Justia Constitutional Law Opinion Summaries

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 that although the jury instruction properly conveyed the standard for determining heat of passion, the argument of counsel may have introduced ambiguity. However, the jury asked a clarifying question, and the trial court's response dispelled any confusion. View "People v. Beltran" on Justia Law

After a jury trial, Petitioner was convicted of two counts of first degree murder and of being a felon in possession of a firearm. Following the penalty phase of trial, the jury sentenced Petitioner to death. The Supreme Court affirmed. While Petitioner's appeal was pending, Petitioner also filed a petition for writ of habeas corpus. Having found the petition stated a prima facie case for relief on several claims of alleged juror misconduct, the Supreme Court issued an order to show cause why relief should not be granted. After an evidentiary hearing, a referee filed his report. The Supreme Court accepted the referee's report and findings as supported by substantial evidence, discharged the order to show cause, and denied relief, holding (1) there was no substantial likelihood that one juror was biased against Petitioner for failing to disclose certain personal information; and (2) the record rebutted the presumption of prejudice that arose from two other jurors' misconduct. View "In re Boyette" on Justia Law

The Service Employees International Union, Local 721 (SEIU) was the exclusive bargaining representative of all Los Angeles County employees. SEIU proposed amending the memorandum of understanding it had with the County's bargaining units to enable SEIU to obtain the home addresses and phone numbers of all represented employees, including those who had not joined the union. The County rejected the amendment. The Los Angeles County Employee Relations Commission concluded that the County's refusal to provide the contact information was an unfair labor practice. The superior court denied the County's petition for relief. The appellate court affirmed but held that nonmember employees were entitled to notice and an opportunity to opt out before their contact information could be disclosed to SEIU. The Supreme Court affirmed but reversed the court of appeal's imposition of procedural requirements limiting disclosure, holding (1) although the County's employees have a cognizable privacy interest in their home addresses and telephone numbers, the balance of interests strongly favors disclosure of this information to the union that represents them; and (2) procedures may be developed for employees who object to this disclosure, but the court of appeal exceeded its authority by attempting to impose specific procedures on the parties. View "County of Los Angeles v. Los Angeles County Employee Relations Comm'n" on Justia Law

After a jury trial, Defendant was convicted of first degree murder under the special circumstances of kidnapping- and robbery-murder, of kidnapping, and of robbery. The jury also found Defendant personally used a firearm in committing each crime. The trial court imposed a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not prejudicially err in denying Defendant's motion to change venue; (2) the trial court did not err with regard to jury selection issues; (3) the trial court did not err with regard to guilt and special circumstance issues; (4) the trial court did not err with regard to certain penalty issues; and (5) not giving criminal defendants the right to take depositions does not violate equal protection. View "People v. Rountree" on Justia Law

After a jury trial, Defendant was found guilty of attempted voluntary manslaughter and assault with a firearm. Defendant waived a jury trial on the prior conviction allegations and admitted having suffered a prior serious felony conviction. Defendant informed the court, however, that the prior conviction had been reduced to a misdemeanor. The court sentenced Defendant to a total term of twenty-four years, which included a five-year sentence enhancement under Cal. Penal Code 667(a) based on Defendant's previously having been convicted of a serious felony. The court of appeal upheld imposition of the five-year enhancement, concluding that the prior assault remained a serious felony conviction for purposes of section 667(a), notwithstanding its having been reduced to a misdemeanor pursuant to Cal. Penal Code 17(b)(3) in 2006 and thereafter dismissed altogether. The Supreme Court reversed the judgment of the court of appeal insofar as it upheld imposition of a five-year sentence enhancement pursuant to section 667(a), holding that when the court in the prior proceeding reduced the assault conviction to a misdemeanor, that offense no longer qualified as a prior serious felony within the meaning of section 667(a), and could not be used to enhance Defendant's sentence. Remanded for resentencing. View "People v. Park" on Justia Law

After a jury trial, Defendant was found guilty of two first degree murders and two counts of second degree robbery. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) the trial court did not commit prejudicial error in pretrial proceedings, including its denial of three Batson/Wheeler motions; (2) the trial court did not commit prejudicial error during the guilt phase of the trial, including its upholding of the prosecutor's objection to defense counsel's questioning of an accomplice; (3) the trial court did not commit prejudicial err during the penalty phase of the trial; (4) Defendant failed to demonstrate he was prejudiced by trial counsel's assistance, and the remainder of Defendant's ineffective assistance of counsel claims could only be addressed in a habeas corpus petition; and (5) California's death penalty law is constitutional. View "People v. Williams" on Justia Law

The City of Riverside declared, by zoning ordinances, that medical marijuana dispensaries were prohibited within the City. Invoking these provisions, the City brought a nuisance action against a facility operated by Defendants. The trial court issued a preliminary injunction against the distribution of marijuana from the facility. The court of appeal affirmed. Defendants appealed, arguing that the Compassionate Use Act (CUA) and the Medical Marijuana Program (MMP) preempted the City's total ban on facilities that cultivated and distributed medical marijuana in compliance with the CUA and MMP. The Supreme Court affirmed, holding that California's medical marijuana statutes do not expressly or impliedly preempt the authority of California cities and counties, under their traditional land use and police powers, to allow, restrict, limit, or entirely exclude facilities that distribute medical marijuana, and to enforce such policies by nuisance actions. View "City of Riverside v. Inland Empire Patients Health & Wellness Ctr., Inc." on Justia Law

After a jury trial, Defendant was convicted of being an accessory for intentionally aiding a parolee in absconding from parole supervision. Defendant appealed, arguing that the act of assisting a parolee abscond from supervision did not satisfy the statutory definition of being an accessory. The court of appeal disagreed and affirmed her conviction. The Supreme Court affirmed, holding (1) Defendant assisted a parolee in absconding from parole because, under the relevant statute, Defendant aiding a principal in a felony with the intent that the principal could escape punishment; and (2) the court of appeal properly found substantial evidence supported Defendant's conviction. View "People v. Nuckles" on Justia Law

Defendant pleaded no contest to being a convicted felon in possession of a firearm and admitted a prior prison term allegation. The trial court imposed the stipulated prison sentence of four years and ordered Defendant to pay a jail booking fee. Defendant appealed, arguing (1) the statute authorizing the court to impose the booking fee required the court to determine if Defendant was able to pay it, and (2) Defendant was entitled to challenge this fee order for sufficiency of the evidence for the first time on appeal. The court of appeal affirmed the trial court's booking fee order. The Supreme Court affirmed, holding that a defendant who fails to contest the booking fee when the court imposes it forfeits the right to challenge it on appeal. View "People v. McCullough" on Justia Law

Defendant was charged with an assortment of felony and misdemeanor charges, mostly theft related. Over the prosecution's objection, Defendant pleaded no contest to all charges and was sentenced to five years in prison. The court of appeal held that the five-year sentence was the product of an unlawful judicial plea bargain and vacated Defendant's pleas and admissions. The Supreme Court affirmed in part, holding that the record was ambiguous as to whether the sentence proposed by the trial court reflected what the court believed was the appropriate punishment for Defendant and his offenses, regardless of whether Defendant was convicted by plea or following trial, or instead reflected what the court believed was necessary to induce Defendant to enter a plea. Remanded to the trial court to clarify the ambiguity. View "People v. Clancey" on Justia Law