Justia Constitutional Law Opinion Summaries

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

In 1987, Michael Hill was convicted of two murders and sentenced to death. Hill maintained that the murders were committed by Michael McCray, whose statements to the police incriminated both himself and Hill. McCray did not testify at trial, invoking his privilege against self-incrimination, but his statements were admitted under the hearsay rule. Decades later, Hill discovered that the prosecution had failed to disclose a promise not to prosecute McCray for his involvement in the case. Hill filed a habeas corpus petition alleging violations of Brady v. Maryland and Napue v. Illinois.The trial court dismissed Hill’s claims, finding he failed to establish a prima facie case. The court concluded that the evidence against Hill was overwhelming and that the failure to disclose the non-prosecution agreement did not undermine confidence in the verdict. The court also found that Hill did not plead that false evidence was presented to the jury, as required under Napue.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court found that Hill established a prima facie case for both Brady and Napue violations. The court noted that McCray’s testimony at the preliminary hearing was misleading and that the prosecution’s suppression of the non-prosecution agreement allowed McCray to assert his privilege against self-incrimination, leading to the admission of his statements without cross-examination. The court concluded that the suppressed evidence was material and could have affected the jury’s verdict. The court reversed the trial court’s order and remanded the case for further proceedings, directing the trial court to issue an order to show cause. View "In re Hill" on Justia Law

In this case, two defendants were tried for multiple assaultive incidents that occurred in 2017. The first incident involved the defendants accosting a man in Pacific Beach, where one defendant punched the victim and the other stole his bike. The second incident took place in Chula Vista, where the defendants attempted to rob a man carrying a shopping bag. The third incident occurred in the Gaslamp Quarter, where one defendant punched an inebriated man, leading to a brawl during which the other defendant fatally stabbed one man and seriously injured another.The Superior Court of San Diego County found both defendants guilty of conspiracy to commit robbery and robbery for the Pacific Beach and Chula Vista incidents. One defendant was also found guilty of premeditated murder, attempted murder, and assault by force likely to produce great bodily injury for the Gaslamp Quarter incident. The other defendant was convicted of involuntary manslaughter and assault by force likely to produce great bodily injury for the same incident.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court concluded that the trial court erred by giving a modified version of CALCRIM No. 375, which used a preponderance of the evidence standard for the jury’s consideration of evidence of the charged Pacific Beach and Chula Vista crimes. This instruction effectively lowered the prosecution’s burden of proving those crimes beyond a reasonable doubt, resulting in a violation of the due process clause of the Fourteenth Amendment. Such a structural error is reversible per se.The Court of Appeal reversed both defendants’ convictions for the Pacific Beach and Chula Vista crimes (counts 5–7) and remanded for further proceedings. The court affirmed the remaining convictions related to the Gaslamp Quarter incident, finding no prejudicial error in those respects. View "P. v. Holliday" on Justia Law

Two police officers on routine patrol stopped a car for a traffic violation. Officer Booth approached the driver, Luis Ramirez, while Officer Driscoll approached the passenger side. Booth ordered Ramirez out of the car after noticing a bulge at Ramirez’s waistband, suspecting he might be armed. As Ramirez exited the car, Driscoll saw a handgun behind the driver’s seat. Ramirez filed a motion to suppress the evidence found during the stop.The Superior Court of Orange County granted Ramirez’s motion to suppress, reasoning that there was no change in circumstances regarding the officers’ safety between the beginning of the stop and the point at which Ramirez was removed from his car. The court dismissed the case because the prosecution could not proceed without the excluded evidence. The Orange County District Attorney appealed the decision.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court found that under the Fourth Amendment, once a vehicle is lawfully detained for a traffic violation, an officer may order the driver to exit the vehicle without any additional justification. The court determined that Officer Booth’s actions were permissible and that there were no Fourth Amendment violations. Consequently, the appellate court reversed the trial court’s dismissal order and remanded the matter with directions to deny Ramirez’s motion to suppress evidence. View "P. v. Ramirez" on Justia Law

In 2019, the California Legislature enacted Assembly Bill No. 218 (AB 218), which allowed plaintiffs to bring childhood sexual assault claims against public entities within a three-year window, even if those claims were previously barred by statutes of limitations or claim presentation requirements. A.M.M. filed a complaint against the West Contra Costa Unified School District, alleging sexual assaults by a District employee from 1979 to 1983. The District argued that reviving such claims constituted an unconstitutional gift of public funds under the California Constitution. The trial court overruled the District’s demurrer, leading the District to seek writ review.The trial court sustained the demurrer for the first three causes of action but overruled it regarding the gift clause argument. The District then petitioned the California Court of Appeal, First Appellate District, for a writ of mandate to sustain the demurrer in its entirety. The appellate court issued an order to show cause, and both parties filed responses, including amicus curiae briefs from various entities.The California Court of Appeal, First Appellate District, held that AB 218’s retroactive waiver of the claim presentation requirement did not constitute an unconstitutional gift of public funds. The court reasoned that the waiver did not create new substantive liability but merely removed a procedural barrier to existing claims. The court also found that AB 218 served a valid public purpose by providing relief to victims of childhood sexual assault, aligning with the state’s interest in public welfare. Additionally, the court ruled that the District lacked standing to assert due process claims under both the federal and California Constitutions. The petition for writ of mandate was denied. View "West Contra Costa Unified School District v. Superior Court" on Justia Law

Travis Mitchell Hicks was convicted by a jury of attempted murder and assault with a semiautomatic firearm, among other charges, following a shooting incident at a bar. The altercation began with an argument between Hicks and the victim, who was intoxicated. Hicks claimed he shot the victim in self-defense after being threatened. The victim was shot in the arm and back, resulting in paralysis. Hicks fled but was apprehended the next day and eventually admitted to the shooting. The Riverside County District Attorney charged Hicks with multiple offenses, including attempted murder and assault, and the jury found him guilty on all counts.In the Superior Court of Riverside County, Hicks's defense objected to the prosecutor's use of a peremptory challenge to dismiss an African-American juror, arguing it was discriminatory under Batson v. Kentucky and People v. Wheeler. The trial court allowed the challenge, accepting the prosecutor's reasons that the juror's prior felony convictions and opinionated demeanor were race-neutral justifications. Hicks was sentenced to a combined determinate and indeterminate prison term.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court found that the trial court erred in accepting the prosecutor's reasons for the peremptory challenge. The appellate court determined that the juror's prior felony convictions and alleged opinionated demeanor were not supported by the record as valid, race-neutral reasons. Consequently, the appellate court reversed the judgment and remanded the case for a new trial. View "P. v. Hicks" on Justia Law

The defendant was arrested for driving under the influence of drugs and bribing an executive officer. During the arrest, the officer observed signs of intoxication and conducted field sobriety tests, which the defendant failed. A preliminary alcohol screening test showed no alcohol, leading the officer to suspect drug use. The defendant admitted to using cannabis and Alprazolam. At the police station, the defendant initially agreed to a blood test but later refused without a warrant. The officer obtained a warrant, and the blood test confirmed the presence of drugs. The defendant was charged and convicted of DUI and bribery.The Superior Court of California, County of Marin, handled the initial trial. The court instructed the jury with CALCRIM No. 2130, allowing them to infer consciousness of guilt from the defendant's refusal to submit to a blood test. The defendant was found guilty on both counts and sentenced to three years of probation and 180 days in jail. The defendant appealed, arguing that the jury instruction was improper because he had a constitutional right to refuse the blood test without a warrant.The California Court of Appeal, First Appellate District, reviewed the case. The court held that the instruction was proper, stating that while the Fourth Amendment prohibits criminal penalties for refusing a blood test without a warrant, it does not prohibit all consequences. The court emphasized that implied consent laws can impose civil penalties and evidentiary consequences for refusal. The court affirmed the lower court's judgment, concluding that the instruction did not violate the defendant's constitutional rights. View "People v. Bolourchi" on Justia Law