Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of the first degree murder of a peace officer. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not err in failing to suspend proceedings and investigate whether Defendant was competent to stand trial; (2) Defendant’s ineffective assistance of counsel claim was inappropriate to address on appeal; (3) the trial court’s failure to suspend proceedings and hold a competency hearing prior to judgment did not violate Defendant’s due process rights; (4) the trial court did not err in allowing Defendant to waive his right to counsel; (5) the trial court did not err by failing to revoke Defendant’s self-representation during the penalty phase pursuant to Cal. Penal Code 686.1; (6) the trial court did not err in failing to obtain an updated Faretta waiver after the People filed a notice of intent to seek death; (7) Defendant’s claim that certain jurors should have been excused for cause was forfeited; (8) the trial court did not deprive Defendant of his constitutional right to testify in his own defense by excluding his liberty defense; and (9) Defendant’s challenges to the death penalty statute were without merit. View "People v. Mickel" on Justia Law

Defendant filed a motion to suppress the evidence found on his phone, arguing that the search of his phone resulted from an unduly prolonged and unjustified detention. The trial court denied the motion, concluding that the phone search was justified under the existing authority of People v. Diaz. The court of appeals affirmed, acknowledging that Diaz’s reasoning was repudiated in Riley v. California but determining that the good faith exception applied because Diaz was controlling law at the time. The Supreme Court reversed, holding (1) the phone search was conducted without a warrant and was improper; and (2) the good faith exception did not apply in this case because the search was not authorized by Diaz. View "People v. Macabeo" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. The jury returned a verdict of death, and the trial court entered the death judgment. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in denying Defendant’s motion for mistrial for discovery violations; (2) the prosecutor did not engage in prejudicial misconduct; (3) the trial court’s rulings regarding Defendant’s proffered third party culpability evidence were not in error; (4) the trial court did not abuse its discretion when it failed to exclude evidence of Defendant’s past uncharged incidents of sexual misconduct; (5) the trial court did not violate Defendant’s due process right to a fair trial in refusing to allow into evidence videotaped interviews of defense witnesses; (6) the trial court did not err in sustaining the prosecution’s objection to testimony that Defendant was alcohol dependent; (7) the trial court did not err in instructing the jury during the penalty phase; and (8) there was no constitutional violation of the state’s death penalty law. View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of both conspiracy to murder and the first-degree murder of her husband. The jury set the penalty at death after weighing aggravating and mitigating evidence presented by the parties. The Supreme Court affirmed the guilt and penalty judgments in their entirety, holding (1) the trial court’s determinations that seven jurors were all substantially impaired and subsequent exclusion of the jurors due to their views on the death penalty was adequately supported by the record; (2) the trial court did not err by denying Defendant’s motions to sever her trial from that of her codefendant; (3) the trial court did not commit reversible error in its rulings regarding several discovery issues; (4) the trial court did not err in its evidentiary rulings; (4) the jury instructions were proper; and (5) no prejudicial error occurred during the penalty phase of trial. View "People v. Thompson" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The jury also found true the special circumstance allegations that Defendant committed multiple murders and that the murders were committed while lying in wait. The jury was unable to reach a penalty verdict, and a second penalty phase was held. The jury returned a verdict of death, and the trial court entered a judgment of death. The Supreme Court (1) reversed the lying-in-wait special-circumstance, holding that the evidence was insufficient to support the inference that Defendant arrived at the murder scene before the victims arrived; (2) reversed the penalty judgment and remanded for retrial of the penalty phase, holding that the trial court’s investigation into the penalty phase retrial jury’s announce deadlock was so intrusive that it prejudicially invaded the deliberations and created a coercive effect on those deliberations; and (3) otherwise affirmed the convictions. View "People v. Nelson" on Justia Law

This dispute concerned a 1.66-acre strip of Defendants’ land that the City of Perris condemned in order to build a road. The City offered to pay Defendants the agricultural value of the strip, relying on City of Porterville v. Young. The trial court agreed with the City, concluding that Porterville applied in this case and that Defendants were entitled to a stipulated agricultural value of $44,000 for the taking. In so deciding, the trial judge concluded that the City’s dedication requirement was lawful under Nollan v. California Coastal Commission and Dolan v. City of Tigard. The Court of Appeal remanded the case to revisit the legality of the dedication requirement, concluding that the lawfulness of the dedication and requirement under Nollan and Dolan should have been decided by a jury, not a judge. The Supreme Court reversed, holding (1) the constitutionality of a dedication requirement under Nollan and Dolan is a question for a court, rather than a jury; and (2) the project effect rule generally applies, and the Porterville doctrine does not apply, to situations when it is probable at the time a dedication requirement is put in place that the property designated for public use will be included in the project for which the condemnation is sought. Remanded. View "City of Perris v. Stamper" on Justia Law

Defendant pleaded no contest to second degree burglary and having served a prior prison term for vehicle theft. Defendant was sentenced to probation on conditions including a year in jail and a condition that he not enter the premises or adjacent parking lot of any Home Depot store in California. The appellate court struck the challenged probation condition, concluding that the condition was unconstitutionally overbroad. The court also suggested that the condition violated Defendant’s constitutional right to travel. The Supreme Court reversed, holding (1) the probation condition at issue was reasonably related to Defendant’s crime and to preventing future criminality, rendering it permissible under state law; and (2) the condition did not implicate Defendant’s right to travel and thus was constitutionally permissible. View "People v. Moran" on Justia Law

California’s anti-SLAPP statute provides that a cause of action against a person arising from allegations of certain activity shall be subject to a special motion to strike unless the court determines there is a probability that the plaintiffs will prevail on the claim. At issue here was how a special motion to strike operates against a “mixed caused of action” that combines allegations of activity unprotected by the statute with allegations of protected activity. Plaintiff filed a second amended complaint pleading four causes of action against Defendant. Defendant filed an anti-SLAPP motion seeking to strike allegations within a certain cause of action. The trial court denied the motion without deciding whether the complaint contained allegations of protected activity, ruling that the motion applied to the complaint as a whole, not to isolated allegations. The court of appeal affirmed, concluding (1) an anti-SLAPP motion must be brought against a mixed cause of action in its entirety; and (2) Plaintiff established a probability of succeeding on claims based on allegations of activity not protected by the anti-SLAPP statute. The Supreme Court reversed, holding that the Legislature’s choice of the term “motion to strike” reflects the understanding that an anti-SLAPP motion may be used to attack parts of a count as pleaded. View "Baral v. Schnitt" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, first degree burglary, and first degree robbery. The jury was unable to reach a penalty verdict, and after the penalty phase was retried with a new jury, the trial court sentenced Defendant to death for the murder conviction and to 212 years to life on the remaining counts. The Supreme Court remanded the case to the trial court to recalculate the noncapital portion of Defendant’s sentence but affirmed the judgment in all other respects, holding (1) there was no prejudicial error in the trial court’s pretrial rulings; (2) the trial court erred in imposing consecutive sentences for certain sex crimes because they were committed against a single victim on a single occasion; and (3) no other prejudicial error occurred during the guilt phase and penalty phase of trial. View "People v. Jackson" on Justia Law

The California Department of Water Resources (Department) sought to conduct environmental and geological studies and testing on over 150 privately-owned parcels of property that the state, in the future, might seek to acquire. Proceeding through the procedure established by the California Eminent Domain Law relating to precondemnation entry and testing, the Department sought a court order granting it authority to enter the properties to undertake environmental and geological testing activities. The trial court authorized the Department to enter the private properties and conduct environmental activities but denied the Department’s request to conduct geological testing. The Court of Appeal affirmed the trial court’s denial of the Department’s proposed geological testing and reversed the trial court’s authorization of environmental testing, concluding that the procedure established by the precondemnation entry and testing statutes did not satisfy the demands of the California Constitution’s takings clause with regard to both the geological and environmental testing sought by the Department. The Supreme Court reversed, holding that, assuming, without deciding, that the environmental and geological activities amount to a taking or damaging of property, the procedure established by the precondemnation entry and testing statutes satisfies the requirements of the California takings clause when the procedure is reformed to comply with the jury trial requirement of that clause. View "Property Reserve, Inc. v. Superior Court" on Justia Law