Justia Constitutional Law Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeal that a Department of Insurance regulation prohibiting bail bond agents from entering into agreements with jail inmates to be notified when individuals have recently been arrested and thus may be in need of bail bond services was facially invalid under the First Amendment, holding that the court of appeal erred in holding that the regulation was unconstitutional on its face.In declaring the regulation constitutionally invalid the court of appeal concluded that the regulation imposed burdens on the free speech rights of bail bond agents that were not adequately justified by the State's interests in deterring abusive bail solicitation practices. The Supreme Court reversed, holding that the regulation burdened a protected speech right, that intermediate scrutiny applied, and that the regulation passed constitutional muster. View "People v. Martinez" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the trial court's judgment concluding that the at-large method of electing city council members in the City of Santa Monica diluted Latino voters' ability to elect their preferred candidates and their ability to influence the outcome of council elections, holding that the court of appeals misconstrued the California Voting Rights Act of 2001, Cal. Elec. Code 14025 et seq. (CVRA).The superior court ruled in favor of Plaintiffs on their claims that the racially polarized voting in the City violated the CVRA. The superior court ruled in favor of Plaintiffs and ordered the City to conduct a special election using a seven-district map drafted by an expert who testified at trial. The court of appeal reversed, concluding that there had been no dilution of Latino voters' ability to elect their preferred candidates or their ability to influence the outcome of the election. The Supreme Court reversed, holding (1) a court presented with a dilution claim should undertake a searching evaluation of the totality of the facts and circumstances; and (2) because the court of appeal did not evaluate the dilution element of the CVRA under the proper standard, remand was required. View "Pico Neighborhood Ass'n v. City of Santa Monica" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming Defendant's conviction of first-degree murder, holding that when the record contains substantial evidence of imperfect self defense, the trial court's failure to instruct on that theory amounts to constitutional error and is subject to review under the federal Chapman standard. See Chapman v. California, 386 U.S. 18 (1967).On appeal, Defendant argued that the trial court committed harmful error in denying his request for an instruction on imperfect self-defense. The court of appeals affirmed, concluding that the trial court erred but that the error was subject to the "reasonable probability" standard for evaluating prejudice set forth in People v. Watson, 46 Cal.2d 818 (1956) and that Defendant suffered no prejudice. The Supreme Court reversed, holding (1) the form of misconstruction in this case precluded the jury from making a finding on a factual issue necessary to establish the element of malice, thus qualifying as a federal error; and (2) the court of appeal's harmless error analysis did not comport with the standards for evaluating prejudice under Chapman. View "People v. Schuller" on Justia Law