Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of the first degree murder of Raymond Shield. In addition, the jury (1) found true the special circumstance allegation that Defendant murdered Shield while in the commission of an attempted robbery, (2) found Defendant guilty of second degree attempted robbery of Shield, and (3) found Defendant guilty of three other second degree robberies of four other victims. Defendant was sentenced to death for the murder and prison terms for the robberies. The Supreme Court affirmed the trial court's judgment in its entirety, holding that the trial court did not commit reversible error in its rulings regarding jury selection, regarding the guilt phase of the trial, and regarding the penalty phase of the trial. View "People v. Watkins" on Justia Law

Plaintiff, a wheelchair user, sued a grocery store owner, contending that a four-inch step located at the entry of the market was an architectural barrier that prevented him and other wheelchair-bound individuals from wheeling into the store and asserting four state and federal law disability access claims. The trial court granted summary judgment for Defendant. The trial court concluded fees for a prevailing defendant under Cal. Civ. Code 55 were mandatory and awarded Defendant $118,458. The court of appeal affirmed. The Supreme Court affirmed, holding that appellate court did not err in determining that Defendant, as the prevailing party, was entitled to costs and, under section 55, to appellate attorney fees as well, as (1) the plain language of section 55 makes an award of fees to any prevailing party mandatory; and (2) the federal Americans with Disabilities Act does not preempt this part of the state's attorney fee scheme for disability access suits. View "Jankey v. Lee" on Justia Law

This case involved the constitutional limits of a vehicle search based on a passenger's parole status. Here, an officer, aware that the front seat passenger was on parole, searched the back seat of Defendant's car and recovered drugs and drug paraphernalia from a chips bag and a pair of shoes. Defendant, the driver, sought to suppress that evidence. Defendant's suppression motion was denied, and Defendant pleaded guilty to four misdemeanor counts. The court of appeal reversed, holding that the search could not be justified on the basis of the front seat passenger's parole status. The Supreme Court reversed, holding that the search was reasonable under the Fourth Amendment where (1) the Constitutional permits a search of those areas of the passenger compartment where the officer reasoanbly expects that the parolee could have stowed personal belongings or discarded items when aware of police activity; and (2) additionally, the officer may search personal property located in those areas if the officer reasonably believes that the parolee owns those items or has the ability to exert control over them. View "People v. Schmitz" on Justia Law

Defendant and five others carried out the September 1985 murders of Vera and Gerald Woodman in California. In a federal prosecution against Defendant, a jury in 1991 convicted him of murder for hire, for which he was sentenced to life imprisonment. Thereafter, Defendant unsuccessfully requested the Los Angeles County Superior Court to dismiss the murder charges then pending against him in this case, asserting that Cal. Penal Code 656's prohibition against double jeopardy precluded the California prosecution because it was founded upon the same act that was the basis of his earlier conviction in federal court. A majority of the California Supreme Court upheld the trial court's rejection of Defendant's claims and affirmed Defendant's capital murder convictions, holding (1) unlike the preceding murder-for-hire federal prosecution, the California murder charges against Defendant included a lying-in-wait special-circumstance allegation, and thus, the California charges against Defendant required proof of conduct that was not required for conviction of the earlier federal charges; and (2) Defendant's remaining allegations of error did not result in prejudice to Defendant. View "People v. Homick" on Justia Law

Petitioner was convicted in 1997 for the murder of his wife. Petitioner subsequently sought habeas corpus relief, stating that his murder conviction was based on false evidence given at trial by the prosecution's dental expert. The dental expert stated that he had testified inaccurately at trial. Other dental experts agreed that the expert had testified inaccurately based on newly available computer technology. After an evidentiary hearing, the superior court granted habeas corpus relief. The court of appeals disagreed. At issue on appeal was whether a conviction is based on "false evidence" when it depends in part on the opinion of an expert witness, and posttrial advances in technology have raised doubts about the expert's trial testimony without conclusively proving that testimony to be untrue. The Supreme Court affirmed, holding (1) in such circumstances the expert's trial testimony was not shown to be "false evidence," but the information garnered from technological advances could be presented as newly discovered evidence in support of habeas corpus relief; and (2) habeas corpus relief should be granted only if the new evidence points unerringly to innocence or reduced culpability, a showing that Petitioner did not make. View "In re Richards" on Justia Law

Defendant was convicted on two counts of possessing a firearm after conviction of a felony in violation of Cal. Penal Code 12021(a)(1) and two counts of possession a firearm after conviction of a specified violent offense in violation of Cal. Penal Code 12021.1(a). All four counts were based on Defendant's simultaneous possession of two firearms. The court of appeal reversed Defendant's section 12021.1(a) convictions, finding that violent offender in possession under section 12021.1(a) was a necessarily included offense of offender in possession under section 12021(a)(1). The Supreme Court reversed, holding (1) Defendant was properly convicted of both offenses because neither section 12021.1(a) nor section 12021(a)(1) is a necessarily included offense of the other; and (2) Defendant may be separately punished for two violations of section 12021(a)(1) and of section 12021.1(a) based on his simultaneous possession of two firearms, but he may not also be separately punished for violations of section 12021(a)(1) and section 12021.1(a) based on possession of the same firearm. Remanded. View "People v. Sanders" on Justia Law

While in Defendant's care, Defendant's young son died of shock and hemorrhage due to blunt force trauma. A jury convicted Defendant of involuntary manslaughter and assault on a child causing death. As relevant here, the court of appeal reversed the conviction upon finding the trial court erroneously failed to instruct the jury, sua sponte, on simple assault as a lesser included offense. The Supreme Court reversed and remanded with directions to reinstate the conviction, holding that the trial court had no sua sponte duty to instruct on that lesser offense, as (1) such instructions are required only when there is substantial evidence that, if the defendant is guilty at all, he is guilty of the lesser offense, but not the greater; and (2) here, it would be speculative at best to construe the trial evidence in this case as supporting a verdict of only simple assault. View "People v. Wyatt" on Justia Law

Prison regulations promulgated by the California Department of Corrections and Rehabilitation (CDCR) provide that validation of an inmate as a gang member or associate can result in the inmate's placement in a security housing unit. The current dispute arose when the CDCR validated Petitioner as a gang associate. Petitioner filed a petition for writ of habeas corpus, which the superior court denied. The court of appeal granted relief based on a disagreement with the CDCR over the interpretation of the CDCR's regulation. The Supreme Court reversed, holding that the court of appeal failed to accord due deference to the CDCR's interpretation of its own regulations. View "In re Cabrera" on Justia Law

Defendant was charged with murder, pled not guilty, and also raised an insanity defense. At the guilt phase trial, the prosecutor requested a jury instruction that Defendant was conclusively presumed to have been sane at the time of the offense. Defendant objected that the instruction might lead the jury to disregard the evidence of his mental illness and its effect on the intent required for murder. The court overruled the objection, gave the instruction on the presumption of sanity, and refused Defendant's request for an instruction on the legal definition of sanity. The jury convicted Defendant of first degree murder. The court of appeal affirmed. The Supreme Court affirmed, holding (1) although Defendant established no due process violation, the instruction was erroneous under state law, as the question of a defendant's sanity is entirely irrelevant at the guilt phase of a bifurcated trial under Cal. Pen. Code 1026; but (2) the error was harmless in this case. View "People v. Mills" on Justia Law

Defendant and Codefendant were charged with murdering two men by running over each of them with a car. The prosecution's theory was that one of the two victims had been drugged before he was killed. To prove this point, the prosecution presented the testimony of a laboratory director who, relying on reports not prepared by him, testified that testing of the victim's blood samples by analysts at his laboratory had determined the presence of drugs that could have caused drowsiness. According to Defendant, that testimony violated her Sixth Amendment right to confront and cross-examine the analysts who had tested the blood samples. The jury found both Defendant and Codefendant guilty of two counts of first degree murder and two counts of conspiracy to commit murder. The court of appeal affirmed, holding that even if there was a confrontation right violation, the error was not prejudicial. The Supreme Court affirmed, holding that in light of the overwhelming evidence against Defendant, exclusion of the laboratory director's trial testimony would, beyond a reasonable doubt, not have affected the outcome of Defendant's trial. View "People v. Rutterschmidt" on Justia Law