Justia Constitutional Law Opinion Summaries

Samuel Scott Copeland was convicted by a jury of attempting to prevent or dissuade a witness from giving testimony, in violation of Penal Code section 136.1, subdivision (a)(2). The conviction was based on allegations that Copeland withheld rent to pressure his friend and landlord, Madelyn Wagner, from testifying in a civil dispute involving their mutual friend, Trina West. The trial court sentenced Copeland to two years of formal probation and imposed but stayed a sentence of 365 days in custody, pending successful completion of probation.The Superior Court of San Diego County declined to reduce the charge to a misdemeanor. Copeland appealed, arguing that substantial evidence did not support the finding that Wagner was a “witness” within the meaning of section 136, subdivision (2) at the time of the alleged intimidation, that the jury instruction improperly expanded the definition of “witness,” and that the prosecution violated his First Amendment right to free speech.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court concluded that the term “witness” as defined in section 136, subdivision (2) does not include potential future witnesses to a civil dispute. Therefore, there was not substantial evidence that Wagner was a “witness” as used in the statute of conviction. Additionally, the court found that the model instruction given to the jury misstated the law in a prejudicial manner by improperly expanding the definition of “witness” to include potential future witnesses.As a result, the Court of Appeal reversed the judgment, holding that the conviction was not supported by substantial evidence and that the jury instruction contained a prejudicial misstatement of the law. View "P. v. Copeland" on Justia Law

The case involves two charitable organizations, Catholic Medical Mission Board, Inc. (CMMB) and Food for the Poor, Inc. (FFP), which were issued cease and desist orders and civil penalties by the California Attorney General for allegedly overvaluing in-kind donations and making misleading statements in their solicitations. The Attorney General found that both organizations used inflated domestic market prices for donated medicines, which could not be distributed within the U.S., and misrepresented their program efficiency ratios to donors.The Superior Court of Los Angeles County reviewed the case and found that the challenged statutory provisions, sections 12591.1(b) and 12599.6(f)(2) of the Government Code, were unconstitutional as they constituted prior restraints on speech. The court vacated the civil penalties and issued permanent injunctions against the Attorney General, preventing the enforcement of these provisions. The court also reformed section 12591.1(b) by adding language to exclude violations of section 12599.6 from the Attorney General's cease and desist authority.The California Court of Appeal, Second Appellate District, reviewed the case and concluded that the trial court abused its discretion by granting the permanent injunctions without requiring the plaintiffs to plead and prove their entitlement to such relief. The appellate court vacated the injunctions and remanded the case to allow the plaintiffs to amend their complaints and prove their entitlement to injunctive relief. The appellate court affirmed the trial court's reformation of section 12591.1(b), allowing the Attorney General to issue cease and desist orders for violations unrelated to speech. The appellate court also vacated the postjudgment orders awarding attorney fees and directed the trial court to reconsider the fees in light of the remand. View "Catholic Medical Mission Board v. Bonta" on Justia Law

A bakery, owned by Catharine Miller, refused to sell a predesigned, plain white cake to a same-sex couple, the Rodriguez-Del Rios, for their wedding reception. The bakery's policy prohibited the sale of any preordered cake for same-sex weddings based on Miller's religious beliefs that marriage is between a man and a woman. The couple ultimately obtained a similar cake from another bakery.The Civil Rights Department (CRD) filed a lawsuit against the bakery and Miller, alleging discrimination under the Unruh Civil Rights Act (UCRA). The Kern County Superior Court ruled in favor of the bakery, concluding there was no intentional discrimination and that Miller's referral of the couple to another bakery constituted full and equal access under the UCRA. The court also found that the bakery's refusal was protected by the First Amendment as both pure speech and expressive conduct.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court determined that the bakery's policy was facially discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court concluded that the trial court erred in its determination that the policy was facially neutral and in its application of the intentional discrimination standard. The court also found that Miller's referral to another bakery did not satisfy the UCRA's full and equal access requirement.Regarding the First Amendment defenses, the appellate court held that the plain white cake was not pure speech or expressive conduct protected by the First Amendment. The court reasoned that the cake was a generic, multi-purpose product and did not convey any particularized message about marriage. The court also upheld the UCRA's application under the federal and state Constitutions' free exercise clauses, concluding that the law is neutral and generally applicable and that there are no less restrictive means to achieve the state's compelling interest in ensuring full and equal access to goods and services irrespective of sexual orientation. The appellate court reversed the trial court's judgment and remanded the case for further proceedings. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

In September 2022, Antoine Leon Richardson had an altercation with Mckyla Middleton at a liquor store in Lancaster, California. Richardson accused Middleton of cutting him off, threatened her, and flashed a gun at her from a satchel. In November 2022, police searched Richardson’s home and found ammunition but no firearms. Richardson admitted to brandishing the gun during the altercation and owning the ammunition.The Los Angeles County Superior Court charged Richardson with being a felon in possession of a firearm, being a felon in possession of ammunition, and misdemeanor exhibiting a concealable firearm in public. The jury found Richardson guilty on all counts and confirmed his prior felony convictions. The court sentenced him to three years and eight months in prison for the firearm and ammunition charges, with a concurrent 364-day term for the misdemeanor.The California Court of Appeal, Second Appellate District, reviewed the case. Richardson argued that his convictions for firearm and ammunition possession violated the Second Amendment, citing New York State Rifle & Pistol Association, Inc. v. Bruen. The court disagreed, stating that the Second Amendment protects law-abiding citizens, not felons. The court also found that substantial evidence supported the trial court’s finding that Richardson had separate objectives for possessing and exhibiting the firearm, thus allowing multiple sentences under Penal Code section 654.The Court of Appeal affirmed the trial court’s judgment, upholding Richardson’s convictions and sentences. View "People v. Richardson" on Justia Law

Michael Lovelace was charged with multiple felonies, including rape and aggravated kidnapping, along with special sentencing enhancements and aggravating factors under California Rules of Court, rule 4.421(c). Lovelace challenged the constitutionality of the rule 4.421(c) residual clause, which allows for consideration of any other factors that reasonably relate to the defendant or the circumstances under which the crime was committed. He argued that this clause violated the separation of powers and due process principles.The trial court denied Lovelace's motion to set aside the information, leading him to seek interlocutory review by petition for a writ of prohibition. The Court of Appeal of the State of California, First Appellate District, Division Four, issued an order to show cause and held oral arguments. Following the Supreme Court's decision in People v. Lynch, which provided guidance on the interpretation and application of Senate Bill 567 amendments to section 1170, subdivision (b)(2), the court took supplemental briefing.The Court of Appeal granted writ relief, holding that the rule 4.421(c) residual clause is unconstitutionally vague and exceeds the Judicial Council’s delegated authority to adopt rules promoting uniformity in sentencing. The court found that the clause grants prosecutors and juries open-ended power to define sentencing criteria on an ad hoc basis, violating the separation of powers clause of the California Constitution. The court directed the trial court to vacate its order denying Lovelace's section 995 motion and to enter a new order sustaining the motion to the extent it seeks to invalidate the residual clause. The court prohibited the trial court from allowing a jury to consider any findings based on the rule 4.421(c) residual clause. View "Lovelace v. Superior Court" on Justia Law

A bakery refused to sell a predesigned white cake to a same-sex couple for their wedding reception, citing a policy against providing cakes for same-sex weddings based on the owner's religious beliefs. The California Civil Rights Department (CRD) filed a lawsuit on behalf of the couple, alleging discrimination under the Unruh Civil Rights Act (UCRA). The trial court ruled in favor of the bakery, finding no violation of the UCRA because the CRD failed to prove intentional discrimination and concluded that referring the couple to another bakery constituted full and equal access under the UCRA. The trial court also considered the bakery's First Amendment defenses, concluding that the UCRA compelled the bakery to speak a message about marriage to which they objected.The CRD appealed, challenging the trial court's interpretation and application of the UCRA and its conclusions regarding the bakery's affirmative defenses. The California Court of Appeal reviewed the case and determined that the bakery's policy was not facially neutral and misconstrued the intentional discrimination standard. The court found that the policy was inherently discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court also concluded that referring the couple to another bakery did not satisfy the UCRA's full and equal access requirement.The court further analyzed the bakery's First Amendment defenses, determining that the cake in question did not constitute pure speech or expressive conduct protected by the First Amendment. The court found that the cake was a generic, multi-purpose product and that its preparation and delivery did not convey any particularized message about marriage. Additionally, the court concluded that the UCRA is a neutral and generally applicable law that satisfies rational basis review and does not violate the bakery's free exercise of religion under the federal or state constitutions.The California Court of Appeal reversed the trial court's judgment and remanded the case for further proceedings consistent with its opinion. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

The Coachella Valley Water District (Water District) appealed a judgment finding that the rates it charged for Coachella Canal water violated Article XIII C of the California Constitution. The Water District argued that the rates were lawful and that no refund remedy was authorized. The court rejected both arguments, finding the rates unlawful and that a refund remedy was constitutionally mandated.In the lower court, the Superior Court of Riverside County ruled that the Water District's Canal Water rates and the Irrigation Water Availability Assessment (IWAA) violated Proposition 218. The court found that the Water District's historical priority argument was not persuasive and that the Water District had made no attempt to show that the rates complied with the California Constitution. The court deferred ruling on remedies and later awarded Class 2 customers approximately $17.5 million in refunds and interest for invalid charges from March 2018 through June 2022.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that Howard Jarvis Taxpayers Association (Howard Jarvis) had standing to challenge the Class 2 rates because domestic customers paid the rates indirectly. The court found that the Class 2 rates were taxes under Article XIII C and did not fall under any exceptions. The court rejected the Water District's arguments that the rates were justified based on historical priority and that they were expenditures of funds. The court also found that the IWAA was an assessment under Proposition 218 and that the Water District failed to show it was proportional to the benefits conferred on the properties.The court affirmed the lower court's ruling on liability and the amount of refund relief awarded. However, the court found that the injunction in the judgment was overbroad and modified the judgment to strike the paragraph enjoining the Water District from imposing any future Canal Water rates and charges that did not comply with Proposition 218. As modified, the judgment was affirmed, and Howard Jarvis was awarded its costs on appeal. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

Christopher Hamilton was convicted of federal felony possession of child pornography. After a federal district court terminated his federal sex offender registration requirement, the California Attorney General notified him of his lifetime obligation to register under California law, pursuant to Penal Code section 290.005(a). The Attorney General determined that the state law equivalent of Hamilton’s federal offense required lifetime registration, placing him in the highest tier of California’s three-tier scheme.Hamilton petitioned the Superior Court of Los Angeles County to terminate his state registration requirement. The Superior Court denied his petition and a subsequent amended motion. Hamilton appealed the denials, arguing violations of equal protection and due process.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the Attorney General’s classification of Hamilton’s offense as a felony with a lifetime registration requirement did not violate equal protection. The court reasoned that the federal offense’s classification as a felony, based on custodial exposure, justified the equivalent state offense’s classification as a felony. Additionally, the court found that the federal offense’s requirement of interstate or foreign commerce provided a rational basis for the different treatment.The court also rejected Hamilton’s due process challenge, concluding that he received notice and had opportunities to contest his tier designation through his petition and amended motion. Lastly, the court dismissed Hamilton’s vagueness challenge, finding that the term “equivalent” in section 290.005(a) was sufficiently clear when considered in context with other statutory provisions.The Court of Appeal affirmed the Superior Court’s orders denying Hamilton’s petition and amended motion. View "People v. Hamilton" on Justia Law

Trevon Bey was convicted by a jury of possession of a firearm by a felon and carrying a loaded firearm in public. The trial court dismissed a prior strike conviction and sentenced Bey to three years for each count, to be served concurrently. Bey appealed, arguing that the trial court improperly revoked his self-representation status, that his conviction for possession of a firearm by a felon violated his Second Amendment rights, and that California's concealed carry laws were unconstitutional under a recent Supreme Court decision.The Superior Court of Los Angeles County initially allowed Bey to represent himself but later revoked this status due to his disruptive behavior and failure to follow court rules. Bey repeatedly challenged the court's authority, disrespected the court, and disrupted proceedings, despite multiple warnings. The court appointed standby counsel to represent him, citing his inability to adhere to courtroom protocol.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the trial court did not abuse its discretion in revoking Bey's self-representation status due to his continuous disruptive conduct. The court also found that Bey's conviction for possession of a firearm by a felon did not violate his Second Amendment rights, referencing recent Supreme Court decisions that upheld prohibitions on firearm possession by felons. Additionally, the court rejected Bey's challenge to California's concealed carry laws, noting that the unconstitutional "good cause" requirement was severable from the rest of the licensing scheme.The Court of Appeal agreed with both parties that the sentence for carrying a loaded firearm in public should be stayed under Penal Code section 654, as it was based on the same act as the possession charge. The court modified the judgment to stay the sentence on count 2 and affirmed the judgment as modified. View "People v. Bey" 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 this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, previously found merit in Field's equal protection argument 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 determined that the People had not met their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated and ordered new commitment trials for both Field and Asher.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 equal protection violation was not justified. View "P. v. Field" on Justia Law