Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of California
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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

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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

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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

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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

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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

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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

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and finding true the special circumstance allegations that the murder was committed while Defendant was engaged in the commission of rape and burglary and sentencing Defendant to death, holding that the errors committed during the trial proceedings were not prejudicial.Specifically, the Supreme Court held (1) assuming for the purposes of argument that a recording of the victim's last telephone call and testimony regarding DNA extraction should not have been admitted, any error was harmless; (2) assuming that portions of correspondence to Defendant were inadmissible hearsay, Defendant was not prejudiced by any error in the admission; (3) the prosecution committed misconduct by eliciting statements from a rebuttal witness during the penalty phase regarding the contents of one of those pieces of correspondence, but the trial court did not abuse its discretion in denying Defendant's related motion for a mistrial; and (4) the cumulative effect of those asserted errors was harmless. View "People v. Schultz" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeal concluding that the Governor acted lawfully when he concurred in the determination of the United States Secretary of the Interior (Interior Secretary) to allow casino-style gaming on tribal trust land in California, holding that California law empowers the Governor to concur.Under the Indian Gaming Regulatory Act, 25 U.S.C. 2701 et seq., the Interior Secretary may permit gaming on certain land taken into federal trust for an Indian tribe so long as the Governor of the state where the land is located concurs. At issue was whether the California Governor has the authority to concur in the Interior Secretary's determination to allow gaming on tribal trust land in California where the California Constitution has not granted explicit authority to concur in the cooperative-federalism scheme. The Supreme Court held that because the California Constitution, as amended in 2000, permits casino-style gaming under certain conditions on Indian and tribal lands and the Legislature imposed no restriction to the Governor's concurrence power, the Governor acted lawfully in concurring in the Interior Secretary's determination. View "United Auburn Indian Community of Auburn Rancheria v. Newsom" on Justia Law

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The Supreme Court overturned the death penalty for Scott Peterson, who, in 2002, was convicted of killing his wife, Laci Peterson, and the couple's unborn son, holding that the trial court made a series of clear and significant errors in jury selection that undermined Peterson's right to an impartial jury at the penalty phase.The Supreme Court affirmed the judgment as to guilt but reversed the judgment as to the sentence of death, holding (1) Defendant received a fair trial as to guilt; (2) the trial court erred by dismissing many prospective jurors because of written questionnaire responses expressing opposition to the death penalty, even though the jurors gave no indication that their views would prevent them from following the law; and (3) under United States Supreme Court precedent, these errors required reversal of the death sentence in this case. View "People v. Peterson" on Justia Law

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The Supreme Court affirmed the judgments of the of the trial court convicting Defendants of first degree murder and other crimes and sentencing both defendants to death, holding that no prejudice resulted from any error of the trial court.Separate juries convicted Daniel Silveria and John Travis of first degree murder, second degree robbery, and second degree burglary. After retrials, a single penalty jury returned death verdicts. The Supreme Court affirmed, holding (1) during the guilt phase, the trial court did not err in denying Travis's motion to suppress or in instructing the jury on first degree murder; and (2) during the joint penalty retrial, there was no abuse of discretion in denying Defendants' severance motions, the trial court did not wrongfully excuse for cause prospective jurors, the trial court did not err in admitting portions of Silveria's first penalty phase testimony, any error in placing conditions on proffered testimony by Travis's trial counsel was harmless, and any other assumed or actual error was not prejudicial. View "People v. Silveria" on Justia Law