Justia Constitutional Law Opinion Summaries

Articles Posted in California Supreme Court
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After a jury trial, Defendant was convicted of first degree murder, attempted robbery, and second degree robbery. Following a retrial of the penalty phase trial, the jury sentenced Defendant to death for the murder conviction. The Supreme Court affirmed the judgment, including the death sentence, but ordered the clerk of the superior court to modify the abstract of judgment to reflect ninety-six days of conduct credit, holding that there was no reversible error in the jury selection and that the trial court did not err in its rulings during the guilt phase and the penalty phase, with the exception of denying Defendant presentence conduct credits. View "People v. Chism" on Justia Law

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After a jury trial in 1995, Defendant was convicted of twelve counts of first degree murder and one count of attempted murder. Defendant’s victims abused drugs and worked as prostitutes. The trial court sentenced Defendant to death with respect to each of the twelve murder convictions. The Supreme Court affirmed, holding (1) the trial court’s denial of Defendant’s motion for a change of venue based on the public’s knowledge of his case did not deprive Defendant of due process of law or a fair trial; (2) the trial court did not err in denying Defendant’s motion to suppress evidence obtained as a result of a traffic stop; (3) the trial court did not err in denying discovery concerning murders of prostitutes with which Defendant was not charged; (4) the trial court did not err in failing to exclude evidence obtained during police questioning of Defendant and in making its other evidentiary rulings; (5) the extent and nature of the victim impact evidence did not deprive Defendant of his rights to due process, a fair trial, and a reliable penalty determination; and (6) California’s death penalty scheme, jury instructions, and procedures are constitutional. View "People v. Suff" on Justia Law

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After a jury trial, Petitioner and his codefendant were convicted of burglarizing the home of Bobby Hassan and of robbing and murdering Bobby and his son, Eric. Petitioner and his codefendant were sentenced to death in 1982. The Supreme Court affirmed on appeal. Petitioner later filed a petition for writ of habeas corpus, alleging that his trial attorney ineffectively represented him at the penalty phase of trial. In 2002, the Supreme Court issued an order to show cause based on Petitioner’s claim of ineffective assistance of counsel. The Court appointed a referee and directed him to take evidence and make findings of fact. In 2014, based on the referee’s findings, the Supreme Court denied relief, holding that Petitioner’s counsel did not provide incompetent representation at trial. View "In re Champion" on Justia Law

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After a jury trial, Defendant was convicted of two counts of animal cruelty. During voir dire, the trial court denied Defendant’s challenges to two prospective jurors on incompetence grounds, after which Defendant used two of his allotted peremptory challenges to remove the same jurors. Defendant subsequently exhausted his peremptory challenges and unsuccessfully requested that the trial court grant him extra peremptory challenges to remove other prospective jurors he deemed to be objectionable. On appeal, Defendant claimed he was entitled to reversal of the trial court’s judgment because one of the jurors he objected to sat on his case. The Supreme Court affirmed Defendant’s conviction, holding (1) Defendant cured any error that occurred when the trial court denied his for-cause challenges because those jurors were removed with Defendant’s peremptory challenges; (2) the trial court was under no obligation to grant Defendant extra peremptory challenges to remove additional, otherwise competent, jurors; and (3) because no incompetent juror who should have been dismissed for cause sat on Defendant’s case as a result of Defendant exhausting his peremptory challenges, Defendant was not entitled to reversal. View "People v. Black" on Justia Law

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After a jury trial, Defendant was found guilty of first degree murder, kidnapping during the commission of a carjacking, carjacking, and being a felon in possession of a firearm. After the penalty phase, the trial court sentenced Defendant to death. The Supreme Court reversed the carjacking conviction and stayed the sentence of kidnapping during the commission of a carjacking but affirmed the judgment in all other respects, including the death sentence, holding (1) because carjacking is a necessarily lesser included offense of kidnapping during a carjacking, Defendant’s conviction and sentence for carjacking could not stand; and (2) Cal. Penal Code 654 required staying of the kidnapping during a carjacking conviction. View "People v. Montes" on Justia Law

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After a jury trial, Defendant was convicted of the first degree murder of Monique Cleveland, the willful, deliberate, and premeditated attempted murder of Robert Cleveland, and being a felon in possession of a firearm. After a penalty retrial, the jury returned a verdict of death on the murder conviction. The Supreme Court affirmed, holding that (1) any error on the trial court’s part in ordering Defendant to wear a stun belt during his trial was harmless because there was no reasonable possibility that Defendant would have received a more favorable verdict had the trial court not required him to wear a stun belt; (2) the evidence was sufficient to support Defendant’s convictions; and (3) the trial court did not commit reversible error in its rulings during the penalty retrial. View "People v. Jackson" on Justia Law

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After a jury trial, Defendant was convicted of the first degree murder of her husband under the special circumstances of murder by administering poison and murder for financial gain. At the penalty trial, the prosecution presented evidence that Defendant had murdered her infant daughter several years previously. The jury returned a verdict of death, and the trial court imposed that sentence. On appeal, Defendant raised allegations of error regarding primarily pretrial events, guilt trial issues, and penalty issues. The Supreme Court affirmed the judgment, holding that the circuit court did not reversibly err in its rulings and that Defendant was not deprived of a fair trial in this case. View "People v. Rodriguez" on Justia Law

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After a jury trial, Defendant was convicted of two counts of first degree murder with robbery and multiple-murder special circumstances and sentenced to death. On appeal, the Supreme Court affirmed the judgment in its entirety, holding (1) no error occurred during the selection of the jury; (2) the trial court did not err in its evidentiary rulings; (3) changes in the composition of the jury did not violate Defendants rights to trial by an impartial jury; (4) the trial court did not err in instructing the jury; (5) no error occurred during the penalty phase of the trial; and (6) the aspects of California’s death penalty Defendant challenged did not render it unconstitutional. View "People v. Duff" on Justia Law

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Plaintiffs requested that the State Bar of California provide them access to certain information contained in the State Bar's admissions database, including applicants' grade point averages, race or ethnicity, and bar exam scores. Plaintiffs sought the information to conduct research on racial and ethnic disparities in bar passage rates and law school grades. The State Bar rejected the request. Plaintiffs then filed a petition for writ of mandate in the superior court, seeking to compel the State Bar to provide the records. The trial court concluded that there was no legal basis for requiring disclosure of the admissions database and denied the petition without reaching any issues regarding the privacy of the applicants. The court of appeal reversed. The Supreme Court affirmed and remanded, holding that under the common law right of public access, the State Bar was required to provide access to the information contained in the admissions database if the information could be provided in a form that protected the privacy of applicants and if no countervailing interest outweighed the public's interest in disclosure. View "Sander v. State Bar of Cal." on Justia Law

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After a jury trial, Defendant was convicted of two counts of first degree murder and related crimes. Following a penalty phase trial, the jury returned a verdict of death. The Supreme Court affirmed the judgment, holding, among other things, that (1) Defendant's rights to a speedy trial were not violated; (2) Defendant's Sixth Amendment rights of self-representation and to the assistance conflict-free counsel were not violated during trial; (3) the prosecution did not violate Defendant's due process rights under Brady v. Maryland; (4) the trial court did not improperly admit "inflammatory and damning evidence" that compromised Defendant's ability to receive a fair trial; (5) the prosecutor did not engage in improper misconduct; and (6) the trial court did not prejudicially err in its penalty phase rulings. View "People v. Williams" on Justia Law