Articles Posted in Supreme Court of California

by
The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of first-degree murder and other crimes and sentencing him to death but remanded the case to the trial court for reconsideration of Defendant’s restitution fine. The court held (1) although Defendant’s absent from portions of the proceedings violated his statutory right to be present, the error was harmless; (2) the trial court did not violate Defendant’s right to an impartial jury by excusing a prospective juror for cause because of her views on the death penalty; (3) the trial court did not err in admitting Defendant’s confession; (4) the trial court did not abuse its discretion by excluding evidence of a conditional plea offer as mitigation during the penalty phase; (5) Defendant’s challenges to California’s death penalty scheme were unavailing; and (6) the trial court applied the wrong statute in imposing Defendant’s restitution fine. View "People v. Wall" on Justia Law

by
The scan data gathered by automated license plate reader (ALPR) technology in this case was not subject to Cal. Gov. Code 6254(f)’s exemption for record of investigations. Petitioners filed a request under the California Public Records Act (CPRA) for all ALPR data collected during a one-week period by the Los Angeles Police Department and the Los Angeles Sheriff’s Department. At issue before the Supreme Court was whether the requested ALPR data was exempt from disclosure as falling within the CPRA provision protecting police and state records of investigations under section 6254(f). The trial court concluded that the data came within section 6254(f)’s records of investigations exemption. The Court of Appeal affirmed. The Supreme Court reversed the Court of Appeal judgment insofar as it rendered anonymized or redacted ALPR data exempt from disclosure, holding that the ALPR scan data at issue was not subject to section 6254(f)’s exemption for records of investigations. The court remanded for further consideration of whether raw data may reasonably be anonymized or redacted such that the balance of interests would shift and disclosure of the data would be required under the CPRA. View "American Civil Liberties Union Foundation of Southern California v. Superior Court of Los Angeles County" on Justia Law

by
The Supreme Court of California held that, in light of the text and other indicia of the purpose associated with the relevant constitutional and statutory provisions, Cal. Const., art. XIII C, section 2 does not limit voters' power to raise taxes by statutory initiative. The court explained that a contrary conclusion would require an unreasonably broad construction of the term "local government" at the expense of the people’s constitutional right to direct democracy, undermining the longstanding and consistent view that courts should protect and liberally construe it. In this case, the California Cannabis Coalition drafted a medical marijuana initiative proposing to repeal an existing City ordinance. The Coalition subsequently petitioned for a writ of mandate when the City failed to submit the initiative to the voters at a special election. The supreme court affirmed the court of appeal's holding that article XIII C, section 2 only governs levies that are imposed by local government, and thus directed the superior court to issue a writ of mandate compelling the City to place the initiative on a special ballot in accordance with Elections Code section 9214. View "California Cannabis Coalition v. Upland" on Justia Law

by
In 2012, plaintiff filed suit against Doe No. 1, a public entity, alleging that she was molested by defendant's employee when she was a high school student from 1993-1994. After the claim was denied, she filed this instant action against Doe No. 1 and Doe Nos. 2-20, alleging that latent memories of the sexual abuse resurfaced in early 2012, when she was about 34 years old. The Supreme Court of California held that the 2012 claim was not timely in light of Shirk v. Vista Unified School Dist. (2007) 42 Cal.4th 201. The court explained that when the Legislature amended Code Civ. Proc., 340.1 without modifying the claims requirement, and later overruled Shirk, but only prospectively, it took measured actions that protected public entities from potential liability for stale claims regarding conduct allegedly occurring before January 1, 2009, in which the public entity had no ability to do any fiscal planning, or opportunity to investigate the matter and take remedial action. View "Rubenstein v. Doe No. 1" on Justia Law

by
Petitioner’s constitutional challenges to Proposition 66, the Death Penalty Reform and Savings Act of 2016, did not warrant relief. Proposition 66, which was approved by California voters in the November 2016 election, is intended to facilitate the enforcement of judgments and achieve cost savings in capital cases. Petitioner sought writ relief from the Supreme Court, arguing that Proposition 66 embraces more than one subject in violation of the California Constitution, interferes with the jurisdiction of courts to hear original petitions for habeas corpus relief, violates inmates’ equal protection rights by treating capital prisoners differently from other prisoners with respect to successive habeas corpus petitions, and violates the separation of powers doctrine by materially impairing courts’ ability to resolve capital appeals and habeas corpus petitions. The Supreme Court denied relief, holding (1) Proposition 66 is not unconstitutional; but (2) in order to avoid separation of powers problems, provisions of Proposition 66 that appear to impose strict deadlines on the resolution of judicial proceedings must be deemed directive rather than mandatory. View "Briggs v. Brown" on Justia Law

by
The Medical Board of California did not violate patients’ right to privacy under Cal. Const. art. I, 1 when it obtained data from the Controlled Substance Utilization Review and Evaluation System (CURES), California’s prescription drug monitoring program, without a warrant or subpoena supported by good cause during the course of investigating the patients’ physician, Dr. Alwin Carl Lewis. The Supreme Court affirmed the judgment of the court of appeal, which determined that the Board’s actions did not involve a significant intrusion on a privacy interest protected by the state Constitution’s privacy provision and, even if there was an invasion of privacy, it was justified. The Supreme Court held that even assuming the Board’s actions constituted a serious intrusion on a legally protected privacy interest, its review of Lewis’s patients’ CURES records was justified by the state’s dual interest in protecting the public from the unlawful use and diversion of a particularly dangerous class of prescription drugs and protecting patients from negligent or incompetent physicians. View "Lewis v. Superior Court of Los Angeles County" on Justia Law

by
The Presiding Judge of the Los Angeles County Superior Court, Juvenile Division, issued a protocol addressing the process by which minors are found incompetent and later found to have attained competency. The Supreme Court of California held that although trial courts are not barred from adopting such protocols as guidance or as local rules, the Court of Appeal was correct that the protocol does not presumptively or otherwise define due process. The court declined to decide whether the length of detention in this case violated due process and instead held that any violation was not prejudicial in light of the juvenile court's finding of malingering. Accordingly, the court affirmed the judgment. View "In re Albert C." on Justia Law

by
The Supreme Court reversed Defendant’s conviction of first-degree murder, holding that the trial court's admission of the confession of Defendant’s accomplice violated Defendant’s Sixth Amendment right to confront her accusers because the jury was, in fact, asked to consider the accomplice’s confession for its truth. Defendant was found guilty of first-degree murder. On appeal, Defendant argued that the admission of her accomplice’s confession violated her constitutional right to confront her accomplice. The prosecution introduced the confession in rebuttal to Defendant’s trial testimony in which Defendant blamed the events on her accomplice, who had since died. The court of appeal affirmed, concluding that the accomplice’s confession was presented not to establish the truth of his account, in which he pinned much of the blame on Defendant, but instead to undermine Defendant’s competing account of their joint crime. The Supreme Court reversed, holding that the prosecution did not use the accomplice’s un-cross-examined confession for the limited nonhearsay purpose of impeaching the statements Defendant had attributed to her accomplice in her testimony. Rather, the prosecution used the accomplice’s confession as evidence establishing a different account of the crime, which the prosecution repeatedly invited the jury to consider for its truth. View "People v. Hopson" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first degree murder, thirteen counts of robbery, and two counts of attempted robbery and sentencing Defendant to death. The trial court found true the special circumstance allegation that Defendant committed the murder during the commission of a robbery. The conviction and sentence were rendered after bench trials for the guilt phases and penalty phases. The Supreme Court held (1) Defendant entered a knowing and intelligent jury waiver; (2) because there was no basis for concluding that Defendant would have chosen a jury trial for the special circumstance allegation had the trial judge avoided an error under People v. Memro 700 P.2d 446 (Cal. 1985), the error was harmless; (3) Defendant’s waiver of a jury trial for the penalty phase was adequate, and no reaffirmation of the waiver before the state of the penalty phase was required; (4) the trial court did not err in considering certain aggravating evidence at the penalty phase; and (5) Defendant’s miscellaneous challenges to the death penalty are rejected. View "People v. Sivongxxay" on Justia Law

by
During jury selection proceedings, three defendants joined in a Batson/Wheeler motion, arguing that the prosecutor improperly excluded prospective jurors on account of Hispanic ethnicity. The trial court denied the motion, finding the prosecutor’s reasons for exercising ten of sixteen peremptory challenges to remove Hispanic individuals from the jury panel to be neutral and nonpretextual. The court of appeal upheld the trial court’s denial of Defendants’ joint Batson/Wheeler motion. The Supreme Court reversed, holding (1) the trial court’s finding that Defendants had not met their burden of proving intentional discrimination with respect to at least one excluded panelist was unreasonable in light of the record of voir dire proceedings, and therefore, Defendants were denied their right to a fair trial and their right to a trial by a jury drawn from a representative cross-section of the community under the state Constitution; and (2) the court of appeal erred in refusing to conduct a comparative juror analysis. View "People v. Gutierrez" on Justia Law