Justia Constitutional Law Opinion Summaries

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

In 1998, Khyle Armando Briscoe, then 21, participated in a robbery with Shaun P. During the robbery, Briscoe and Shaun P. both had guns. A struggle ensued, resulting in Ben P., the robbery victim, fatally shooting Shaun P. Briscoe was charged with first-degree murder, robbery, and burglary, with firearm-use enhancements and a special circumstance of murder during a robbery and burglary. A jury convicted Briscoe on all counts, and he was sentenced to life without parole.Briscoe filed a motion in 2022 for a parole hearing under Penal Code section 3051, which allows certain youth offenders to seek parole but excludes those sentenced to life without parole for special circumstance murder. He argued that this exclusion violated equal protection under the California and U.S. Constitutions. The trial court denied his motion, adhering to the majority view that section 3051 did not violate equal protection. Briscoe appealed.The California Court of Appeal, First Appellate District, reviewed the case. The court noted that section 3051’s exclusion of youth offenders sentenced to life without parole for special circumstance murder was previously upheld in People v. Hardin. However, Briscoe raised a narrower challenge, arguing that excluding youth offenders sentenced under section 190.2, subdivision (d) for special circumstance murder, while including those convicted of first-degree felony murder under section 189, subdivision (e)(3), violated equal protection. The court agreed, finding no rational basis for treating these equally culpable offenders differently.The court reversed the trial court’s order and remanded the case for a Franklin proceeding and a section 3051 parole hearing, holding that section 3051’s exclusion of youth offenders sentenced under section 190.2, subdivision (d) for murder during a robbery or burglary violated equal protection. View "People v. Briscoe" on Justia Law

In March 2010, the defendant pled guilty to two counts of attempted murder and actively participating in a criminal street gang, resulting in a 22-year prison sentence. Approximately 12 years later, he filed a petition for resentencing under Penal Code section 1172.6. The trial court admitted statements the defendant made during a parole risk assessment interview and testimony from a parole hearing, ultimately denying the petition.The Superior Court of San Joaquin County initially handled the case, where the defendant's petition for resentencing was reviewed. The trial court admitted the parole hearing transcript and the defendant’s statements from the comprehensive risk assessment, despite objections from the defense counsel on grounds of hearsay and constitutional violations. The court found that the defendant’s statements demonstrated an intent to kill and denied the petition for resentencing.The California Court of Appeal, Third Appellate District, reviewed the case. The defendant argued that his statements and testimony from the parole proceedings should be subject to use immunity and were involuntary. The appellate court held that statements made in preparation for, and during, a parole hearing are not subject to use immunity under the reasoning of People v. Coleman and related authorities. The court also found that the statements were not involuntary, as the defendant was advised of his rights and chose to participate. The court concluded that the trial court did not err in admitting the statements and testimony, affirming the order denying the petition for resentencing. View "People v. Zavala" on Justia Law

The defendant was charged with three felonies related to firearm and ammunition possession. During a traffic stop, police officers discovered a loaded handgun in his vehicle. The defendant moved to suppress the evidence, arguing that the search violated his Fourth Amendment rights. The trial court granted the motion, finding that the traffic stop was unduly prolonged and pretextual, and dismissed the case.The Sonoma County Superior Court found that the traffic stop was pretextual and unduly prolonged, as the officers could have issued the citation at the gas station where they first observed the defendant. The court also noted that new legislation would make pretextual stops illegal, although this law was not yet in effect. The court concluded that the stop was designed to allow time for a canine unit to arrive and conduct a search, which it deemed unreasonable.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the trial court's finding of an unduly prolonged stop was unsupported by substantial evidence. The appellate court noted that the traffic stop began when the vehicle was pulled over, not when the officers first observed the defendant. The court found that the time taken to write the citation and conduct the canine search was within the normal duration for such activities. Additionally, the court clarified that the new Vehicle Code section 2806.5, which prohibits pretextual stops, was not in effect at the time of the stop and does not alter the federal constitutional analysis regarding pretextual stops. The appellate court reversed the trial court's order suppressing the evidence and remanded the case for further proceedings. View "People v. Valle" on Justia Law

In 2017, Michael Ingram was found to be a sexually violent predator (SVP) and committed to the State Department of State Hospitals (DSH) for an indeterminate term under the Sexually Violent Predator Act (SVPA). In 2020, he filed a petition for conditional release, arguing he was not likely to engage in sexually violent criminal behavior if released under supervision and treatment in the community. The trial court denied his petition, and Ingram appealed, challenging both the trial court’s decision and the constitutionality of the SVPA’s conditional release provisions.The Superior Court of Sacramento County initially handled the case, where a jury found Ingram to be an SVP. Ingram then filed a petition for conditional release, which the trial court denied. The court found that Ingram had not made significant progress in his treatment program and that his risk to the community remained unchanged. The court also noted that while Ingram might receive better treatment in the community, the issue before the court was whether he could be safely released, not whether he could receive better treatment elsewhere.The California Court of Appeal, Third Appellate District, reviewed the case. The court affirmed the trial court’s decision, finding that substantial evidence supported the denial of Ingram’s petition. The appellate court noted that all experts agreed Ingram continued to meet the definition of an SVP and that he had not yet learned to control his sexually violent behavior. The court also found that Ingram’s proposed alternative conditional release program, which included 24/7, one-on-one supervision, was neither reasonable nor required by the SVPA. Additionally, the court rejected Ingram’s constitutional challenges, noting that these issues were not properly raised in the lower court and that Ingram lacked standing to challenge potential delays in finding housing for conditionally released SVPs. View "People v. Ingram" on Justia Law

The City of Gridley operates an electric utility and approved reduced electric rates for residential users in September 2020. Plaintiffs, residential ratepayers, challenged these rates, alleging they resulted in charges exceeding the reasonable cost of providing electric service, thus constituting a tax without voter approval in violation of article XIII C of the California Constitution. They also claimed the rates violated the state and federal takings clauses under the unconstitutional conditions doctrine. Plaintiffs sought a writ of mandate and class action complaint, alleging the City set rates higher than necessary and transferred excess revenues to its general fund.The Superior Court of Butte County denied the City’s motion for summary judgment, finding triable issues of fact regarding whether the rates resulted in excessive charges and whether plaintiffs had a property interest in continued electric service. The court rejected the City’s argument that article XIII C was inapplicable because the City did not impose, extend, or increase a tax when it approved reduced rates. The court also found that the unconstitutional conditions doctrine could apply to plaintiffs' takings claim.The California Court of Appeal, Third Appellate District, reviewed the case and concluded that the City was entitled to relief. The court found article XIII C inapplicable because the City did not impose, extend, or increase any tax by reducing its electric rates. The court also found the unconstitutional conditions doctrine inapplicable, as it applies only in the land-use permitting context, not to user fees like the electric rates in question. Consequently, the court directed the trial court to set aside its order denying the City’s motion for summary judgment and to enter a new order granting the motion. The City’s motion for summary judgment was granted, and the stay of proceedings in the trial court was vacated. View "City of Gridley v. Super. Ct." on Justia Law

Sutter’s Place, Inc., which operates Bay 101 Casino, challenged the City of San Jose's annual cardroom regulation fee, arguing it was an unconstitutional tax imposed without voter approval and violated due process. The fee was equally divided between Bay 101 and Casino M8trix, the only two cardrooms in the city. The plaintiff contended that the fee included costs outside the constitutional exception for regulatory charges and that the equal allocation was unfair.The Santa Clara County Superior Court held a bench trial and found the fee valid, covering reasonable regulatory costs and fairly allocated between the cardrooms. The court determined the fee was for regulatory functions, the amount was necessary to cover costs, and the equal allocation was reasonable given the equal number of tables and benefits to both cardrooms. The court also excluded certain expert testimony from the plaintiff and denied a separate due process trial.The California Court of Appeal, Sixth Appellate District, reviewed the case. It upheld the trial court's finding that the equal allocation of the fee was reasonable but reversed the judgment on other grounds. The appellate court found the trial court erred by not specifically determining whether all costs included in the fee fell within the constitutional exception for regulatory charges. The case was remanded for the trial court to identify and exclude any non-permissible costs from the fee and to conduct further proceedings on the due process claim if necessary. The appellate court also reversed the award of costs to the city and directed the trial court to reassess costs after applying the correct legal standards. View "Sutter's Place, Inc. v. City of San Jose" on Justia Law

Nathaniel DiMaggio filed a petition for writ of mandate to challenge the denial of his motion to suppress evidence obtained from his cellphone and tablet. DiMaggio argued that the Monterey County Sheriff’s Office exceeded the scope of the search warrant and that the trial court erred in finding the sheriff’s office acted in good faith. The Monterey County District Attorney contended that the sheriff’s office properly executed the search warrant and acted in good faith.The Monterey County Superior Court issued a search warrant authorizing the search of DiMaggio’s cellphone and tablet for evidence related to a sexual assault within a specific date range. During the search, the sheriff’s office found images of suspected child pornography, which were outside the specified date range. DiMaggio filed a motion to suppress this evidence, arguing it was obtained in violation of the Fourth Amendment. The trial court found that the sheriff’s office exceeded the scope of the warrant but denied the motion to suppress, applying the good faith exception to the exclusionary rule.The California Court of Appeal, Sixth Appellate District, reviewed the case and agreed with DiMaggio. The court found that the sheriff’s office knowingly exceeded the scope of the search warrant by including items without timestamps, which were not authorized by the warrant. The court held that the good faith exception did not apply because the actions of the sheriff’s office were not objectively reasonable and were part of a standard protocol that disregarded the warrant’s limitations. The court issued a peremptory writ of mandate directing the trial court to vacate its order denying the motion to suppress and to enter a new order suppressing any evidence obtained outside the date and time limitations set forth in the search warrant. View "DiMaggio v. Superior Court" on Justia Law