Justia Constitutional Law Opinion Summaries

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

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

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

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

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

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

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

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

The Supreme Court affirmed the judgment of the trial court convicting Defendant of the first degree murder of a twelve-year-old boy, finding true the special circumstance that the murder was committed while Defendant was engaged in the commission of a lewd and lascivious act on the child, and sentencing Defendant to death.Specifically, the Court held (1) there was not substantial evidence of Defendant’s present incompetence that required the trial court, on its own motion, to declare a doubt and conduct a competence hearing during the penalty phase of trial; (2) Defendant’s constitutional challenge to the death penalty for mentally ill defendants was unavailing; (3) there was sufficient evidence of first degree murder and sufficient evidence to support a true finding on the special circumstance allegation; (4) Defendant’s argument that the trial court erred in excluding testimony regarding the victim’s relationships lacked merit; (5) the challenged jury instructions were not improper; (6) there was no reasonable possibility that the prosecutor’s comments during the penalty phase affected the jury’s verdict; and (7) Defendant’s challenges to California’s death penalty scheme failed. View "People v. Ghobrial" on Justia Law

In this habeas case, the Supreme Court held that Juror No. 045882, who, during Petitioner’s criminal proceedings, intentionally concealed that he had previously been convicted of public fighting and was then on probation, was not actually biased against Petitioner and that no prejudicial misconduct occurred.Petitioner was convicted of two counts of first degree murder and was sentenced to death. While his appeal was pending, Petitioner filed this habeas petition, alleging that Juror No. 045882 committed misconduct. This Court issued an order instructing the Secretary of the Department of Corrections and Rehabilitation (CDCR) to show cause why the Court should not grant Petitioner relief based on juror misconduct. A referee appointed by the Court concluded that the juror at issue was not actually biased. The Supreme Judicial Court agreed and discharged the order to show cause, holding that there was no substantial likelihood that the juror harbored actual bias against Petitioner. View "In re Cowan" on Justia Law