Justia Constitutional Law Opinion Summaries

Chioma and Edwards were each convicted on multiple counts arising from their joint 2012 sexual assault and robbery of Jane Doe and robbery of her male friend. With “one-strike” (because they inflicted great bodily injury and personally used a firearm) and other allegations against them, Chioma was sentenced to 129 years to life, and Edwards was sentenced to 95 years to life. Both were 19 years old when they committed these offenses. They challenged their prison sentences as cruel and unusual punishment, and, on equal protection grounds, challenged their exclusion from the Section I. 2 provisions of Penal Code section 30511—which mandates youthful-offender parole hearings for most who receive de facto life sentences for crimes they commit at or before age 25. The court of appeal rejected the’ cruel and unusual punishment challenge but accepted their equal protection arguments and remanded to allow the development of the record with evidence of youth-related factors that will be relevant in a youthful-offender parole hearing. Under the One-Strike exemption to Penal Code 30511, an entire class of youthful offenders convicted of crimes short of homicide is, regardless of criminal history, categorically exempted from an opportunity offered to all youthful first degree murderers except those sentenced to life without the possibility of parole. View "People v. Edwards" on Justia Law

In 1994, a jury convicted Bryan Jones of the first degree murders of JoAnn S. and Sophia G., attempted murder of Maria R. and Karen M., and the forcible rape, sodomy and oral copulation of Karen M. The jury also sustained an allegation that Jones used a deadly weapon in the attempt to murder Maria R., along with special circumstance allegations: Jones murdered JoAnn S. and Sophia G. during the commission or attempted commission of the crime of sodomy, and he committed multiple murders. The jury sentenced Jones to death, and the judgment was affirmed on appeal. During jury selection, the prosecution used peremptory challenges to excuse two African-American jurors, and defense counsel objected. The court determined the defense attorney made a prima facie showing of racial bias. The prosecutor offered race-neutral explanations for excusing the jurors, citing in part a numerical score for each prospective juror that the prosecution team had devised. The trial court found the explanations credible and permitted the strikes. In an amended petition for writ of habeas corpus, Jones alleged ineffective assistance of counsel because his trial counsel failed to raise a Batson/Wheeler error for the prosecutor's exercise of peremptory challenges against women, noting 13 of the prosecution's 17 peremptory strikes were against prospective female jurors. Furthermore, Jones alleged his trial counsel was ineffective for failing to raise a Batson/Wheeler error on the ground that four of those women were also African-American. Following Jones's direct appeal, his habeas attorney sought postconviction discovery of the jury selection notes. The trial court granted the request in April 2018. In May, the district attorney filed a writ of mandate and/or prohibition seeking a stay and requesting the Court of Appeal vacate the trial court's order, which was denied. The district attorney appealed. The California Supreme Court granted the petition for review and transferred the matter to the Court of Appeal court. The appellate court then vacated its order denying the writ of mandate and/or prohibition and issued an order to show cause returnable why petitioner was not entitled to the relief requested. The Court of Appeal concluded the prosecution's jury selection notes were discoverable as part of postconvicton writ of habeas corpus discovery. The Court denied the district attorney's petition for mandamus relief. View "California v. Superior Court (Jones)" on Justia Law

In 1988, at age 17, Palmer pled guilty to kidnapping for robbery and was sentenced to life with the possibility of parole. He became eligible for parole in 1996 and, over the next 19 years, had 10 parole suitability hearings at which parole was denied. While challenging the denial of parole at a 2015 hearing Palmer also sought habeas corpus relief, citing the Eighth Amendment. On December 6, 2018, the Board held a new parole suitability hearing, as ordered by the reviewing court, and found Palmer suitable for release on parole. The court of appeal concluded that the serial denials of parole Palmer experienced resulted in punishment so disproportionate to his individual culpability for the offense he committed, that it must be deemed constitutionally excessive and that Palmer is entitled to release from all forms of custody, including parole supervision. The court noted that such challenges based on the length of prison time already served are rare. View "In re Palmer" on Justia Law

The Court of Appeal affirmed the trial court's denial of defendants' special motion to strike under the anti-SLAPP statute, because information about the views from a private residence affecting only those directly interested in buying or selling that house is not an issue of public interest. The court also held that plaintiff was entitled to attorney fees and therefore reversed the trial court's ruling on that issue. The court also granted plaintiff's motion for sanctions. View "Workman v. Colichman" on Justia Law

Zachary Weir was convicted on four counts of felony possession of personal identifying information. On appeal, Weir contended his felony convictions should have been classified as misdemeanors under Proposition 47's enactment of section 490.2 defining petty theft. The Court of Appeal determined this case required an interpretation of Penal Code section 530.5(c), and for a determination of whether a conviction under subsections (1) and (2) of this subdivision should be reduced to a misdemeanor under section 490.2's petty theft provision. The Court concluded section 530.5(c) was not subject to reclassification under Proposition 47 because section 490.2 only reclassified theft offenses. A violation of section 530.5(c) was a nontheft offense, and to conclude otherwise would be contrary to Proposition 47's intent. View "California v. Weir" on Justia Law

A woman, inspecting property on which her family was in escrow, saw a van backed up to the garage door. Morales got out of the van and claimed to be interested in buying the property. When the woman took photos of the van and license plate, Morales became agitated and drove away. The woman called 911. Napa County Sheriff’s Deputy Quigley was dispatched to investigate and spotted the van in a nearby parking lot. Morales got out as Quigley approached. Quigley found drug paraphernalia on Morales, who said that "Shawn" gave him the van to use because Morales was homeless. Morales was charged with felony unlawful taking or driving of a vehicle (Vehicle Code 10851(a)). The information alleged prior felony convictions in Nevada for robbery and conspiracy to commit robbery. At trial, no evidence established when the van was stolen or by whom. The verdict form referenced only unlawful driving, not unlawful taking. The court sentenced Morales to 32 months in state prison. The court of appeal remanded on a claim that the trial court reviewed an ambiguous record of his Nevada convictions to find true the prior strike allegations, violating the Sixth Amendment. The court rejected claims that the section 10851 conviction merited only misdemeanor punishment and that the court violated his due process rights by failing to instruct the jury on a purported defense. View "People v. Morales" on Justia Law

Following a murder trial, the foreperson wrote a note stating the jury was deadlocked on count 2, and “[f]rustrations are running high.” A second note stated, “I do not feel the dissenting juror is basing their dissent on reasonable doubt.” In subsequent questioning, the foreperson and Juror 10 indicated dissatisfaction with Juror 11. The judge questioned and discharged Juror 11, under Penal Code section 1089. The court of appeal reversed, noting the risk to a defendant’s right to due process and a fair trial by an unbiased jury. A trial court must “rely on evidence, that in light of the entire record, supports its conclusions” that a juror was actually unable to perform. Juror 11 “fail[ed] to agree with the majority of other jurors [and] persist[ed] in expressing doubts about the sufficiency of the evidence in support of the majority view” and had trouble “articulat[ing] the exact basis for disagreement after a complicated trial,” but these circumstances do not amount to juror misconduct. It is not a ground to discharge a juror because he “relies on faulty logic or analysis” or because he “does not deliberate well or skillfully.” The foreperson and Juror 10 did not claim that Juror 11 said he intended to disregard the court’s instructions or he disagreed with the law as instructed by the court. View "People v. Salinas-Jacobo" on Justia Law

The Court of Appeal granted Reyna Hernandez’s petition for writ of habeas corpus seeking to have her conviction for possession of methamphetamine for the purpose of sale vacated and the opportunity to withdraw her guilty plea. The record both showed her appointed trial counsel failed to advise her before she entered her guilty plea that her plea would subject her to mandatory deportation, and contained evidence, including contemporaneous objective evidence, she would not have entered her guilty plea had she been so advised. The Court of Appeal published this opinion because it discussed evidence establishing ineffective assistance of counsel, including prejudice, for failure to advise of mandatory deportation consequences attached to a guilty plea. View "In re Hernandez" on Justia Law

Defendant Morgan Eddy and the victim often spent time at Lonnie L.’s apartment. At some point, however, Lonnie decided that defendant was no longer allowed in the residence. On the day of the victim’s death, defendant came to the apartment and Lonnie asked him to leave. Defendant initially complied, but shortly after Lonnie left, defendant returned. The victim then told defendant to leave. The victim and defendant subsequently yelled at each other and engaged in aggressive, mutual hand-to-hand combat inside and outside of the apartment, which was observed by multiple individuals. At one point, the victim had defendant pinned on the ground and repeatedly asked defendant if he would leave if the victim let him go. Defendant eventually agreed to leave and the victim went outside. The victim was turning to his right when Joseph S., a neighbor, saw defendant exit the apartment and strike the victim in the abdomen three times with a clenched fist in a sideways motion, consistent with a stabbing. Joseph did not see a weapon but heard sounds consistent with punches connecting. The victim, looking in defendant’s direction with a terrified expression, exclaimed, “You stabbed me!” and fell to the ground. Joseph saw defendant briefly reenter the apartment to grab a bag before fleeing the scene. Joseph did not see defendant discard anything in the apartment. Joseph attempted to pursue defendant after seeing blood on the victim’s shirt. A forensic pathologist testified the victim bled to death as a result of a single stab wound to the lower abdomen, which cut the lower aorta and vena cava. The jury found defendant guilty of first degree murder and found true the special allegation that he had used a knife. At his sentencing hearing, defendant made a Marsden request to replace his counsel, which the trial court denied. The court imposed a sentence of 25 years to life, plus one year for the knife enhancement. The court also imposed various fines and fees and awarded victim restitution, none of which are challenged on appeal. Defendant argued on appeal trial counsel violated his “Sixth Amendment right to choose the objective of his defense by conceding guilt against his express wishes.” The Court of Appeal found that, under McCoy, defendant’s Sixth Amendment rights were indeed violated by his counsel’s actions and found no meaningful basis upon which to distinguish this case from McCoy’s recognition of a defendant’s absolute right to maintain innocence as the objective of his defense. Judgment was reversed and the case remanded for further proceedings. View "California v. Eddy" on Justia Law

Minor Charlotte C. contended the juvenile court erred in denying her counsel's request for her relatives' RFA assessment information. She argued a number of statutory and regulatory exceptions allowed minor's counsel to access such information, including Welfare and Institutions Code section 317. Charlotte argued minor's counsel had an obligation to review her relative's RFA information due to allegations the relative had used methamphetamine and had engaged in an incident of domestic violence. Charlotte argued the error in denying minor's counsel access to RFA information was prejudicial because counsel was forced to make an uninformed decision concerning her best interests.In a second appeal, Charlotte argued her due process rights were violated at a hearing under section 361.3 in which she was not permitted to present evidence and cross-examine witnesses about information obtained during her relatives' RFA assessment. The Court of Appeal concluded minor's counsel was entitled to receive a copy of her client's case file, including any RFA-related information, upon request pursuant to sections 317(f) and 827. Here, minor's counsel's request for RFA information was overbroad and she would not have been entitled to the relatives' "RFA-related information" under the standard as defined today. With respect to the claim that her due process rights were violated at the section 361.3 hearing, because Charlotte did not request a new trial or a reversal of the order placing her with her relatives, and error was harmless. The Court reversed the juvenile court's finding it does not have the authority to review or release the relatives' RFA information that is pertinent to section 361.3 to minor's counsel. View "In re Charlotte C." on Justia Law