Justia Constitutional Law Opinion Summaries

Defendant was found guilty by a jury of the first degree murder of his nephew, the second degree murder of his sister, and being a felon in possession of a firearm. The jury also found true the firearm-use allegations and the special circumstances of multiple murder. The jury concluded that defendant was sane and returned a verdict of death. On automatic appeal, the court considered pretrial issues, guilt phase issues, sanity phase issues, penalty phase issues, and presentencing issues. The court affirmed the judgment.

Defendant, a member of the Crips street gang, was found guilty by a jury of the first degree murders of Perry Coder and Gregory Martin and two counts of possession of a firearm by a convicted felon. The jury also found true the allegation that defendant personally used a firearm in the commission of the murders and the multiple-murder special-circumstance allegation. After a penalty trial, the jury returned a verdict of death. On automatic appeal, the court addressed numerous pretrial issues, guilt phase issues, and penalty phase issues and subsequently affirmed the judgment.

Defendant attacked another inmate and was convicted of assault with a deadly weapon or by means likely to inflict great bodily injury by a prisoner serving a life sentence (aggravated assault by a life prisoner) and assault with a deadly weapon other than a firearm or by means likely to inflict great bodily injury (aggravated assault). On appeal, defendant argued that the conviction for aggravated assault must be reversed because that offense was lesser than, and necessarily included within, the offense of aggravated assault by a life prisoner. The court agreed and reversed the judgment because the Court of Appeals reached a contrary conclusion.

Plaintiff, an environmental organization, filed this administrative mandamus action to challenge the issuance of a federally required permit authorizing the Moss Landing Powerplant (MLPP) to draw cooling water from the adjacent Moss Landing Harbor and Elkhorn Slough. This case presented issues concerning the technological and environmental standards, and the procedures for administrative and judicial review, that apply when a thermal powerplant, while pursuing the issuance or renewal of a cooling water intake permit from a regional board, also sought necessary approval from the State Energy Resources Conservation and Development Commission (Energy Commission), of a plan to add additional generating units to the plant, with related modifications to the cooling intake system. The court held that the superior court had jurisdiction to entertain the administrative mandamus petition here under review. The court also held that the trial court erred when it deferred a final judgment, ordered an interlocutory remand to the board for further "comprehensive" examination of that issue, then denied mandamus after determining that the additional evidence and analysis considered by the board on remand supported the board's reaffirmed findings. The court further held that recent Supreme Court authority confirmed that, when applying federal Clean Water Act (CWA), 33 U.S.C. 1326(b), standards for the issuance of this permit, the Regional Water Board properly utilized cost-benefit analysis. The court declined to address several other issues discussed by the parties. Accordingly, the court affirmed the judgment of the Court of Appeals.

Defendant was convicted of murdering a 22-year-old Soy Sun Lao during a doughnut shop robbery and convicted of two other robberies, both committed with a knife and one accompanied by an assault with force likely to produce great bodily injury. Defendant was sentenced to death and the court subsequently reviewed defendant's case on automatic appeal. The court reviewed guilt phase issues, penalty phase issues, and defendant's other claims of error. The court concluded that defendant's claim that the cumulative effect of guilt and penalty phase errors required reversal of his sentence failed because defendant had not established that any prejudicial error had occurred at either phase of his trial. Accordingly, the court affirmed the judgment.

Defendant was convicted of crimes related to the murder of Colleen Mary Kennedy and sentenced to death. On automatic appeal, defendant argued, among other things, that the trial court provided an erroneous instruction concerning the element of asportation for the offense of kidnapping and thereby violated his rights to due process and a fair trial under the Fifth, Sixth, Eighth, and Fourteenth Amendments of the U.S. Constitution and article I, sections 7 and 17 of the California Constitution. The court held, and the Attorney General conceded, that the totality of the circumstances standards set forth in People v. Martinez could not be applied to defendant's actions where defendant moved the victim from one room to another room. The court also held, and the Attorney General conceded, that "it is reasonably probable that a result more favorable to [defendant] would have been reached in the absence of the error." Therefore, the court reversed the judgment of conviction for kidnapping, vacated the findings related to kidnapping, and otherwise affirmed the judgment.

Defendant was convicted of residential burglary and receiving stolen property. The trial court held a trial to determine whether defendant had suffered a prior Alabama felony conviction that qualified as a serious felony conviction under the Three Strikes Law, Pen. Code, 667. At issue was whether faxed copies of certified court records were admissible to establish that a prior conviction qualified as a serious or violent felony under the Three Strikes law. The court affirmed the Court of Appeal judgment upholding the trial court's admission of the faxed copy of the certified court record because there was sufficient evidence to sustain a finding that the faxed document was an accurate copy of an authentic court record from the Circuit Court of Lauderdale County, Alabama.

Defendant had twice been convicted and sentenced to death for robbing and murdering the two managers of an apartment where he had lived. On his automatic appeal, the court addressed defendant's numerous claims of error. The court rejected defendant's claims and held that in those few instances in which the court found error or assumed the existence of error, the court concluded that any error was harmless. The court also held that, in combination, these errors did not compel the conclusion that defendant was denied a fair trial. Accordingly, the court affirmed the convictions and sentence of death.

Defendant filed a motion to suppress evidence, a spiny lobster, obtained by a game warden on the ground that the warden had engaged in an unconstitutional search and seizure in stopping defendant's car a few blocks from a pier where the warden had observed, through a spotting telescope, defendant fishing with a handline. At issue was whether a game warden, who reasonably believed that a person had recently been fishing or hunting, but lacked reasonable suspicion that the person had violated an applicable fish or game statute or regulation, could stop a vehicle in which the person was riding to demand that the person display all fish or game the person had caught or taken. The court held that when, as in this case, the vehicle stop was made reasonably close in time and location to the fishing or hunting activity, the encroachment upon an angler's or hunter's reasonable expectation of privacy resulting from a brief vehicle stop and demand was nonetheless rather modest, and no more intrusive than other actions by game wardens that have been upheld in past California cases. In weighing the special need of the state to stop persons who choose to fish or hunt in the state and to demand such persons display all fish or game that had been taken against the intrusion upon such persons' reasonable expectation of privacy entailed by such a stop and demand, the court held that the vehicle stop and demand at issue constituted a reasonable procedure under the Fourth Amendment. Accordingly, the court reversed the judgment of the Court of Appeals upholding the suppression of evidence obtained by the game warden and subsequent dismissal of the charges against defendant.

In this case, the court addressed the remedies available to a patient when a debt collector, acting on behalf of a medical professional, was asserted to have illegally disclosed confidential patient information to various consumer reporting agencies in the course of a dispute over an alleged medical debt. At issue was whether all state law claims arising from the furnishing of information to consumer reporting agencies were preempted by the Fair Credit Reporting Act ("FCRA"), 15 U.S.C. 1681t(b)(1)(F). The court concluded that, because of the dual state and federal responses to the protection of an individual's privacy and accuracy interests, when the interests overlap, as in this case, the question of what remedies were available was a federalism problem. The court subsequently held that Congress did not intend for the state remedies to be preempted. Accordingly, the court reversed and remanded for further proceedings.