Justia Constitutional Law Opinion Summaries

Plaintiffs were five independent retail pharmacies licensed in California, and Defendants were prescription drug claims processors. In 2002, Plaintiffs filed a federal class action suit alleging that Defendants failed to comply with Cal. Civil Code 2527, which requires prescription drug claims processors to compile and summarize information on pharmacy fees and transmit that information to their clients. The district court dismissed the cases for lack of standing without reaching the merits. On appeal, the Ninth Circuit Court of Appeals concluded that Plaintiffs had standing, reversed the district court, and remanded. On remand, Defendants moved for judgment on the pleadings, contending that section 2527 unconstitutionally compels speech in violation of the California and U.S. Constitutions. The district court denied the motions. On appeal, the Ninth Circuit asked the California Supreme Court to answer a question of state law. The Supreme Court answered by holding (1) section 2527 implicates the right to free speech guaranteed by the California Constitution and is subject to rational basis review; and (2) the statute satisfies that standard because the compelled factual disclosures are reasonably related to the Legislature's legitimate objective of promoting informed decisionmaking about prescription drug reimbursement rates. View "Beeman v. Anthem Prescription Mgmt." on Justia Law

After a jury trial, Defendant was convicted of first degree felony murder and robbery. The jury also sustained a special circumstance allegation of murder in the commission of a robbery. After a penalty trial, the court pronounced a death judgment for the special circumstance murder. Defendant appealed, alleging several trial errors. The Supreme Court affirmed, holding that the trial court did not commit prejudicial error in, among other things, selecting the jury, making its evidentiary rulings, and instructing the jury during both the guilt phase and the penalty phase. The Court also rejected Defendant's attack on California's death penalty law, finding it to be constitutional. View "People v. Contreras" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder and one count each of attempted murder, aggravated mayhem, and second degree attempted robbery. The trial court sentenced Defendant to death for the two murder convictions. The Supreme Court affirmed, holding (1) the trial court did not err in allowing a certain juror to remain on the jury despite her alleged fear for her safety; (2) Defendant's arguments that the trial court should have granted a new trial and a new penalty phase trial in light of alleged juror misconduct failed; (3) the trial court did not err in excusing for cause three prospective jurors and in failing to remove five prospective jurors for cause; (4) the prosecution did not impermissibly use peremptory challenges to excuse prospective jurors for discriminatory reasons; (5) the trial court did not violate Defendant's constitutional rights by ordering him to wear an electric shock belt during trial; (6) the evidence was sufficient to sustain Defendant's aggravated mayhem conviction; and (7) the trial court did not prejudicially err in instructing the jury. View "People v. Manibusan" on Justia Law

Defendant was charged with driving under the influence of alcohol and driving with a blood-alcohol concentration of 0.08 percent or more. During the trial proceedings, the trial court excluded expert witness testimony challenging the reliability of the breach-alcohol testing machines used on Defendant. The jury was unable to reach a verdict on the generic charge but found Defendant guilty of driving with 0.08 percent or more of alcohol in his blood. The court of appeals reversed, concluding that the trial court committed prejudicial error in excluding the challenged expert testimony. The Supreme Court reversed and affirmed Defendant's conviction, holding that the trial court properly excluded the challenged expert testimony, holding that the fundamental reliability of a federally approved, properly calibrated and employed breath-testing machine used in the application and enforcement of a per se statute is a matter that has been determined as policy by the Legislature, and a defendant's expert witness may not invite a jury to nullify that determination in the manner at issue here. View "People v. Vangelder" on Justia Law

Defendant was arrested and charged for unlawful transportation of marijuana and unlawful possession of marijuana for purposes of sale. In his defense, Defendant claimed he possessed the marijuana lawfully for purposes of medical treatment. After a jury trial, Defendant was convicted as charged. Defendant appealed, arguing that the evidence at trial was insufficient to establish his intent to sell because the expert who gave his opinion at trial lacked experience distinguishing between lawful possession for medical use and unlawful possession for purposes of sale. The Supreme Court affirmed, holding (1) Defendant forfeited his argument that the expert's opinion was inadmissible because the witness was unqualified by failing to object at trial to the witness's qualifications; and (2) the evidence was sufficient to sustain Defendant's convictions. View "People v. Dowl" on Justia Law

Defendant was charged with murder and use of a deadly weapon. The trial court gave instructions on first and second degree murder, as well as voluntary manslaughter based upon a sudden quarrel or heat of passion. The jury found Defendant guilty of second degree murder with a use enhancement. The court of appeal reversed Defendant's conviction, concluding that the voluntary manslaughter instruction was prejudicially erroneous. The Supreme Court reversed after clarifying what kind of provocation will suffice to constitute heat of passion and reduce a murder to manslaughter, holding (1) provocation is adequate only when it would render an ordinary person of average disposition "liable to act rashly or without due deliberation and reflection, and from this passion rather than judgment; and (2) although the jury instruction properly conveyed the standard for determining heat of passion, the argument of counsel may have introduced ambiguity, but the jury asked a clarifying question, and the trial court's response dispelled any confusion. Remanded. View "People v. Beltran" on Justia Law

After a jury trial, Defendant was convicted of several offenses, including robbery and theft. The convictions stemmed from Defendant's acquisition of gift cards through his false representation that he was using valid payment cards to purchase the gift cards. Defendant challenged his robbery convictions, contending that the type of theft that constitutes a "felonious taking," an element of robbery, was theft by larceny only and not theft by false pretenses, the type of theft that Defendant committed. The court of appeal affirmed Defendant's robbery convictions, holding that theft by false pretenses can satisfy the "felonious taking" requirement of robbery. The Supreme Court reversed, holding that theft by false pretenses cannot satisfy the "felonious taking" element of robbery. Remanded. View "People v. Williams" on Justia Law

After a jury-waived trial, Defendant was convicted of first degree murder. The court found true the special circumstance that the killing was intentional and that Defendant knew or should have known the victim was a peace officer engaged in the performance of duty. After a penalty jury returned a death verdict, Defendant was sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) Defendant's counsel did not labor under a conflict of interest or provide ineffective assistance; (2) the evidence supporting the special circumstance finding that Defendant intentionally killed a police officer engaged in the performance of duty was legally sufficient; (3) a certain juror was not biased on the issue of penalty; (4) substantial evidence supported the race-neutral reasons given by the prosecutor for his excusal of African-American prospective jurors; (5) the trial procedures did not deny Defendant reliable determinations of death eligibility and of the appropriate penalty; and (6) California's death penalty statute is not unconstitutional. View "People v. Mai" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, two counts of attempted murder, and of committing forcible rape, sodomy, and oral copulation. Following a penalty trial, Defendant was sentenced to death. The Supreme Court affirmed in all respects, holding (1) the trial court did not err in its pretrial rulings contested by Defendant; (2) the trial court did not err in its rulings made during the guilt phasel; (3) the trial court did not err when instructing the jury during the guilt phase; (4) the trial court did not err during the penalty phase of the trial; and (5) having found no legal error, Defendant's claim that the cumulative effect of all errors required reversal was rejected. View "People v. Jones" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, unlawful taking of a vehicle, and arson. The jury returned a verdict of death. The trial court sentenced Defendant to death on the murder count and imposed a determinate sentence on the remaining counts and enhancements. The Supreme Court affirmed, holding, (1) the trial court properly denied Defendant's motions for a change of venue; (2) the trial court did not err in its rulings regarding the selection of the jury; (3) the trial court did not prejudicially err in its decisions during the guilt phase of trial; (3) the trial court did not prejudicially err in its decisions during the penalty phase of trial; and (4) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Harris" on Justia Law