Justia Constitutional Law Opinion Summaries

These consolidated cases raised the following question: Under the statutes and regulations applicable here, what showing must be made to postpone the filing of a sexually violent predator (SVP) petition beyond the inmate's scheduled release date to allow for the completion of a full SVP evaluation? Reading Welf. & Inst. Code 6601.3, the court concluded that the statute provided that, to be timely, a petition must be filed while the inmate was in lawful custody. The lawful custody period extended to the release date. However, an inmate could be held for up to 45 days beyond the release date upon a showing of good cause. Petitioners argued that the regulation's definition of good cause was inadequate because it did not require a showing that the need for the requested delay was justified. The court held that the regulation was invalid, but that the Board's reliance upon it was excusable as a good faith mistake of law.

Defendant was convicted of violating Penal Code section 246 by standing outside his truck and shooting a passenger. Defendant argued that because the gun had crossed the threshold of the truck at the time of the shooting, the gun was not "discharged 'at' the vehicle" but was instead discharged "within" the vehicle. Although the court agreed that the statutory text alone was susceptible of more than one interpretation, reliable extrinsic evidence aids to statutory construction convinced the court that the Legislature intended section 246 to apply to a person standing outside an occupied motor vehicle and shooting into it, even if the gun had crossed the plane of the vehicle. Because the court could discern the Legislature's intent, there was no need to invoke the rule of lenity. Therefore, the court reversed the judgment.

A jury convicted defendant of the first degree murder of the victim, also finding that he had personally used a firearm in the commission of the offense and finding true the circumstance that defendant had committed the murder during the course of a robbery. The jury imposed the death sentence. On appeal, the court addressed pretrial and guilt phase issues, as well as penalty phase issues. The court concluded that the outcome of the trial was unaffected by any errors that occurred and affirmed the judgment of the district.

Defendant was convicted of second degree murder of one victim and two first degree murders of officers. The jury found true special circumstances allegations that the officers were killed while engaged in the performance of their duties and that defendant was convicted of more than one murder. On automatic appeal, the court modified the judgment to correct the sentence imposed on count 1 for second degree murder where the trial court made an error in imposing a sentence of death for count 1, an offense that was not punishable by death. The court affirmed defendant's convictions and death sentence in all other respects.

Defendant was convicted of the first degree murder of a Los Angeles County Deputy Sheriff and the premeditated attempted murder of the deputy sheriff's partner. The jury found true the special circumstance allegations that the murder of the deputy sheriff was committed for the purpose of avoiding and preventing a lawful arrest and that the deputy sheriff was a peace officer engaged in the performance of his duties when defendant knowingly and intentionally killed him. The jury also found true the allegations that defendant personally used a firearm in the murder and attempted murder, previously had been convicted of a serious felony, and had served two prior prison terms. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues related to the denial of a motion for discovery of law enforcement officers' personnel files; the denial of a motion to continue the trial; asserted errors during voir dire; guilt phase challenges; penalty phase challenges; assertedly improper denial of motion for new trial based upon insufficiency of the evidence; assertedly improper role of race in the proceedings; asserted denial of an impartial judge; challenges to the constitutionality of California's death penalty statutes; and cumulative prejudicial effects of asserted errors.

Defendant was convicted of first degree murder of two victims, with a multiple-murder special circumstance finding. Defendant was also convicted of assault with a deadly weapon on another victim, with a a great bodily injury finding. Firearm use and criminal street gang findings were made as to all three counts. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues involving the admissibility of defendant's confession; the trial court's refusal to instruct on heat of passion; instructions on perfect and imperfect self-defense; defendant's waiver of his right to testify; victim impact evidence; asserted improper prosecutorial argument; lack of remorse; refusal to instruct on lingering doubt; and challenges to the death penalty law and instructions.

Defendant was convicted of murder in the first degree with the special circumstance of murder during the commission of a robbery and sentenced to death. Defendant was also convicted of robbery and assault with a deadly weapon, using a handgun to commit both the robbery and assault. On automatic appeal, the court addressed pretrial and jury selection issues; issues relating to guilt; issues relating to penalty; and the adequacy of the appellate record. The court ultimately affirmed the judgment.

Defendant was sentenced to death on a first degree murder conviction by trying to suffocate the victim, putting her in the trunk of a car and driving to a remote location, pouring gasoline on her and the outside of the trunk, and lighting the gasoline on fire. The victim burned to death trapped inside of the trunk. On automatic appeal, the court affirmed the convictions of first degree murder and the other charged felonies, but the court reversed as to the penalty of death and set aside the kidnapping special circumstances finding because the trial court erroneously instructed the jury.

Defendant was convicted of various crimes against a number of victims. At issue was whether there was sufficient evidence to support defendant's conviction of second degree murder under a theory of implied malice when defendant cracked the victim's skull by punching him during a fight. The Court of Appeal reduced the conviction to voluntary manslaughter because of insufficient evidence of implied malice, focusing solely on the subjective component of implied malice. The court held, however, that the evidence was sufficient to satisfy both the physical and mental components of implied malice. Accordingly, the court held that the Court of Appeal erred in finding otherwise.

Defendant was convicted of crimes arising out of two separate assaults. At issue was whether California courts could apply a higher standard of mental competence for self-representation than for competency to stand trial in light of the Supreme Court's holding under Indiana v. Edwards. Because California law has long been that criminal defendants have no right of self-representation, the court concluded that California courts could deny self-representation when the U.S. Constitution permitted such denial. The court also concluded that the trial court acted within its discretion in revoking defendant's self-representation status.