Justia Constitutional Law Opinion Summaries

Defendant was charged with vehicular manslaughter while intoxicated after her vehicle collided with another, killing its driver. To prove intoxication, the prosecution at trial introduced into evidence a laboratory analyst's report on the percentage of alcohol in a blood sample taken from Defendant two hours after the accident. The analyst did not testify, but a colleague did. A jury found Defendant guilty as charged. The court of appeal reversed, holding that the admission of the nontestifying analyst's laboratory report and the colleague's testimony relating some of the report's contents violated Defendant's right to confront and cross-examine the report's author. The Supreme Court reversed, holding that the nontestifying analyst's laboratory report was not testimonial in nature, and the trial court did not err in permitting the prosecution to introduce that portion of the report into evidence, and in permitting the colleague to testify regarding it. View "People v. Lopez" on Justia Law

At Defendant's murder trial, a forensic pathologist testifying for the prosecution described to the jury objective facts about the condition of the victim's body as recorded in the autopsy report and accompanying photographs. Based on those facts, the expert gave his independent opinion that the victim had died of strangulation. Neither the autopsy report, which was prepared by another pathologist who did not testify, nor the photographs were introduced into evidence. The court of appeal reversed Defendant's conviction for second degree murder, holding that the expert's testimony violated Defendant's Sixth Amendment right to confront and cross-examine the preparer of the autopsy report, and that the error was prejudicial. The Supreme Court reversed, holding that the trial court did not err in admitting the expert's testimony over a Confrontation Clause objection, as the statements of the preparer of the autopsy report were not testimonial, and the Confrontation Clause did not bar their use. View "People v. Dungo" on Justia Law

This case involved the second habeas corpus petition filed by Petitioner, who was sentenced to death. The petition was an "exhaustion petition," which sought to exhaust state claims in order to raise them in federal court. Nearly all of Petitioner's claims raised legal issues that were not cognizable or were procedurally barred. The Supreme Court denied the writ after taking the opportunity to establish new ground rules for exhaustion petitions in capital cases, holding (1) this petition exemplifies abusive writ practices; and (2) following finality of this opinion, exhaustion petitions in capital cases will be subject to the page limits and other rules described in this opinion.

In People v. Carmony (Carmony II), a decision of the California court of appeal concluded that a twenty-five-year-to-life sentence under the Three Strikes law constituted cruel and/or unusual punishment as applied to a defendant whose triggering offense was the failure to annually update his sex offender registration within five working days of his birthday. In the present habeas corpus proceeding, the court of appeal, considering the constitutionality of a twenty-five-year-to-life sentence imposed upon Defendant, who also was convicted of failing to update his sex offender registration within five working days of his birthday, expressly disagreed with the conclusion of the appellate court in Carmony II and held that the punishment was constitutionally permissible. The Supreme Court affirmed on other grounds, holding that Defendant's sentence here did not constitute cruel and unusual punishment under the circumstances of this case, but this holding did not rest upon a determination that Carmony II was wrongly decided.

Defendant was charged with two separate crimes, murder and participation in a criminal street gang. The court failed to include the standard reasonable doubt instruction prior to the jury's deliberations. The court's instructions with regard to the murder charge did inform the jury that it must find every element of that charge must be proved beyond a reasonable doubt. The instruction relating to the gang offense did not include similar reasonable doubt language. The jury found Defendant guilty of the lesser offense of voluntary manslaughter and of the gang offense. The court of appeals reversed Defendant's conviction of the gang offense. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court's omission of the standard reasonable doubt instruction did not constitute federal constitutional error as to the voluntary manslaughter conviction, and although the omission amounted to state law error as to that conviction, the error was harmless; and (2) with respect to the gang offense, the failure to instruct the jury to prove the elements of the crime beyond a reasonable doubt constituted error under both state law and the federal constitution, but the error was harmless.

Petitioner was found guilty of the murders of two brothers. The trial court sentenced Petitioner to death. The Supreme Court affirmed. Petitioner subsequently filed a habeas corpus petition for relief from the judgment of death. The Supreme Court ordered an evidentiary hearing on Petitioner's claim that the prosecution had failed to disclose evidence that would have supported a case in mitigation at the penalty phase that Petitioner committed the two murders because of a Colombian drug cartel's death threats against him and his family. The referee found merit to Petitioner's claim. The Supreme Court upheld the determination by the referee and granted Petitioner's habeas corpus petition, holding (1) substantial evidence supported the referee's determination, and (2) it was reasonably probable that Petitioner's penalty phase jury would have returned a verdict of life imprisonment without parole had it heard the evidence withheld by the prosecution.

In 2007, sixteen-year-old Defendant opened fire on three teenage boys who were members of a rival gang. A jury convicted Defendant of three counts of attempted murder. The jury found true that Defendant personally and intentionally discharged a firearm and inflicted great bodily harm on one victim and that Defendant committed the crimes for the benefit of a criminal street gang. Defendant's total sentence was 110 years to life. The court of appeal affirmed. At issue before the Supreme Court was whether the sentence contravened the mandate in Graham v. Florida against cruel and unusual punishment of juveniles convicted of nonhomicide offenses and sentenced to life imprisonment without the possibility of parole. The Court reversed, holding that consistent with the U.S. Supreme Court's holding in Graham, sentencing a juvenile offender for a nonhomicide offense to a term of years with a parole eligibility date that falls outside the juvenile offender's natural life expectancy constitutes cruel and unusual punishment in violation of the Eighth Amendment.

After a jury trial, Defendant, who spoke Spanish, was convicted of first degree murder. At issue on appeal was whether, while Defendant was in custody and after a law enforcement officer read Defendant his Miranda rights, Defendant's response to whether a detective could speak to Defendant was sufficiently ambiguous to justify the officer in seeking to clarify whether Defendant was attempting to invoke his right to counsel, or whether he was desirous of waiving his Miranda rights and speaking with the detective without an attorney present. The trial court concluded that Defendant's waiver of Miranda rights was voluntary, knowing and intelligent. The court of appeals reversed. The Supreme Court reversed, holding (1) Defendant's reply to the officer's inquiry was sufficiently ambiguous to justify her seeking further clarification of his intent, consistent with the Court's holding in People v. Williams; (2) Defendant's responses made clear he was willing to speak with the detective at that time without an attorney present; and (3) therefore, under the totality of the circumstances, Defendant's waiver of Miranda rights, including his right to counsel, was voluntary, knowing, and intelligent.

A jury convicted Defendant Richard Valdez of five counts of first degree murder. As to each count, the jury found true special circumstance allegations of multiple murder and gang and weapon enhancement allegations. The evidence presented at trial established that Defendant was a member of the Sangra street gang. The jury returned a verdict of death as to each of the victims. The trial court denied the automatic application to modify the verdict and sentenced Defendant to death for the five murders. The Supreme Court affirmed, holding, among other things, that Defendant's claims alleging numerous errors in connection with protective orders the trial court issued delaying and limiting disclosure of the identities of certain prosecution witnesses failed, and that the trial judge did not prejudicially err in refusing to declare a mistrial after the jurors declared they were at an impasse and could not reach a unanimous verdict on any count.

Defendant, an ex-felon on probation, planted an object near a government building that resembled a bomb and that caused fear and disruption when discovered. Defendant was convicted of violating Cal. Penal Code 148.1(d), which allows misdemeanor or felony punishment for anyone who maliciously places a false bomb with the intent to cause another person to fear for his own safety or the safety of others. Defendant's sentence included a twenty-five-years-to-life three strikes term based on the section 148.1(d) felony count and his prior serious and violent felony convictions. The court of appeal reduced the section 148.1(d) conviction to a misdemeanor, finding that the felony provision under which Defendant was convicted and sentenced denied him equal protection of the law when compared to an entirely different statute, Cal. Penal Code 11418.1, which provides that anyone who places a WMD with the intent to cause fear in others can be convicted of a felony only if the perpetrator's conduct causes another person to be placed in sustained fear, an element not necessary under the false bomb statute. The Supreme Court reversed, holding that no equal protection violation occurred, as the challenged distinction was not irrational.