Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of the murders of four young men during the robbery of a car wash and his sentence of death, holding that there was no merit to any of Defendant's claims.Specifically, the Supreme Court held (1) the trial court did not err by denying a motion to suppress two witnesses' identifications of Defendant; (2) Defendant's Sixth Amendment right to confrontation was not violated by the trial court's admission of certain testimony; (3) the trial court did not err by failing to instruct the jury on the lesser-included offense of unpremeditated second-degree murder, and there was no other instructional error; (4) Defendant's claims of trial error in the admission of allegedly prejudicial hearsay were without merit; (5) the trial court's denial of Defendant's new trial motion was not erroneous; (6) the trial court did not abuse its discretion by failing to investigate certain allegations raised by Defendant; and (7) Defendant's objections to the constitutionality of California's death penalty scheme were unavailing. View "People v. Wilson" on Justia Law

The Supreme Court held that when the court-appointed attorneys of parents in termination proceedings have failed to timely file a notice of appeal of an order terminating parental rights, parents whose rights have been terminated may seek relief based on the attorney's failure to provide competent representation.After M.B.'s parental rights to her child were terminated, M.B. timely asked her new court-appointed counsel to file an appeal. The attorney, however, did not file an appeal until after the sixty-day filing deadline had passed. The court of appeal dismissed the appeal as untimely. The Supreme Court reversed, holding (1) every parent facing the termination of parental rights is entitled to the assistance of competent counsel; and (2) when an attorney fails to file a timely appeal in accordance with his or her client's instructions, the parent may seek relief based on the denial of the statutory right to the assurance of competent counsel. View "In re A.R." on Justia Law

The Supreme Court affirmed the judgment of the court of appeal concluding that Petitioner was entitled to a new bail hearing, holding that the common practice of conditioning freedom solely on whether an arrestee can afford bail is unconstitutional.The trial court set Petitioner's bail at $350,000 without commenting on Petitioner's inability to afford bail. Petitioner filed a petition for writ of habeas corpus claiming that requiring money bail as a condition of release at an amount he could not pay was the functional equivalent of a pretrial detention order and requesting immediate release or a new bail hearing. The court of appeals reversed the bail order because the trial court failed to determine whether Petitioner could feasibly post bail. On remand, the superior court conducted a new bail hearing and ordered Petitioner released on various non-financial conditions. The Supreme Court affirmed, holding (1) where a financial condition is necessary, the court must consider the arrestee's ability to pay the stated amount of bail and may not detain the arrestee solely because the arrestee lacked the resources to post bail; and (2) Petitioner was entitled to a new bail hearing. View "In re Humphrey" on Justia Law

The Supreme Court upheld Senate Bill 1391 as a permissible amendment to Proposition 57 and reversed the judgment in the case, holding that the Legislature acted within its authority.Proposition 57, which was passed in the November 2016 general election, allowed prosecutors to move to transfer some minors as young as fourteen years old from juvenile court to adult criminal court. Senate Bill 1391, enacted in 2018, amended Proposition 57 to prohibit minors under the age of sixteen from being transferred to adult criminal court. The court of appeal held that Senate Bill 1391 was invalid because it was inconsistent with Proposition 57. The Supreme Court reversed, holding that the amendment was fully consistent with and furthered Proposition 57's purposes of promoting rehabilitation of youthful offenders and reducing the prison population, and therefore, Senate Bill 1391 was a constitutional amendment to Proposition 57. View "O.G. v. Superior Court" on Justia Law

The Supreme Court affirmed Defendant's conviction for five counts of murder, one count of residential burglary, and three counts of residential robbery with enhancements for personal use of a firearm and Defendant's death sentence, holding that there was no reasonable possibility that any assumed error could have affected the verdict.Specifically, the Supreme Court assumed potential errors in the trial court's failure to admonish support persons each time they accompanied a witness and in admitting hearsay during the penalty phase of trial. The Court, however, found no reasonable possibility that either assumed error could have affected the verdict. The Court further concluded that no cumulative prejudice rendered Defendant's trial unfair and therefore affirmed Defendant's convictions and his sentence of death. View "People v. Chhoun" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and sentence of death, holding that any errors, found or assumed, were not prejudicial.Specifically, the Supreme Court held (1) at the guilt phase, assuming that the trial court erred in admitting certain DNA evidence, the error was not prejudicial; (2) at the penalty phase, assuming the trial court erred in admitting evidence of potential animal abuse, the error was not prejudicial; (3) any error in imposing a parole revocation fine was harmless; (4) even when viewed in combination, the guilt phase and penalty phase errors were not prejudicial; and (5) the abstract of judgment reflected a clerical error, which will be corrected. View "People v. Baker" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder, attempted murder, and other offenses, and sentencing Defendant to death, holding that any errors that occurred during the trial proceedings were not prejudicial.Specifically, the Supreme Court held (1) during the guilt phase, there was error with respect to the prosecutor's misstatement of the reasonable doubt standard and with respect to defense counsel's agreement with the prosecutor on a certain point of law, but there was no reasonable probability that the prosecutor's or defense counsel's misstatements were prejudicial; (2) at the penalty phase, the prosecutor's comment about Defendant during penalty phase arguments bordered on "inflammatory" rhetoric, but any error was not prejudicial; and (3) the cumulative effect of these errors did not rise to the level of prejudice necessary to reverse Defendant's conviction or sentence. View "People v. Johnsen" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and sentence of death, holding that there was no prejudicial error in the trial proceedings.Defendant was convicted of the first degree murder of San Leandro Police Officer Nels Niemi. The jury returned a verdict of death, and the trial court sentenced Defendant accordingly. The court also ordered Defendant to pay a restitution fine of $10,000. The Supreme Court affirmed, holding (1) there was no error in the guilt phase of the proceedings; (2) there was no cumulative effect of any purported errors occurring at the penalty phase; and (3) the trial court did not violate any statutory or constitutional law by imposing restitution. View "People v. Ramirez" on Justia Law

The Supreme Court reversed Defendant's conviction of fetal murder and affirmed his convictions of ten counts of murder, holding that hearsay was improperly admitted on the question of fetal viability.Defendant was convicted of murdering ten women and one viable fetus and sentenced to death. The primary issues on appeal were whether the trial court erred in admitting statistical evidence about the significance of DNA matches and in admitting hearsay testimony about the fetus's viability. The Supreme Court reversed the fetal murder conviction and otherwise affirmed, holding (1) the challenged testimony admitted in this case was hearsay, and the error in admitting the testimony was prejudicial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Turner" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder, conspiracy to commit murder and grand theft, mingling a harmful substance with food or drink, and solicitation to commit murder, and sentence of death, holding that any error was not prejudicial.Specifically, the Supreme Court held (1) Defendant's judicial bias claim failed; (2) the erroneous admission of certain statements and the possibly erroneous admission of a certain letter were cumulatively harmless; (3) there was sufficient evidence for the lying-in-wait special circumstance finding and the lying-in-wait first degree murder conviction; (4) any asserted juror misconduct did not, singly or in combination, substantially prejudice the trial's fairness; (5) the trial court did not err in finding that Defendant was competent to stand trial; and (6) Defendant's challenges to the constitutionality of California's Death Penalty Law were unavailing. View "People v. Flinner" on Justia Law