Justia Constitutional Law Opinion Summaries

A 16-year-old committed a violent home invasion, during which he sexually assaulted his former neighbor at knifepoint. He was convicted by a jury of multiple offenses, including rape, sodomy, oral copulation, robbery, burglary, and related enhancements. The original sentence was a combination of determinate and indeterminate terms, ultimately resulting in a total sentence of 44 years to life in prison, with parole eligibility at age 60 after a later modification.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that excluding him from resentencing relief violated equal protection principles. The trial court denied the petition, finding that his sentence was not functionally equivalent to LWOP and that, under People v. Heard, he was not eligible for relief.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which is rooted in Eighth Amendment jurisprudence, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as articulated in recent California Supreme Court decisions. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those, like the appellant, sentenced to lengthy terms with parole eligibility within their expected lifetimes. The court concluded that section 1170(d)’s limitation to LWOP sentences does not violate equal protection as applied to a 44-years-to-life sentence. The trial court’s denial of the petition was affirmed. View "People v. Baldwin" on Justia Law

Daniel Orozco was involved in a drive-by shooting in Los Angeles, where he and three other members or associates of the Varrio Norwalk gang entered rival Chivas gang territory. During two separate incidents about twenty minutes apart, a shooter in Orozco’s car used Orozco’s gun to wound one man and kill another, who was not a gang member. Police quickly connected the car to Orozco, found the group at his home, and recovered the weapon and other evidence. Orozco was arrested along with the others. At trial, Orozco’s defense centered on his alleged intoxication, arguing he was too drunk to form criminal intent.At the preliminary hearing in the Superior Court of Los Angeles County, the magistrate suppressed a confession by the shooter, Martinez Garibo, due to a Miranda violation. Despite this, the magistrate found sufficient evidence to hold Orozco to answer for murder and attempted murder, but not for conspiracy to commit murder, as there was no evidence of an agreement to kill. On the day of trial, the prosecution moved to add a conspiracy charge, which the trial court allowed over Orozco’s objection. The jury convicted Orozco of all three charges, and he was sentenced to consecutive terms for murder and attempted murder, with a stayed sentence for conspiracy.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It held that the conspiracy conviction must be reversed because the evidence at the preliminary hearing did not support that charge, and Orozco was not given proper notice. The court affirmed the convictions for murder and attempted murder, finding no merit in Orozco’s other arguments, including ineffective assistance of counsel and alleged prosecutorial error. The court also held that Orozco forfeited his challenge to the attempted murder sentence by failing to object and having adequate notice. The case was remanded for further proceedings consistent with the opinion. View "People v. Orozco" on Justia Law

A man was stopped by a California Highway Patrol officer for speeding on Interstate 680. He was the sole occupant of the vehicle and did not have a valid driver’s license, instead presenting a fake one. During an inventory search of the impounded car, the officer found a loaded handgun and a large sum of cash. The firearm was determined to be registered to several previous owners, but not to the man. He was charged with carrying a concealed, loaded firearm in a vehicle and carrying a loaded firearm not registered to him.Before trial in the Superior Court of California, County of Contra Costa, the defendant filed a demurrer arguing that the statutes under which he was charged were unconstitutional under the Second Amendment, as interpreted by New York State Rifle & Pistol Association, Inc. v. Bruen and United States v. Rahimi. The trial court denied the demurrer. The defendant then pled no contest to the charges and appealed, with the trial court granting a certificate of probable cause.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court held that California’s licensing scheme for carrying concealed firearms, even as it existed prior to recent amendments, was not facially unconstitutional under the Second Amendment. The court reasoned that requiring a license to carry a concealed firearm is a reasonable means of screening for ineligible individuals, such as felons, and does not require a finding of dangerousness for each applicant. The court found that the statutes at issue are consistent with the nation’s historical tradition of firearm regulation and rejected the argument that the absence of a dangerousness finding rendered the statutes unconstitutional. The judgment of the trial court was affirmed. View "P. v. Roberts" on Justia Law

The petitioner was convicted in 2003 after pleading no contest to several counts of lewd and lascivious acts with minors and one count of nonforcible oral copulation with a minor. The plea agreement amended one charge from forcible to nonforcible oral copulation, and the factual basis for the plea referenced police reports describing acts involving force. In 2005, mental health professionals evaluated the petitioner and, relying in part on a probation report, certified him as a mentally disordered offender (MDO) under California law, finding he had committed a qualifying offense involving force or violence. The Board of Parole Hearings affirmed this certification, and the petitioner did not seek review in the superior court at that time. He has remained in state custody under annual recommitment orders since then.Years later, the petitioner challenged his original MDO certification in the Fresno County Superior Court through a habeas corpus petition, arguing that his conviction did not qualify as a predicate offense for MDO commitment because he did not admit to using force or violence, and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force, and concluded the petitioner’s offense qualified under the statutory “catchall” provision for nonenumerated crimes involving force or violence.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is an appropriate means to challenge an initial MDO certification based on the nature of the underlying offense, even many years after the initial commitment. The court further held that the evidentiary rule announced in People v. Stevens, which restricts the use of expert testimony to prove qualifying offenses, does not apply retroactively. The court found sufficient evidence supported the original certification under the law in effect at the time and rejected claims of ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

Several general law cities in California challenged the constitutionality of a state law, Senate Bill No. 9 (SB 9), which requires local agencies to ministerially approve two-unit housing projects and urban lot splits in single-family residential zones. The cities argued that SB 9 usurps their authority over local land use and zoning, imposes a uniform approach that disregards local needs and conditions, and is not reasonably related to its stated goal of ensuring access to affordable housing, as it does not mandate affordability for new units.The Superior Court of Los Angeles County reviewed the cities’ complaint and the state’s motion for judgment on the pleadings and demurrer. The trial court concluded that, as general law cities, the plaintiffs could not invoke the municipal affairs doctrine under article XI, section 5 of the California Constitution, which provides certain protections only to charter cities. The court also found that the cities failed to identify any constitutional provision that SB 9 violated and determined there was no reasonable likelihood that the complaint could be amended to state a viable cause of action. Judgment was entered in favor of the state, and the cities appealed.The California Court of Appeal, Second Appellate District, Division Four, affirmed the trial court’s judgment. The appellate court held that general law cities are not protected by the municipal affairs doctrine and must yield to conflicting state law. The court further found that the cities did not identify a constitutional right that SB 9 violated and failed to show that the statute was unconstitutional on its face or as applied. The court also concluded that the trial court did not abuse its discretion in denying leave to amend the complaint, as no viable claim could be stated. View "City of Rancho Palos Verdes v. State" on Justia Law

In 2006, Victor Arriaga entered into an oral agreement with Gilbert Torres to repair water-damaged drywall in Torres’s home. The project expanded to include additional repairs and a room addition, with Torres paying Arriaga substantial sums by check and cash. After several weeks, Arriaga and his father, who worked with him, left the job unfinished and removed their tools and materials from the property. Torres was unable to contact Arriaga afterward. The Los Angeles Building and Safety Department later issued a stop-work notice due to unpermitted and non-code-compliant work, and the Contractors State License Board (CSLB) discovered Arriaga was unlicensed. The CSLB referred the matter to the district attorney, who filed a felony complaint in 2007 for wrongful diversion of construction funds. However, there was no evidence that law enforcement attempted to contact Arriaga or inform him of the warrant. Arriaga moved to Nevada, and only learned of the warrant in 2022 after a misdemeanor arrest there. He returned to Los Angeles in 2023 to address the warrant and was arraigned.The Los Angeles County Superior Court held a preliminary hearing in 2023, after which Arriaga was held to answer. In 2024, Arriaga moved to dismiss the information, arguing that the 16-year delay between the complaint and his arraignment violated his state and federal speedy trial rights, causing him prejudice due to lost evidence and the death of his father, a key witness. The trial court denied the motion, finding no actual prejudice and concluding that the People had a legitimate justification for the delay.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. It held that Arriaga’s state speedy trial right was violated by the 16-year post-complaint delay, finding that he made a prima facie showing of prejudice due to the loss of his father’s testimony, and that the prosecution failed to provide a legitimate justification for the delay. The court granted Arriaga’s petition for a writ of prohibition and directed the trial court to dismiss the felony count. View "Arriaga v. Superior Court" on Justia Law

Arron and Arthur Benedetti, along with the Estate of Willie Benedetti, challenged a provision in Marin County’s amended local coastal program (LCP) that allows owners of certain farmland to build additional residential units only if they record a restrictive covenant. This covenant requires the owner of the new units to be actively and directly engaged in agriculture, either through direct involvement in commercial agriculture or by leasing the property to a commercial agricultural producer. The Benedettis, who inherited farmland and sought to build a second residence, argued that this provision was facially unconstitutional, claiming it violated the nexus and proportionality requirements established in Nollan v. California Coastal Commission and Dolan v. City of Tigard, and infringed upon their substantive due process rights by compelling them to work in a specific occupation.The Marin County Superior Court initially ruled that the Benedettis could not bring a facial takings challenge under Nollan/Dolan and, applying rational basis review, denied their petition and complaint based on their due process theory. The trial court sustained a demurrer to one cause of action and denied relief on the others, leading to the Benedettis’ appeal.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The appellate court held that, contrary to the trial court’s conclusion, the Benedettis could raise a facial Nollan/Dolan claim. However, the court found that the restrictive covenant requirement had a sufficient nexus and rough proportionality to the county’s interest in preserving agricultural land and did not violate substantive due process. The court applied rational basis review and determined the provision was reasonably related to a legitimate legislative goal. The judgment of the Marin County Superior Court was affirmed. View "Benedetti v. County of Marin" on Justia Law

In 2021, a plaintiff filed a complaint against a public school district, alleging that she was repeatedly sexually assaulted by a teacher while attending middle and high school. The complaint asserted that the teacher’s abusive conduct was widely known within the school and that the district either knew or should have known about the abuse but failed to act, allowing the teacher to remain employed. The plaintiff brought claims for negligence and negligent hiring, retention, and supervision, relying on statutory provisions that exempt certain childhood sexual assault claims from the usual requirement to present a claim to the public entity before filing suit.The Superior Court of Los Angeles County reviewed the case after the school district moved for judgment on the pleadings. The district argued that the plaintiff’s claims were only possible due to Assembly Bill 218 (AB 218), which retroactively eliminated the claims presentation requirement for childhood sexual assault claims against public entities. The district contended that AB 218 violated the gift clause of the California Constitution by imposing liability for past acts where no enforceable claim previously existed. The trial court agreed, finding that AB 218 retroactively created liability and constituted an unconstitutional gift of public funds, and dismissed the complaint with prejudice.The California Court of Appeal, Second Appellate District, Division One, reviewed the trial court’s decision de novo. The appellate court held that AB 218 does not violate the gift clause because it did not create new substantive liability; rather, it removed a procedural barrier to enforcing pre-existing liability for negligence and negligent hiring, retention, and supervision. The court reversed the trial court’s order and remanded with directions to deny the school district’s motion for judgment on the pleadings. View "O.B. v. L.A. Unified School Dist." on Justia Law

A 16-year-old committed a violent home invasion, during which he raped, sodomized, and assaulted his former neighbor at knifepoint, then stole property from her home. He was convicted by a jury in 2002 of multiple counts, including forcible rape, oral copulation, sodomy, sexual battery, robbery, burglary, and related enhancements. His sentence was ultimately modified to a determinate term of 19 years, followed by a consecutive indeterminate term of 25 years to life, resulting in an effective sentence of 44 years to life.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d)(1)(A), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that, under equal protection principles as articulated in People v. Heard, he should be eligible for relief. The trial court denied the petition, finding that a 44-years-to-life sentence was not functionally equivalent to LWOP and thus did not qualify for resentencing under the statute.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which was developed in the Eighth Amendment context, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as required for equal protection claims. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those with lengthy term-of-years sentences that do not guarantee death in prison. The court affirmed the trial court’s denial of the petition, holding that section 1170(d)’s limitation to those sentenced to LWOP does not violate equal protection as applied to a juvenile nonhomicide offender sentenced to 44 years to life. View "People v. Baldwin" on Justia Law

Greg Wright was recorded on video robbing a gas station convenience store at gunpoint. The cashier, who was present during the incident, testified that Wright showed no signs of intoxication—he did not smell of alcohol, slur his words, or appear confused. The robbery was carried out efficiently, with Wright taking money, a lighter, and his own dollar before leaving. Police arrested Wright the next day and found a loaded pistol in his car. At trial, Wright represented himself and argued that he was too intoxicated to form the intent to rob, but the evidence from both the cashier and the surveillance video contradicted this claim.The Superior Court of Los Angeles County presided over the trial. The jury convicted Wright of robbery, possession of a firearm by a felon, and unlawful possession of ammunition, and found true the firearm use and prior conviction allegations. The trial court sentenced Wright to 36 years and four months to life, including enhancements for firearm use and prior convictions. Wright challenged the jury instructions regarding intoxication, the prosecutor’s closing argument, and the imposition of multiple punishments for related offenses, as well as the process for determining aggravating sentencing factors.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the trial court erred by using the term “specific intent” in the intoxication defense instruction, but found the error harmless given the overwhelming evidence that Wright was not impaired. The court also found any assumed prosecutorial error and cumulative error to be harmless. However, the appellate court agreed that sentencing errors occurred: multiple punishments for the firearm and ammunition offenses violated Penal Code section 654, and Wright was denied his right to a jury trial on aggravating sentencing factors as required by Erlinger v. United States. The convictions were affirmed, but the case was remanded for full resentencing. View "People v. Wright" on Justia Law