Justia Constitutional Law Opinion Summaries

The Minor in this case was the subject of several delinquency petitions. Minor was eventually placed in foster care. Minor appealed, arguing the dispositional order placing him in foster care had to be reversed because the juvenile court had failed to comply with the notice requirements of the Indian Child Welfare Act (INCA). The court of appeals affirmed, holding notice was not required because federal law specifically excludes delinquency cases from ICWA, and any interpretation of California law that would expand ICWA's application to delinquencies would be invalid under federal preemption principles. The Supreme Court affirmed, holding (1) California law requires the court to inquire about a child's Indian status at the outset of all juvenile proceedings, but ICWA's additional procedures are not required in most delinquency cases; (2) a delinquency court must ensure that notice is given and other ICWA procedures are complied with only under certain circumstances; and (3) assuming Minor was an Indian child, the juvenile court did not err in failing to give notice under ICWA in this case.

A jury convicted Defendant of the first degree murder of a Los Angeles County sheriff's deputy. The jury found true the special circumstance allegations that Defendant committed the murder to avoid a lawful arrest and that he knew or should have known that the victim was a peace officer performing his duties. The jury also found that Defendant was armed with and personally used a firearm during the offense. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment after examining (1) pretrial and guilt phase issues, (2) penalty phase issues, and (3) challenges to the death penalty law, holding that the trial court correctly convicted and sentenced Defendant.

A jury convicted Defendant of first degree murder and found true the robbery-murder and burglary-murder special circumstance allegations. The jury also convicted Defendant of first degree robbery, first degree burglary, and kidnapping for robbery, finding as to these counts that the victim was sixty-five years or older. The jury additionally convicted Defendant of two counts of second degree burglary. The trial court imposed a sentence of death for the murder. With respect to the remaining counts, the trial court imposed, among other things, the upper term of nine years for carjacking plus one year for the elderly victim enhancement. The Supreme Court affirmed the death judgment as modified, concluding that the judgment should be modified to stay the sentence on the carjacking count, as Defendant could not be punished for both carjacking and kidnapping for robbery because the prosecutor argued to the jury that the victim's car was the object of the robbery.

A jury convicted Defendant of the first degree murders of four persons and found true a multiple-murder special-circumstance allegation. The jury also convicted Defendant of the attempted murders of ten other persons and found true allegations that the attempted murders were willful, deliberate, and premeditated; that Defendant personally used a firearm in committing the murders and attempted murders; and that, except as to one person, Defendant personally inflicted great bodily injury in committing the attempted murders. The jury further convicted Defendant of assault with a firearm on three individuals and false imprisonment for the purpose of protection from arrest. After a sanity trial, the jury found Defendant to be sane. After a penalty phase, the jury returned a verdict of death. The trial court sentenced Defendant to death on the murder counts, life imprisonment on the attempted murder counts, and a determinate sentence on the remaining counts and enhancements. The Supreme Court affirmed the judgment of the district court, holding that the court did not err in its judgment.

Defendant Ivan Joe Gonzales was convicted of murdering four-year-old Genny Rojas. The jury found as a special circumstances that the murder was intentional and involved the infliction of torture. However, it was unable to reach a penalty verdict. Another jury was impaneled, and the second penalty phase trial resulted in a death verdict. After analyzing several aspects of the conviction of and sentence, including (1) guilt phase issues, and (2) penalty phase issues, the Supreme Court affirmed the judgment of the trial court, holding that the court did not err in its judgment.

After a jury trial, Defendant was convicted of various counts of kidnapping, robbery, and rape against five women. During the trial, the trial court modified pattern jury instruction CALCRIM No. 1191, which explains to a jury that it may consider a defendant's uncharged sexual offense as evidence of his or her propensity to commit a charged sexual offense, to permit to the jury to consider the defendant's charged sexual offenses as evidence of his propensity to commit the other charged sexual offenses. On appeal, Defendant challenged a modified pattern jury instruction based on People v. Quintanilla, which held that charged offenses could not be considered as propensity evidence under a similar provision and its corresponding jury instruction. The court of appeal rejected Defendant's challenges to the modified instruction. The Supreme Court affirmed, holding that under the facts of this case, the trial court did not err in giving the modified instruction.

Defendant was an adult who was diagnosed with mental retardation and other mental disorders. Because of her increasingly violent behavior, the People sought to civilly commit Defendant pursuant to Cal. Welf. & Inst. Code 6500. After a nonjury trial, the court ordered Defendant committed for one year. The court of appeal affirmed. At issue on appeal was whether Defendant's jury trial was validly waived if, as Defendant alleged, the court did not obtain Defendant's personal waiver of a jury. The Supreme Court affirmed after acknowledging that an individual facing commitment has cognitive and intellectual impairments that would prevent him or her from making a meaningful decision whether to invoke, or waive, the right to a jury trial, holding (1) Defendant was not denied due process and equal protection of the law insofar as the record did not reveal the circumstances under which Defendant was tried by the court, rather than by a jury, as (2) an individual facing commitment in section 6500 proceedings is protected by the state's statutory obligation to provide counsel, and (3) it is counsel who must make the tactical decision whether to seek or waive a jury in section 6500 proceedings.

An amended information charged Defendant Richard Tully with the 1986 murder of Shirley Olsson and assault with intent to commit rape. The information also alleged a special circumstance that the murder was committed in the commission of a burglary and, as to both counts, that Defendant used a dangerous and deadly weapon: a knife. A jury convicted Defendant as charged and found true the special circumstance and weapon allegations. It then returned a verdict of death, which the trial court declined to modify. The Supreme Court affirmed the trial court's judgment in its entirety, holding, among other things, that California's death penalty statute was constitutional.

A jury convicted Defendant Keith Thomas of the first degree murder of Francia Young, of kidnapping her for the purpose of robbery, of forcibly raping her, and of forcibly sodomizing her. The jury also convicted Defendant of robbing Sebrena Flennaugh, assaulting two peace officers with an assault weapon, and being a felon in possession of a firearm. The jury returned a verdict of death for the murder of Young. The trial court sentenced Defendant to death, imposed a concurrent sentence of life with the possibility of parole for the kidnapping of Young, and stayed imposition of sentence on the remaining counts. The Supreme Court affirmed the judgment in its entirety, holding that the trial court did not err in its judgment.

Burglary is committed when a person enters a building with the intent of committing larceny or any felony. In People v. Valencia, the Supreme Court held that a building is entered when the building's "outer boundary" is crossed. An "unenclosed balcony," Valencia noted in a footnote, was not part of a building's outer boundary. Defendant in this case was charged with residential burglary after climbing onto a second-story apartment's private balcony, which was surrounded by a metal railing four feet in height and accessible only through the single bedroom's sliding glass door. The trial court instructed the jury that such a balcony was within the apartment's outer boundary, and the jury convicted Defendant. The court of appeal reversed, relying on Valencia. The Supreme Court reversed, holding (1) a second floor apartment's balcony is part of the apartment when the balcony is designed to be entered from and offers an extension of the apartment's living space; (2) this holding was not fully reflected in the trial court's jury instruction, as the instruction's language was overbroad; but (3) Defendant was not prejudiced by this error.