Justia Constitutional Law Opinion Summaries

The case involves Jeremiah Ira Williams, who was sentenced to an indeterminate prison term of 100 years to life plus 86 years and two months for committing multiple forcible sexual offenses under California's One Strike law when he was 24 years old. Williams argued that the exclusion of One Strike offenders from early parole eligibility under California’s youth offender parole statute (Pen. Code, § 3051) violated his equal protection rights under the Fourteenth Amendment. He contended that it was irrational to exclude young adults convicted of One Strike offenses from early parole while not excluding young adults convicted of murder without special circumstances.The San Diego County Superior Court convicted Williams on multiple counts, including robbery, forcible rape, and sodomy by use of force, among others. The jury found him guilty on most counts and found true several aggravating factors, including personal use of a firearm and infliction of great bodily injury. The trial court imposed the lengthy sentence based on these findings. Williams appealed to the Fourth Appellate District, Division One, arguing that the exclusion of One Strike offenders from early parole eligibility violated equal protection. The Court of Appeal rejected his claim, finding a rational basis for the differential treatment based on the threat of recidivism by violent sexual offenders.The Supreme Court of California reviewed the case and affirmed the Court of Appeal’s judgment. The court held that the Legislature could rationally exclude One Strike offenders from early parole eligibility under section 3051 based on concerns about the high risk of recidivism and the aggravated nature of their offenses. The court concluded that these concerns provided a rational basis for the differential treatment, thus rejecting Williams' equal protection challenge. The court remanded the matter to the Court of Appeal to consider any briefing on Williams' entitlement to the benefit of any ameliorative legislation enacted during the pendency of his appeal. View "People v. Williams" on Justia Law

Robert Ward Frazier was convicted by a jury of the murder, forcible rape, and forcible sodomy of Kathleen Loreck. The jury also found true two felony-murder special-circumstance allegations. At the penalty phase, the jury returned a death verdict, which the trial court upheld, sentencing Frazier to death. Frazier's appeal is automatic.The trial court excused a prospective juror for cause due to his views on the death penalty, denied Frazier's request for individually sequestered voir dire, and gave a jury instruction on flight from the scene of a crime. The court also denied Frazier's requests to represent himself during the penalty phase and post-verdict proceedings, including the hearing on his automatic motion to modify the death verdict and sentencing.The California Supreme Court affirmed the trial court's decisions. The court held that the trial court did not err in excusing the prospective juror, as substantial evidence supported the finding that the juror's views would substantially impair his performance. The court also found no error in denying individually sequestered voir dire, as there is no federal constitutional requirement for such in capital cases, and the trial court did not abuse its discretion under state law.The court upheld the flight instruction, finding sufficient evidence to support it and rejecting Frazier's additional arguments against the instruction. The court also ruled that Frazier's requests for self-representation were untimely and that the trial court did not abuse its discretion in denying them. Finally, the court rejected Frazier's claim that his Sixth Amendment right to choose the objective of his defense was violated by the presentation of certain mitigating evidence over his objection. View "P. v. Frazier" on Justia Law

Wilson next argues that the trial court erred in admitting statements he made to detectives after the break when he was outside smoking with Detective Hagen. As Wilson notes, Detective Hagen agreed to end the interview in response to Wilson’s statement that he was not going to discuss the case further and request to be taken back to the holding cell. These circumstances reflect Wilson’s unambiguous invocation of his right to remain silent. (People v. Krebs, supra, 8 Cal.5th at p. 313 [defendant’s invocation was unambiguous when he asked to be returned to his cell and told officers he had nothing to say].) Despite recognizing that Wilson no longer wished to speak, Detective Hagen made additional comments that were reasonably likely to prompt Wilson to continue speaking: He encouraged Wilson to cooperate “right now” to get beneficial treatment before his “partner” did, and he stated that he had “[n]o doubt [Wilson] did it.”However, the trial court found that Wilson reinitiated the conversation during the cigarette break, and substantial evidence supports this finding. Detective Hagen testified that Wilson began discussing the case again during the break, expressing concerns about his family’s safety and asking questions about the investigation. This testimony indicates that Wilson voluntarily chose to resume the conversation, thereby waiving his previously invoked right to remain silent. The trial court’s credibility determinations and factual findings are supported by substantial evidence, and we defer to those findings.Given these circumstances, the trial court did not err in admitting the statements Wilson made to the California detectives after the cigarette break. Wilson’s reinitiation of the conversation and his voluntary engagement in the subsequent interview indicate that his statements were not the product of coercion or improper interrogation tactics. Therefore, the admission of these statements did not violate Wilson’s Fifth Amendment rights. View "P. v. Wilson" on Justia Law

The case involves Business and Professions Code section 7451, enacted through Proposition 22, which classifies app-based drivers for companies like Uber, Lyft, and DoorDash as independent contractors rather than employees, provided certain conditions are met. This classification exempts these drivers from California workers’ compensation laws, which typically apply to employees. Plaintiffs, including several individuals and unions, argue that section 7451 conflicts with article XIV, section 4 of the California Constitution, which grants the Legislature plenary power to create and enforce a complete system of workers’ compensation.The Alameda County Superior Court found Proposition 22 unconstitutional, reasoning that it improperly limited the Legislature’s power to govern workers’ compensation, a power deemed "unlimited" by the state Constitution. The court held that the people must amend the Constitution through an initiative constitutional amendment, not an initiative statute, to impose such limitations. Consequently, the court invalidated Proposition 22 in its entirety.The California Court of Appeal reversed the lower court’s decision, holding that article XIV, section 4 does not preclude the electorate from using its initiative power to legislate on workers’ compensation matters. The court reasoned that the Legislature’s power under article XIV, section 4 is not exclusive and that Proposition 22 does not conflict with this constitutional provision. The court did, however, affirm the invalidation of certain severable provisions of Proposition 22 not at issue in this appeal.The California Supreme Court affirmed the Court of Appeal’s judgment, agreeing that section 7451 does not conflict with article XIV, section 4. The court held that the Legislature’s plenary power under article XIV, section 4 is not exclusive and does not preclude the electorate from enacting legislation through the initiative process. The court did not address whether other provisions of Proposition 22 improperly constrain the Legislature’s authority, as those issues were not presented in this case. View "Castellanos v. State of California" on Justia Law

The case involves John Harris, Jr., who was charged with attempted first degree murder and aggravated mayhem related to a violent rape committed over 30 years ago. The charges were based on a DNA match between Harris and evidence from the crime scene. The prosecution sought to detain Harris without bail under a provision of the California Constitution (article I, section 12(b)) that allows for pretrial detention without bail for certain violent felonies, if there is clear and convincing evidence that the person's release would result in great bodily harm to others.The trial court denied Harris's bail, relying on a proffer by the prosecution that included hearsay evidence and documents without the full evidentiary foundation required at trial. Harris challenged this decision, arguing that only evidence admissible at a criminal trial could support pretrial detention without bail.The Court of Appeal rejected Harris's argument but conditionally vacated the order denying bail and remanded the matter to the trial court for further findings, because the trial court failed to consider less restrictive alternatives to detention.The Supreme Court of California held that a trial court may consider reliable proffered evidence in making factual findings under article I, section 12(b) without violating due process principles. However, the court remanded the case to the trial court to apply the standards discussed in its opinion and to consider less restrictive alternatives to detention. View "In re Harris" on Justia Law

The Supreme Court of California ruled that the Taxpayer Protection and Government Accountability Act (TPA), a proposed initiative measure, could not be placed on the November 2024 general election ballot. The TPA sought to revise the California Constitution by requiring voter approval for any new or increased state or local tax, and by expanding the definition of "tax" to include a wider range of government charges. The petitioners, the Legislature of the State of California, Governor Gavin Newsom, and former Senate President Pro Tempore John Burton, argued that the TPA was invalid because it attempted to revise the California Constitution via citizen initiative, and because it would seriously impair essential government functions.The court agreed with the petitioners, finding that the TPA would substantially alter the basic governmental framework set forth in the California Constitution. The court noted that the TPA would eliminate the Legislature's ability to levy taxes without prior voter approval, shift power between the executive and legislative branches, and transform local revenue-raising by requiring that exempt charges go through legislative rather than administrative processes. The court concluded that these changes were so significant that they amounted to a revision of the Constitution, which could not be enacted by initiative. The court therefore issued a writ of mandate directing the Secretary of State to refrain from placing the TPA on the November 2024 election ballot. View "Legislature of the State of California v. Weber" on Justia Law

In California, the People v. Hardin case involves the defendant, Tony Hardin, who is serving a life sentence without parole for a special circumstance murder he committed at age 25. Hardin challenged the constitutionality of a California statute that provides parole hearings for most young adult offenders but excludes those serving life sentences without parole for crimes committed after turning 18.The Supreme Court of California found that the legislature acted rationally in distinguishing between young adults serving life sentences without parole and those serving parole-eligible sentences for crimes committed when they were young. The court reasoned that the legislature's decision to exclude certain offenders from parole hearings reflected a balance of multiple considerations, including the seriousness of the offender's crimes and the capacity of all young adults for growth.The court stated that while the primary purpose of the statute was to provide opportunities for early release to certain young adults, the legislature also considered other factors. It could rationally balance the seriousness of the offender's crimes against the capacity of all young adults for growth, and determine that young adults who have committed certain very serious crimes should remain ineligible for release from prison.The court also noted that it is the legislature's prerogative and duty to define degrees of culpability and punishment and to distinguish between crimes. Therefore, Hardin's argument that the statute violates the Fourteenth Amendment’s equal protection guarantee by irrationally discriminating against young adult offenders sentenced to life without parole was dismissed, and the judgment of the Court of Appeal was reversed. View "P. v. Hardin" on Justia Law

In the Supreme Court of California, the defendant, Glen Taylor Helzer, pleaded guilty to five counts of murder and multiple other charges, including robbery, kidnapping, and conspiracy. After a penalty trial, the jury sentenced him to death for the five counts of murder. The murders were particularly gruesome, involving kidnapping, robbery, and dismemberment of the bodies. The defendant argued that he was under the influence of methamphetamine and suffering from a mental or emotional disturbance at the time of the crimes. On appeal, the defendant raised several issues, including the exclusion of a potential juror due to their views on the death penalty, the denial of a proposed question during jury selection, and the admission of graphic evidence including photographs of the dismembered bodies and the sound of a power saw used in the dismemberment during the prosecution's closing argument. The court affirmed the judgment, finding that the trial court did not abuse its discretion in its rulings and that any error was harmless. The court held that the photographs and the sound of the saw were relevant to the circumstances of the crimes and did not unduly prejudice the jury. The court also held that the removal of a potential juror due to their views on the death penalty did not violate the defendant's right to a representative jury. View "People v. Helzer" on Justia Law

In the case of The People v. Fernando Rojas, the Supreme Court of California addressed the issue of whether the application of Assembly Bill 333 to the gang-murder special circumstance in section 190.2(a)(22) of the California Penal Code constituted an unlawful amendment of Proposition 21, which had previously defined the term "criminal street gang".The defendant, Fernando Rojas, was convicted of first degree murder and was found to have committed the crime while being an active participant in a criminal street gang, which made him subject to life imprisonment without the possibility of parole under section 190.2(a)(22). While Rojas's appeal was pending, the state legislature passed Assembly Bill 333, which substantially narrowed the definition of "criminal street gang" for the purposes of section 190.2(a)(22).The lower courts disagreed on whether the application of Assembly Bill 333 would constitute an unlawful amendment of Proposition 21, which had been passed by the voters and was therefore protected from legislative amendment without a two-thirds majority vote of each house of the legislature or approval by the voters.The Supreme Court of California concluded that the application of Assembly Bill 333 to the gang-murder special circumstance did not violate the limitation on legislative amendment in Proposition 21. The Court reasoned that the voters who enacted Proposition 21 intended to impose a specific punishment for gang-related murder while relying on an existing statutory provision to define "criminal street gang". The Court found no indication that the voters intended to adopt a fixed definition of "criminal street gang" and held that applying Assembly Bill 333's narrower definition did not change the punishment for those convicted of the gang-murder special circumstance. Therefore, the Court reversed the judgment of the Court of Appeal and remanded the case for further proceedings. View "P. v. Rojas" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Petitioner's petition for relief and resentencing under the new procedure set forth in Senate Bill No. 1437 (former Cal. Penal Code 1170.95, subd. (a); now Cal. Penal Code 1172.6, subd. (a)), holding that the trial court erred.Petitioner was convicted of first degree murder and sentenced to life imprisonment without the possibility of parole. Twelve years later, the Legislature enacted Senate Bill 1437 narrowing or eliminating certain forms of accomplice liability for murder. Petitioner petitioned for relief and resentencing under the new procedure, but the trial court denied the petition for failure to state a prima facie case. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court erred in rejecting Petitioner's prima facie showing and should have proceeded to an evidence hearing on Petitioner's resentencing petition. View "People v. Curiel" on Justia Law