Justia Constitutional Law Opinion Summaries

Plaintiff, a nonprofit public benefit corporation that was granted a charter in 2003 to serve Los Angeles County, had its charter revoked by the County Board of Education in 2007. Plaintiff appealed, contending that the revocation proceedings violated due process and revocation was not based on substantial evidence. The State Board of Education affirmed the revocation. The trial court issued a writ setting aside the revocation of the charter, finding that Plaintiff was not afforded a hearing before an impartial adjudicator because the County Board has an interest in ensuring that funds flowing to charter schools are reallocated to other public schools. The court of appeal reversed. The Supreme Court affirmed, holding that the school failed to establish that the Legislature's chosen procedures denied it the opportunity to be heard at a "meaningful time and in a meaningful manner" by a decision maker without financial or other bias. View "TodayÂ's Fresh Start, Inc. v. Los Angeles County Office of Educ. " on Justia Law

At issue in this case was the database of information about land parcels in a geographic information system (GIS) file format maintained by Orange County and whether it was subject to disclosure at the actual cost of duplication under the California Public Records Act (PRA) or whether it was covered by the PRA's exclusion of "computer software" from the definition of a public record. Sierra Club requested a copy of the OC Landbase pursuant to the PRA. The County agreed to produce the records but refused to provide the records in GIS format unless Sierra Club paid a licensing fee and agreed to the license's restrictions on disclosure and distribution. Sierra Club subsequently sought a writ of mandate to compel the County to provide the OC Landbase in a GIS file format as a public record with no requirement that Sierra Club comply with the licensing agreement. The superior court denied the petition for writ of mandate, concluding that the OC Landbase in GIS file format was excluded from the PRA's general rules of disclosure. The Supreme Court reversed, holding that GIS-formatted databases like the OC Landbase are public records that must be produced upon request at the actual cost of duplication. View "Sierra Club v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of possession of cocaine and resisting a peace officer. On appeal, Defendant argued that the trial court committed reversible error when, after finding the prosecution improperly used a peremptory challenge to discharge a prospective juror under People v. Wheeler, it reseated the juror instead of discharging the entire jury venire. The court of appeal agreed, finding that Defendant did not consent to the court's remedy of reseating the juror, therefore reversing Defendant's conviction. The Supreme Court reversed, holding (1) in the context of a trial court's order to reseat an improperly discharged prospective juror after the court granted the complaining party's Wheeler motion, the complaining party's assent to reseating the improperly discharged juror can be found on the basis of implied consent; and (2) in this case, Defendant did impliedly consent to the alternative remedy of reseating the juror. View "People v. Mata" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, kidnapping for child molestation, forcible rape, sodomy, and committing a lewd and lascivious act upon a child under fourteen. Prior to sentencing, the trial court ordered a new trial based on juror misconduct. On retrial, the second jury found Defendant guilty of the same charges. The trial court imposed a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not prejudicially err in its rulings during the guilt phase, sanity phase, and penalty phase of trial; (2) California's death penalty scheme and related jury instructions do not violate the United States Constitution; (3) the trial court did not prejudicially err in sentencing Defendant; and (4) the cumulative effect of the trial court's few errors did not warrant reversal. View "People v. DeHoyos" on Justia Law

After a jury trial, two defendants (Defendants) were convicted of the first degree murders of two people. The jury found true special circumstance allegations of multiple murder and sentence enhancement allegations that Defendants committed the murders to benefit a criminal street gang and used firearms to commit them. The trial court sentenced Defendants to death. The Supreme Court vacated one multiple-murder special-circumstance finding for each defendant and the true findings for the street gang and fire use enhancements, holding (1) the trial court erred in instructing the jury pertaining to the gang enhancement allegations, and the error was prejudicial; (2) the sentence enhancement allegations for personal firearm use must also be vacated because those findings depended on the jury first finding true the gang enhancement allegations; and (3) the trial court erred in allowing the jury to make multiple-murder special-circumstance findings as to each count of murder. View "People v. Nunez" on Justia Law

After police seized a package from FedEx and discovered marijuana inside, Petitioner, who went to FedEx to claim the package, was arrested with possession of marijuana for sale and with the sale or transportation of marijuana. The superior court denied Petitioner's motion to suppress evidence, concluding that exigent circumstances justified the seizure, and the subsequent search was valid under the inevitable discovery doctrine. The court of appeal granted Petitioner's petition for writ of mandate and ordered the superior court to grant the motion to suppress, holding that the inevitable discovery doctrine did not apply to the facts in this case, that exigent circumstances did not justify the subsequent search of the container, and that the odor of contraband alone cannot justify a warrantless search. The Supreme Court affirmed in part, holding (1) a container's mobility may constitute exigent circumstances sufficient to justify a warrantless seizure, but it cannot alone justify a search of the container once it has been seized; and (2) the District Attorney forfeited his argument that the plain smell of marijuana constituted an exception to the warrant requirement. View "Robey v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, residential burglary, attempted rape, and a forcible lewd act on a child under the age of fourteen. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment of the trial court, holding, inter alia, (1) the trial court did not prejudicially err in its guilt phase evidentiary rulings; (2) the trial court did not unfairly frustrate defense efforts to present a defense establishing Defendant was coerced into making false admissions and a confession; (3) the trial court did not err in failing to excuse a certain juror for misconduct; (4) the trial court did not deprive Defendant of his ability to present a penalty phase defense and to establish lingering doubt as a mitigating factor by refusing to allow Defendant to call certain witnesses and restricting certain testimony; (5) the trial court did not err in allowing the admission of photographs of the victim and testimony as victim impact evidence; (6) Defendant's claims of prosecutorial misconduct were either not preserved for appeal or meritless; and (7) California's death penalty is not unconstitutional. View "People v. Linton" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, assault by means of force likely to produce great bodily injury and/or with a deadly weapon, and first-degree residential burglary. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not err in its rulings surrounding jury selection issues; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) the evidence was sufficient to support Defendant's conviction of first-degree murder; (4) the prosecutor did not commit misconduct during closing argument; (5) the trial court did not prejudicially err in instructing the jury during the guilt phase; (6) the trial court did not prejudicially err in its rulings during the penalty phase; (7) California's death penalty statute is not unconstitutional; and (8) Defendant was not cumulatively prejudiced. View "People v. Lopez" on Justia Law

After a second jury trial, Defendant was convicted of one count of attempted mayhem and two counts of assault with a firearm. Defendant appealed, contending that the trial court erred in instructing the jury that a gunshot wound may constitute a "serious bodily injury" for purposes of the offense of attempted mayhem. The court of appeal reversed the attempted mayhem conviction, holding that the trial court erred in giving the instruction because the instruction suggested to the jury that Defendant could be found guilty of attempted mayhem if it found Defendant merely intended to inflict a gunshot wound rather than intending to inflict a wound that would seriously impair the victim's physical condition. The Supreme Court reversed, holding (1) the pattern jury instruction on mayhem improperly requires proof of a "serious bodily injury"; but (2) assuming the trial court erred in giving the instruction in this case, the error was harmless. View "People v. Santana" on Justia Law

After a jury trial, Defendant was convicted of second degree murder. The court of appeal reversed the murder conviction, concluding that the trial court erred by failing to sua sponte instruct the jury on voluntary manslaughter as a lesser included offense of murder on the theory that Defendant killed without malice in the commission of an inherently dangerous assaultive felony. The Supreme Court reversed, holding that because a killing without malice in the commission of an inherently dangerous assaultive felony is not voluntary manslaughter, the trial court could not have erred in failing to instruct the jury that it was. View "People v. Bryant" on Justia Law