Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder. The jury also found true the special circumstance allegations of burglary-murder and torture-murder. After the jury was unable to agree on a sentence, the trial court declared a mistrial. At the second penalty phase trial, the trial court entered a judgment of death. The Supreme Court affirmed, holding (1) the trial court did not commit prejudicial error in its rulings regarding pretrial issues; (2) the trial court did not prejudicially err in its rulings during the guilt phase of trial; and (3) the trial court did not prejudicially err in its rulings during the second penalty phase. View "People v. Edwards" on Justia Law

Kevin Reilly was originally committed as a sexually violent predator (SVP) in 2000. In 2008, the Secretary of the Department of Corrections and Rehabilitation sought a petition for recommitment. Two evaluators evaluated Reilly under the Sexually Violent Predator Act (SVPA) and concluded he was an SVP. The Office of Administrative Law subsequently determined that the initial evaluations supporting the petition were conducted under an assessment protocol that amounted to an invalid regulation. The evaluators subsequently re-evaluated Reilly based on In re Ronje, this time concluding that he no longer met the criteria for commitment as an SVP. The court of appeal subsequently dismissed the SVPA commitment petition based on Ronje, which ordered replacement evaluations in these circumstances without requiring a determination that the underlying mistake in the assessment protocol amounted to material error. The Supreme Court reversed, holding (1) the Ronje decision was error; (2) an alleged SVP must show that any fault that did occur under the assessment protocol contained a material error; and (3) the court of appeal erroneously dismissed the petition against Reilly without requiring a finding of material error. View "Reilly v. Superior Court of Orange County" on Justia Law

Sheriff's deputies came to the home of Shane Hayes in response to a call from a neighbor. When the deputies arrived, Hayes's girlfriend informe them that Hayes was suicidal. The deputies then entered the house, where Hayes came toward them with a large knife raised in his right hand. The deputies simultaneously drew their guns and fired at Hayes, who died from the gunshot wounds. Hayes's daughter filed a complaint in federal district court against the County of San Diego and the deputies, alleging three federal law claims and two state law claims. The district court granted summary judgment for Defendants on all claims, finding that the deputies owed Plaintiff no duty of care with respect to their preshooting conduct. The Ninth Circuit Court of Appeals asked the California Supreme Court to answer a question of state law. The Court answered by holding that, under California negligence law, liability can arise from tactical conduct and decisions employed by law enforcement preceding the use of deadly force if the conduct and decisions leading to the use of deadly force show, as part of the totality of the circumstances, that the use of deadly force was unreasonable. View "Hayes v. County of San Diego" on Justia Law

Pursuant to the terms of a plea bargain, Defendant, who was an eighteen-year-old citizen of Mexico at the time, pleaded guilty to the sale or transportation of marijuana. After completing his probation, Defendant sought an adjustment in status to lawful permanent residency. Defendant's application was denied because of his conviction, and removal proceedings were initiated against him. Defendant filed a motion to vacate his conviction pursuant to Cal. Penal Code 1016.5, asserting that had he known the immigration consequences of pleading guilty, he would have rejected the plea offer. The only issue adjudicated at the hearing on Defendant's motion was whether he would have received a more favorable outcome had he rejected the plea bargain. The trial court denied the motion without considering the possibility Defendant might have rejected the plea bargain even if it were not reasonably probable he would have received a more favorable outcome. The Supreme Court reversed, holding (1) relief is available under section 1016.5 if the defendant establishes he would have rejected the existing bargain to accept or attempt to negotiate another; and (2) the trial court applied the incorrect test for prejudice in this case. Remanded. View "People v. Martinez" on Justia Law

After a jury trial, Defendant, an alleged member of the Mexican Mafia, was convicted of the first degree murders of three adults and two children. The jury also found true multiple-murder special-circumstance and weapon use sentence enhancement allegations. Defendant was sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in its rulings and decisions prior to trial; (2) the evidence was sufficient to support Defendant's convictions and the multiple-murder special-circumstance true finding; (3) the trial court did not err in the remainder of its rulings during the guilt phase of Defendant's trial; (4) the trial court did not engage in judicial misconduct during either the guilt phase or the penalty phase; (5) the prosecutor did not commit prejudicial misconduct during closing argument; (6) the trial court did not err in the remainder of its rulings during the penalty phase; and (7) California's death penalty statute is not constitutionally invalid. View "People v. Maciel" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and arson of property. The jury found true the special circumstance that Defendant was previously convicted of first degree murder. The trial court imposed the death sentence for the murder. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not err in granting the prosecution's challenge for cause against a prospective juror; (2) the trial court did not err in admitting evidence of two uncharged murders; (3) the jury was properly instructed regarding flight; (4) the prior-murder-conviction special circumstance was valid; (5) the trial court did not err in its penalty phase rulings; and (6) Defendant's challenges to California's death penalty failed. View "People v. Rogers" on Justia Law

Defendant was charged with sale and possession for sale of a controlled substance. At trial, evidence showed that the pills contained 3,4-methylenedioxymethamphetamine (MDMA). The court of appeal affirmed, holding that although there was not a stipulation or expert testimony showing that MDMA met the definition of a controlled substance or controlled substance analog within the Health and Safety Code, the name supported the inference that the pills contained some quantity of methamphetamine or amphetamine. The Supreme Court reversed, holding that evidence of MDMA's chemical name, standing alone, was insufficient to prove the material is a controlled substance where MDMA is not listed in the Code. View " People v. Davis" on Justia Law

Defendant was charged with committing four lewd acts upon his niece. Before trial, the prosecution offered evidence under Cal. R. Evid. 1108 that Defendant had sexually abused his sister when Defendant was nearly fourteen. Defendant opposed the prosecutor's motion, arguing that the evidence should be excluded because, as a minor under the age of fourteen, he was presumed incapable of committing a crime. The court allowed the evidence. During trial, the trial court did not give an instruction directing the jury to assess Defendant's capacity to commit the offense admitted under section 1108 under Cal. Penal Code 26(1). The jury convicted Defendant on all counts. The court of appeal reversed, holding that the trial court erred by not sua sponte instructing the jury that the prosecution must prove by clear and convincing evidence that Defendant appreciated the wrongfulness of his conduct admitted under section 1108. The Supreme Court reversed, holding (1) proof was required that Defendant knew the conduct at issue was wrongful and was thus capable of committing a crime; and (2) the trial court was not required to sua sponte instruct the jury to consider Defendant's age at the time of his act admitted under section 1108. Remanded. View "People v. Cottone" on Justia Law

After a jury trial, Defendant was convicted of resisting an executive officer in the performance of his duties pursuant to Cal. Penal Code 69. Defendant appealed, arguing that the trial court erred by denying his request to instruct the jury that it could instead convict him of the lesser offense of resisting a public officer under Cal. Penal Code 148(a)(1). The Supreme Court affirmed, holding (1) section 148(a)(1) was a necessarily included lesser offense of section 69 as alleged in the amended information; but (2) because substantial evidence did not reveal Defendant violated section 148(a)(1) without also violating section 69, the trial court did not err in refusing to instruct the jury on section 148(a)(1). View "People v. Smith" on Justia Law

Defendants were part of a Bakersfield gang and were involved in various retaliatory shootings against perceived rivals. After a jury trial, Defendants were convicted of, inter alia, first degree murder with multiple-murder and gang-murder special circumstances, active gang participation, and conspiracy. The conspiracy count alleged that each Defendant had engaged in conspiracy to commit felony assault, robbery, murder, and gang participation. The court of appeals affirmed the conspiracy convictions, holding that conspiracy to actively participate in a criminal street gang did not qualify as a crime, but each conspiracy count was also based on the valid theory of conspiracy to commit murder. The Supreme Court reversed, holding that that a defendant may conspire to actively participate in a criminal street gang and may be separately charged once a conspirator has committed an overt act. Remanded. View "People v. Johnson" on Justia Law