Justia Constitutional Law Opinion Summaries

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

The Supreme Court affirmed Defendant's sentence of death, following resentencing, in connection with his convictions of first degree murder, two counts of forcible rape, and enhancements for personal use of a firearm, holding that any error in the resentencing was harmless beyond a reasonable doubt.When Defendant was convicted in 2000 the jury found true special circumstances for committing murder during a kidnapping and intentional infliction of torture and set the penalty at death. The Supreme Court upheld the guilt judgment but reversed the penalty verdict on the grounds that the trial court erroneously dismissed a juror during penalty phase deliberations. After a retrial, Defendant was again sentenced to death. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar Defendant's penalty retrial; (2) the penalty retrial did not violate due process; (3) Defendant's challenges to the constitutionality of California's death penalty statute were unavailing; and (4) any error brought about by retroactive application of Senate Bill 1437 was harmless beyond a reasonable doubt. View "People v. Wilson" on Justia Law

The Supreme Court held that Cal. Penal Code 667.6(d), which requires that a sentencing court impose "full, separate, and consecutive" terms for certain sex crimes if it finds certain facts, complies with the Sixth Amendment to the United States Constitution.Defendant was convicted of six counts of forcible lewd acts on a child under the age of fourteen and one lesser-included offense of attempt and sentenced to full, consecutive terms for each of his convictions. On appeal, Defendant argued that the trial court violated his Sixth Amendment right to a jury trial by sentencing him under section 667.6(d) without submitting to the jury the question of whether each of his offenses was committed on a separate occasion. The court of appeal denied relief. The Supreme Court affirmed, holding that the operation of section 667.6(d) does not violate the rule of Apprendi v. New Jersey, 530 U.S. 466 (2000), and Alleyne v. United States, 570 U.S. 99 (2013). View "People v. Catarino" on Justia Law

A gambling dispute incited a fistfight between gang subsets. Witnesses later testified that after they thought the fight was over, they saw Ferrell shoot a gun, then saw Rawlings, lying on the ground, bloodied. Ferrell dropped the gun and fled. Ferrell later claimed he had only shot once, into the air. The juvenile court transferred Ferrell, age 17, to a court of criminal jurisdiction, where he was charged with murder, with alleged sentencing enhancements for use of a firearm.The Court of Appeal affirmed Ferrell’s second-degree murder conviction and 40-year sentence. The California Supreme Court granted Ferrell habeas relief. The jury instructions erroneously permitted the conviction based on a felony-murder theory invalidated in 2009. The unadorned guilty verdict does not show that the jury avoided that theory. The court rejected an argument that the jury’s additional finding — that Ferrell intentionally discharged a firearm and caused death in committing his offense — along with other evidence, establish that any rational jury would have found Ferrell guilty under a valid theory of second-degree murder, implied malice. Even in light of the entire record, the jury’s additional finding fails to establish the mental component of implied malice, which requires a defendant to act with a conscious disregard for life, knowing his act endangers another’s life. The jury could have, consistent with its finding, concluded Ferrell shot Rawlings while trying to stop a fight without believing he was shooting toward any person. View "In re Ferrell" on Justia Law

In 2005, a jury convicted Lopez and three others of Gomez’s first-degree premeditated murder and found true the gang-murder special circumstance and the criminal street gang sentencing enhancement. Lopez was sentenced to life imprisonment without the possibility of parole. The Court of Appeal affirmed. Lopez sought habeas relief, alleging his jury had been instructed on the natural and probable consequences theory of aiding and abetting first-degree murder, found invalid in the California Supreme Court's 2014 "Chiu" decision. In 2019, the Court of Appeal held that the Chiu error was harmless beyond a reasonable doubt based on the gang-murder special circumstance, which required the jury to find that an aider and abettor acted with intent to kill, and the “overwhelming” evidence against Lopez generally. The court discounted the prosecutor’s discussion of the natural and probable consequences theory in his closing argument and found a jury note referencing that theory inconsequential under the circumstances.The California Supreme Court reversed. The gang-murder special circumstance here does not necessarily render the Chiu error harmless beyond a reasonable doubt but indications that the jury may have relied on an invalid theory, such as a prosecutor’s closing argument or a jury note, do not preclude a finding of harmlessness. The court must rigorously review the evidence to determine whether any rational juror who found the defendant guilty based on an invalid theory and made the factual findings reflected in the verdict, would necessarily have found the defendant guilty based on a valid theory. View "In re Lopez" on Justia Law

The Supreme Court affirmed Defendant's conviction for the first degree murder of Rafael Noriega and his sentence of death, holding that there was no reversible error in the proceedings below.A jury convicted Defendant of first degree murder and found true the special circumstance allegation that the murder was committed while Defendant was engaged in the commission of a robbery. The jury also found true the special circumstance allegation that Defendant was previously convicted of murder. The jury returned a verdict of death, and the trial court denied Defendant's ensuing motion for modification of his sentence. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant's right to self-representation in its rulings regarding Defendant's funding requests; (2) there was no error or abuse of discretion in the district court's evidentiary rulings; (3) Defendant's challenges to the special service allegations were unavailing; (4) there was no error in the jury instructions; (5) there was no error or abuse of discretion during the penalty phase; and (6) Defendant's challenges to the constitutionality of California's death penalty law failed. View "People v. Thomas" on Justia Law

The Supreme Court reversed Defendant's conviction for three counts of first degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request.Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless. View "People v. Waldon" on Justia Law

The Supreme Court held that a law enforcement officer's act of shining a spotlight for illumination does not ipso facto constitute a detention under the Fourth Amendment, but rather, the proper inquiry requires consideration of the totality of the circumstances, including the use of the spotlight.Defendant was charged with drug offenses after a law enforcement officer conducted a search of the car he was driving. At issue was whether the officer engaged in a consensual encounter when he pulled behind Defendant's car and turned on his spotlight. The court of appeal concluded that spotlight illumination and approach on foot did not "manifest a sufficient show of police authority to constitute a detention." The Supreme Court agreed, holding (1) under the totality of the circumstances, Defendant was not detained by the officer's use of a spotlight; and (2) remand was appropriate for a new factual finding as to whether the officer's detention of the vehicle's female passenger effectuated a detention of Defendant. View "People v. Tacardon" on Justia Law