Justia Constitutional Law Opinion Summaries

Defendant pled no contest to one count of assault by means of force likely to produce great bodily injury. Based on a negotiated disposition, the trial court sentenced Defendant to two years' incarceration. The question arose whether Defendant's prior conviction for burglary, which the trial court had stricken, nevertheless disqualified him from receiving day-for-day presentence conduct credits under Cal. Penal Code former 4019. Former section 4019 allowed prisoners in local custody to earn conduct credits against their term of confinement for work and good behavior. The possibility of early release, however, was withheld from prisoners who had a prior conviction for a serious or violent felony. The court concluded it had no power to disregard the prior conviction for purposes of credits and award 116 days of conduct credits rather than the 232 to which Defendant would otherwise have been entitled. The court of appeal reversed the judgment as to credits. The Supreme Court reversed, holding that Cal. Penal Code 1385, which permits a court in furtherance of justice to order an action to be dismissed, does not authorize a court to disregard the historical facts that disqualify a local prisoner from earning day-for-day conduct credits under former section 4019.

Defendant, driving while intoxicated, killed another driver instantly in a freeway collision. The accident left no surviving family, dependents, or heirs. Defendant was convicted and sentenced to prison. In addition, pursuant to the statute requiring that persons convicted of felonies pay restitution to the crimes' victims for their resulting economic loss, Defendant was also ordered to pay substantial restitutionary amounts to Decedent's estate. The award represented death-related loss in value of the decedent's business and property, and probate, estate administration, and funeral expenses. The court of appeal affirmed the award. The Supreme Court reversed, holding (1) mandatory restitution is not payable to the estate for economic loss the estate itself has sustained as a result of the death, but the decedent's personal representative is entitled to collect mandatory restitution on the decedent's behalf for economic loss the decedent personally incurred before death as an actual victim of the defendant's criminal conduct; (2) after the actual victim has died, he or she does not incur personal economic loss subject to mandatory restitution; and (3) there was no valid basis for any of the mandatory restitution amounts awarded to the estate in this case.

A jury found Defendant John Alexander Riccardi guilty of the first degree murders of Connie Navarro and Sue Jory by use of a firearm. The jury also found true the special circumstance allegations of multiple murder and that Defendant committed Connie's murder while engaged in the commission of a burglary. Subsequently, the jury fixed the penalty at death. The Supreme Court (1) reversed the judgment of death because of the erroneous excusal of a prospective juror during jury selection; (2) reversed the burglary special circumstance and one of the two multiple-murder special-circumstance findings; and (3) affirmed in all other respects.

A jury found Defendant guilty of robbery, as an aider and abetter, and attempted murder, on the theory that the nontarget offenses of attempted murder were a natural and probable consequence of the target offenses of robbery, which Defendant had aided and abetted. The jury further found that the attempted murders were willful, deliberate, and premeditated under Cal. Penal Code 664(a), which increases the punishment for attempted murder beyond the maximum otherwise prescribed when those findings are found true by the trier of fact. At issue on appeal was whether, as to the premeditation allegation under section 664(a), the jury needs to be instructed that a premeditated attempt to murder, not just attempted murder, must have been a natural and probable consequence of the target crime of robbery. The Supreme Court affirmed the court of appeal, holding (1) under the natural and probable consequences doctrine, there is no requirement that an aider and abettor reasonably foresee an attempted murder as the natural and probable consequence of the target offense; and (2) it is sufficient that attempted murder is a reasonably foreseeable consequence of the crime aided and abetted, and the attempted murder itself was committed willfully, deliberately, and with premeditation.

Defendant, a prison inmate, was charged with escape from custody. However, Defendant only broke out of his cell and breached interior security barriers. The jury found Defendant guilty of escape from prison without force or violence. The court of appeal reversed, finding insufficient evidence of escape and concluding that the term "escape" under the relevant statute required an actual escape beyond the outer boundary of the prison facility having custody of that prisoner. The court refused to modify the escape conviction to attempt to escape. The Supreme Court affirmed, holding that the court of appeal correctly determined it could not modify the escape conviction to an attempt to escape, as the record contained evidence that could lead a rational jury to find the element of specific intent lacking.

After a jury trial, Defendant was convicted of first-degree murder, burglary, and robbery. The trial court sentenced Defendant to death. The Supreme Court remanded the case, holding that the trial court committed reversible error by permitting Defendant to represent himself during proceedings to determine whether he was mentally competent to stand trial. To remedy the error, the Court remanded the case for further proceedings to allow the trial court to determine whether a retrospective evaluation of Defendant's competence to stand trial was feasible and, if it was, to hold such a hearing. If the trial court determined that such a hearing was not feasible or Defendant was incompetent, Defendant was entitled to a new trial.

Defendant Perla Gonzalez (Perla) recruited her brother and her boyfriend to assault Roberto Canas-Fuentes (Canas). After Canas fended off a knife attack and gained the upper hand in the fight, Perla handed the boyfriend a loaded rifle. Canas wrested the rifle away and shot the boyfriend dead. The jury convicted Perla of the attempted premeditated and deliberate murder of Canas and, based on the provocative act doctrine, the first degree murder of her boyfriend. The Supreme Court affirmed, holding (1) substantial evidence supported Perla's conviction for the murder of her boyfriend; and (2) the trial court erred in instructing the jury on the requirements for premeditated and deliberate first degree murder, but the error was harmless beyond a reasonable doubt.

A charter city entered into certain contracts for the construction of public buildings. A federation of labor unions then petitioned the superior court for a peremptory writ of mandate, asserting that the city must comply with California's prevailing wage law notwithstanding local ordinances stating otherwise. The prevailing wage law requires that certain minimum wage levels be paid to contract workers constructing public works. At issue on appeal was whether, under the state constitution, the subject matter of the state's prevailing wage law was a "statewide concern" over which the state has primary legislative authority, or whether the matter was a municipal affair and therefore governed by the charter city's local ordinances. The Supreme Court affirmed the court of appeal, which in turn affirmed the trial court's judgment denying the union's petition for a writ of mandate, holding that there was no statewide concern at issue in this case, and therefore, the state's prevailing wage law did not apply to the charter city.

On February 10, Donald Smith and Christopher Sims were charged with felony first degree residential burglary. Smith did not waive his statutory right to be brought to trial within sixty days of his arraignment, but the trial date of Sims was continued beyond the sixty-day period for good cause. The trial was set for April 27, which meant that the last day for trial, pursuant to Cal. Penal Code 1382, was May 7. On May 1, Smith sought a writ of mandate in the court of appeal to stay further trial court proceedings against him. The court of appeal directed the superior court to enter an order dismissing the information pending against Smith. The Supreme Court reversed, holding (1) under section 1382, when one codefendant's trial is continued to a date within section 1382's ten-day grace period, the state's strong interests in joinder provide good cause to continue the trial for all properly joined codefendants to the same date within the ten-day period; and (2) therefore, the trial court did not abuse its discretion in continuing Smith's trial to a date within the ten-day period in order to permit Smith and Sims to be joined in a single trial.

In 1984 a jury convicted Defendant of first degree murder, attempted murder, attempted rape, and burglary. After a penalty trial, the jury set the penalty at death. The Supreme Court affirmed. In 1997, the Ninth Circuit Court of Appeals, while affirming the federal district court's denial of Defendant's petition for writ of habeas corpus as to the guilt phase, reversed its denial of the writ as to the death sentence. After the first retrial of the penalty phase resulted in a mistrial, a second penalty retrial was held, in which the jury returned a verdict of death. The Supreme Court affirmed, holding (1) the second penalty retrial was constitutional; (2) the trial court did not err by excusing prospective jurors; (3) the court did not erroneously admit victim impact evidence and giving related instructions; (4) the court did not err in excluding proffered defense expert opinion testimony or mitigating evidence; (5) there was no prejudicial prosecutorial misconduct; and (6) California's death penalty law and related standard jury instructions were constitutional and lawful.