Justia Constitutional Law Opinion Summaries

Articles Posted in California Supreme Court

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During the course of one evening, Defendant and another man burglarized two businesses, robbing several people inside, and killing off-duty peace officer Shayne York. After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a peace officer in retaliation for the performance of his duties and of murder during the commission of robbery and burglary. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed Defendant’s convictions, holding (1) the trial court did not err in its evidentiary rulings or in instructing the jury during the guilt phase; (2) sufficient evidence supported the finding that Defendant intentionally killed York in retaliation for the lawful performance of his duties, and the special circumstance allegation was constitutional; (3) Defendant’s challenges to the robbery-murder and burglary-murder special circumstances were unavailing; (4) Defendant’s Sixth Amendment right to self-representation was not violated at the penalty phase; (5) any error in the instructions during the penalty phase was harmless; and (6) Defendant’s death sentence was proportional and constitutional. View "People v. Boyce" on Justia Law

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One of the jurors in Defendant’s criminal case prematurely decided to vote guilty, repeatedly talked about the case outside deliberations, prematurely reached a conclusion regarding the veracity of certain testimony, and adopted the mantle of an advocate, repeatedly telling the other jurors that Defendant was guilty. The trial court found that the juror engaged in serious misconduct but that Defendant did not suffer prejudice. Defendant appealed his conviction of two counts of first degree murder and death sentence on the basis of juror misconduct. The Supreme Court reversed, holding that, under the facts of this case, the People did not discharge their burden of establishing that there was no substantial likelihood that the juror was actually biased against Defendant. View "People v. Weatherton" on Justia Law

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After a jury trial, Defendant was convicted of murder, rape, and kidnapping and sentenced to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in finding that Defendant was competent to stand trial; (2) the prosecutor did not improperly exercise a peremptory challenge to a prospective juror based on race; (3) during the guilt phase of trial, the trial court did not abuse its discretion in admitting crime scene and autopsy photographs and in instructing the jury; (4) no prejudicial error occurred during the penalty phase of trial; (5) the trial court did not err in denying Defendant’s motion for a new trial; and (6) Defendant’s challenges to California’s death penalty statute failed. View "People v. Sattiewhite" on Justia Law

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After a jury trial, Defendant was convicted of kidnapping, committing two counts of lewd and lascivious acts on, and murdering a five-year-old girl. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding that the trial court (1) did not err in refusing to change venue from Orange County, as the record presented no reason to find a reasonable likelihood that Defendant did not receive a fair trial before impartial jurors; (2) did not err in denying Defendant’s request for additional peremptory challenges after he exhausted his statutory allotment of challenges because Defendant did not demonstrate that additional peremptory challenges were necessary to secure his right to a fair trial; (3) did not abuse its discretion in admitting evidence that Defendant had sexually molested three girls where Defendant had been charged with and acquitted of crimes concerning two of the girls; and (4) did not abuse its discretion in admitting photographs of the crime scene, evidence regarding the child pornography found on the computer to which Defendant had access, and victim impact evidence. View "People v. Avila" on Justia Law

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After a jury trial, Defendant was convicted of three counts of first degree murder with a multiple-murder special circumstance, one count of attempted murder, and firearm enhancements for the shootings and attempted shootings of staff members at a hospital. After two penalty trials that resulted in hung juries, the third penalty jury returned a verdict of death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court’s denial of Defendant’s motion to recuse the district attorney’s office was not an abuse of discretion; (2) the trial court erred in its instructions to the jury, but the error was harmless; (3) retrial did not violate Defendant’s rights to due process and equal protection and the prohibition against cruel and unusual punishment; (4) Defendant was not deprived of the right to equal protection and trial by a representative jury because the jury included no Vietnamese-Americans; (5) although the prosecutor engaged in misconduct during the penalty phase, the improper questions did not influence the verdict; and (6) Defendant’s allegations of error in post-trial issues were without merit. View "People v. Trinh" on Justia Law

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After a jury trial, Defendant was convicted of first degree murder, attempted premeditated murder, two counts of second degree robbery and arson causing great bodily injury. The jury returned a verdict of death. The Supreme Court vacated Defendant’s arson-murder special-circumstance finding but otherwise affirmed the judgment in its entirety, holding (1) the trial court did not err in restricting Defendant’s counsel’s questioning of prospective jurors during voir dire; (2) the evidence was insufficient to support the arson-murder special circumstance because the arson did not involve an inhabited structure or property; (3) the trial court did not abuse its discretion in dismissing a juror during the trial; (4) the trial court did not prejudicially err in its instructions to the jury; (5) the trial court did not err in refusing to declare a mistrial after the penalty jury initially declared it was deadlocked; and (6) Defendant’s challenges to the constitutionality of California’s death penalty scheme were without merit. View "People v. Debose" on Justia Law

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After a jury trial, Defendant was convicted of first degree murder, sodomy, and forcible lewd act on a minor. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in failing to exclude expert testimony that the victim died by drowning in association with sexual assault; (2) the trial court did not err in the remainder of its evidentiary rulings; (3) the evidence was sufficient to support the convictions; (4) defense counsel provided constitutionally effective assistance; (5) the trial court did not err by accepting Defendant’s waiver of his right to present mitigating evidence; (6) Defendant’s voluntary absence during trial did not violate the federal Constitution; and (7) Defendant’s constitutional challenges to the death penalty law and related jury instructions were without merit. View "People v. Brown" on Justia Law

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The Los Angeles Times asked the City of Long Beach to release the names of the police officers involved in certain shootings. The Long Beach Police Officers Association (“Union”) sought injunctive relief against the City, attempting to prevent release of the names to the Times. The Times subsequently intervened, seeking disclosure of the names. The City supported the Union’s request for injunctive relief and opposed disclosure. The trial court denied the Union’s request for a preliminary or permanent injunction. The court of appeal upheld the denial. The Supreme Court affirmed, holding that the particularized showing necessary to outweigh the public’s interest in the disclosure of the names of peace officers involved in the on-duty shootings was not made in this case. View "Long Beach Police Officers Ass'n. v. City of Long Beach" on Justia Law

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Defendants, Stephen Edward Hajek and Loi Tan Vo, were convicted of, among other crimes, the murder of Su Hung. The jury found true lying-in-wait and torture-murder special circumstances as to both defendants. The jury also found true firearm use allegations as to Hajek and deadly or dangerous weapon use as to Vo, in Defendants’ commission of the murder, attempted murder, kidnapping, and false imprisonment counts. The jury returned verdict of death as to each defendant. The Supreme Court affirmed the death judgments, reversed the lying-in-wait special circumstances findings as to both defendants, and ordered that the firearm use enhancements found true as to Hajek be struck and replaced with deadly or dangerous weapon use enhancements, holding (1) there was insufficient evidence to show that Defendants intentionally killed the victim while lying in wait, but the reversal of the lying-in-wait special-circumstance findings did not require reversal of Defendants’ death sentences; and (2) a change in the law excluding pellet guns from the definition of a firearm required that Hajek’s firearm use enhancements involving the use of a pellet gun be struck, but the jury’s true findings on the firearm use enhancements necessarily included true findings on deadly or dangerous weapon use enhancements. View "People v. Hajek" on Justia Law

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Defendants in these cases were both seventeen-year-old offenders who were convicted of special circumstance murder and sentenced to life imprisonment without the possibility of parole under Cal. Penal Code 190.5(b). After Defendants were sentenced, the U.S. Supreme Court decided Miller v. Alabama. On review, the California Supreme Court held (1) section 190.5(b), properly construed, confers discretion upon a trial court to sentence a juvenile convicted of special circumstance murder to life without parole, with no presumption in favor of life without parole; (2) Miller requires a trial court, in exercising its sentencing discretion, to consider the distinctive attributes of youth before imposing life without parole on a juvenile offender; (3) section 190.5(b) does not violate the Eighth Amendment to the U.S. Constitution because it authorizes and requires consideration of the distinctive attributes of youth highlighted in Miller, once the statute is understood not to impose a presumption in favor of life without parole; and (4) because the trial courts in these cases sentenced Defendants without awareness of the full scope of their discretion conferred by section 190.5(b) and without the guidance set forth in Miller, the cases must be remanded for resentencing. View "People v. Gutierrez" on Justia Law