Articles Posted in Supreme Court of California

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The Supreme Court affirmed in its entirety the judgment of the trial court imposing a sentence of death after a jury convicted Defendant of first degree murder, holding that no reversible error occurred in the proceedings below. Defendant was convicted of first degree murder, robbery, and grand theft. The jury found that the murder occurred during a robbery and that Defendant personally used a firearm. The jury then returned a verdict of death. The trial court imposed that sentence, as well as an aggregate determinate sentence of eight years four months. The Supreme Court affirmed, holding that no prejudicial error occurred during the pretrial proceedings, the guilt phase proceedings, or the penalty phase proceedings. Further, the Court held that Defendant’s death judgment did not constitute cruel and unusual punishment in light of his youth and intellectual shortcomings, that Defendant’s challenges to the constitutionality of California’s death penalty statute failed, and that Defendant’s claim of cumulative prejudice must be rejected. View "People v. Powell" on Justia Law

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The Supreme Court held that voter approval was not required for a transfer from a utility’s enterprise fund to the city’s general fund. Cal. Const. art. XIIIC prohibits local governments from imposing or increasing any tax without voter approval. Any charge imposed for a service or product that does not exceed the reasonable costs of providing it is excepted from the definition of tax. The City of Redding operated an electric utility as a department of its city government. At issue was whether an annual interfund transfer from the utility’s enterprise fund to the city’s general fund required voter approval where the transfer was intended to compensate the general fund for costs of services that other city departments provide to the utility. The Supreme Court held that because neither the budgetary transfer nor the rate the city charged its utility customers constituted a tax, voter approval was not required. View "Citizens for Fair REU Rates v. City of Redding" on Justia Law

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The Supreme Court affirmed the judgment of the Court of Appeal concluding that some overlap between the Investigative Consumer Reporting Agencies Act (ICRAA), Cal. Civ. Code 1786 et seq. and the Consumer Credit Reporting Agencies Act (CCRAA), Cal. Civ. Code 1785.1 et seq., does not render ICRAA unconstitutionally vague as applied to employer background checks when the statutes are otherwise unambiguous. In this class action, Plaintiff sued Defendants, investigative consumer reporting agencies, for violating ICRAA because Defendants did not obtain her written authorization to conduct a background check. Defendants moved for summary judgment, claiming (1) ICRAA was unconstitutionally vague as applied to Plaintiff’s claim because it overlapped with CCRAA, and (2) Defendants satisfied CCRAA. The trial court granted the motion. The Court of Appeal reversed. The Supreme Court affirmed and remanded, holding (1) the background check that Defendants conducted was an investigative consumer report under ICRAA; and (2) although the CCRAA also applied here, Defendants were not exempted from the requirement that they obtain Plaintiff’s written authorization under ICRAA before conducting or procuring a background investigation. View "Connor v. First Student, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death following a second penalty proceeding, holding that there was no error requiring reversal. Specifically, the Court held (1) the Ireland merger doctrine did not bar Defendant’s convictions for torture murder and mayhem murder; (2) the evidence was sufficient to support Defendant’s convictions for torture murder and rape murder; (3) the trial court’s admission of gang affiliation evidence during the guilt phase of trial was harmless; (4) the evidence supported the special circumstance findings of torture murder and mayhem murder; (5) the jury’s finding that Defendant was sane at the time of the killing did not require reversal; (6) the trial court did not err in admitting evidence of Defendant’s possible gang affiliation and racist beliefs during the penalty phase; (7) imposition of the death penalty on a mentally ill defendant does not violate the Eighth Amendment; and (8) Defendant’s constitutional challenges to California’s imposition of the death penalty failed. View "People v. Powell" on Justia Law

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After issuing an order to show cause with respect to Petitioner habeas claim that prejudicial juror misconduct occurred when a juror did not timely disclose a history of childhood abuse, the Supreme Court discharged the order to show cause and held that Petitioner was not entitled to relief. Petitioner was convicted of four counts of first degree murder and was sentenced to death. Petitioner then filed this amended habeas corpus petition alleging that the jury foreperson had committed misconduct by concealing that he was abused as a child. The Supreme Court issued an order to show cause and ordered a reference hearing directing a referee to answer four questions. After an evidentiary hearing, the referee found that there was no prejudicial juror misconduct because the juror’s nondisclosure was neither intentional nor deliberate and that juror was not biased against Petitioner. The Supreme Court agreed generally with the referee’s findings and held that Petitioner failed to establish that he was entitled to habeas corpus relief on his claim of prejudicial juror misconduct. View "In re Manriquez" on Justia Law

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The Supreme Court reversed the sentence of death imposed in connection with Defendant’s conviction for the first degree murder of a police officer and the attempted murder of a police officer, holding that the trial court, over defense objection, erroneously excused for cause a prospective juror based on his written response to questions about his view on capital punishment, requiring reversal of the penalty verdict. After finding that Defendant did not have an intellectual disability, and following a penalty trial, the jury returned a verdict of death. The trial court imposed a judgment of death after denying the automatic motion to modify the verdict. The court also imposed a prison sentence on the other counts for which Defendant was convicted and enhancement allegations. The Supreme Court held (1) the trial court erred in excusing a prospective juror based on his questionnaire responses, an error that automatically compelled reversal of the penalty phase; and (2) the trial court’s judgment is affirmed in all other respects. View "People v. Woodruff" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of murdering James Madden and sentencing Defendant to death. On appeal, Defendant raised a number of issues, most of which focused on purported errors made by the trial court. Defendant also took issue with the Supreme Court’s decision not to supplement the appellate record with the trial transcripts of his codefendants and also challenged the constitutionality of California’s death penalty scheme. The Supreme Court affirmed the judgment of the trial court in its entirety, holding that there was no reversible error in this case. View "People v. Spencer" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendants Joseph Adam Mora and Ruben Rangel of two counts of murder and two counts of attempted robbery and sentencing Defendants to death. On appeal, Defendants argued that several errors during the guilt and penalty phases of their trial warranted reversal of their convictions. The Supreme Court disagreed with the exception of a guilt phase instructional error. The Court held (1) the trial court erred by permitting the jury to find the multiple murder special circumstance try without finding that either defendant intended to kill or actually killed either victim, but the error was harmless; and (2) no error or assumed error, whether considered separately or collectively, merited reversal. View "People v. Mora" on Justia Law

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The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death. Defendant was convicted of first-degree murder for killing his girlfriend’s twenty-one-month-old granddaughter, assault resulting in the death of a child under eight years old, and committing lewd and lascivious conduct on a child under the age of fourteen. The Supreme Court affirmed, holding (1) the admission of testimony from child witnesses was not in error and did not violate Defendant’s due process rights; (2) the evidence was sufficient to support Defendant’s murder conviction; (3) the trial court did not err in admitting evidence of a witness’s broken leg; (4) the trial court did not improperly coerce a death verdict; (5) the trial court’s response to a jury question, coupled with the prosecutor’s argument, did not allow the jury to consider inadmissible evidence during its penalty determination; (6) the prosecutor did not commit error under Griffin v. California, 380 U.S. 609 (1965); and (7) the admission of rebuttal character evidence was not in error. View "People v. Lopez" on Justia Law

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At issue was how to assess the validity of a stipulation entered into by Defendant, through counsel, that admitted all of the elements of a charged crime, making it tantamount to a guilty plea, when Defendant was neither advised of, nor expressly waived, his privilege against self-incrimination or his rights to a jury trial and confrontation. The Supreme Court reversed the court of appeal’s judgment affirming Defendant’s conviction of misdemeanor driving when his driver’s license was suspended or revoked. The Court held (1) the test set forth in People v. Howard, 1 Cal.4th 1132 (1992), that a plea is valid notwithstanding the lack of express advisements and waivers if the record affirmatively shows that it is voluntary and intelligent under the totality of the circumstances applies in cases where there is a total absence of advisements and waivers; and (2) applying that test, the record failed affirmatively to show that Defendant understood his counsel’s stipulation had the effect of waiving Defendant’s constitutional rights. View "People v. Farwell" on Justia Law