction hearing, the juvenile court found this allegation true beyond a reasonable doubt. N.S. was declared a nonward for up to six months and ordered to complete probation. N.S. appealed, arguing insufficient evidence supported the finding and that the officer’s search was unlawful.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. It applied the substantial evidence standard and concluded that N.S.’s conduct—repeated refusals and physically leaving the scene—constituted willful resistance and delay under section 148, subdivision (a)(1). The court also held that school liaison officers are considered “school officials” for Fourth Amendment purposes, requiring only reasonable suspicion (not probable cause) to conduct a search. The officer had reasonable suspicion based on N.S.’s own statement. The order of the juvenile court was affirmed. View "In re N.S." on Justia Law