Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of four counts of first degree murder and other crimes, holding that there was no error or abuse of discretion during the guilt phase or penalty phase of trial.Specifically, the Supreme Court held (1) the evidence was sufficient to show that Defendant committed the murders with premeditation and deliberation; (2) the trial court did not err in admitting testimony of the People's crime scene reconstruction expert; (3) the trial court did not abuse its discretion by admitting certain crime scene and autopsy photographs of the victims; and (4) during the penalty phase, the trial court did not err by admitting victim impact testimony or in instructing the jury. View "People v. Morales" on Justia Law

The Supreme Court held that the exemption in Cal. Const. art. II, 9, subd.(a) applies to measures setting municipal water rates, and therefore, municipal water rates and other local utility charges are not subject to referendum.To prevent the referendum process from disrupting essential governmental operations, the California Constitution exempts "statutes providing for tax levies or appropriations for usual current expenses" of the government. See Cal. Const. art. II, 9, subd.(a). After the City of Dunsmuir passed Resolution 2016-02 establishing a five-year plan for a $15 million upgrade to the City's water storage and delivery infrastructure Plaintiff submitted a petition for a referendum seeking to overturn the Resolution. The City declined to place the referendum on the ballot, and Plaintiff filed a petition for writ of mandate seeking to compel the City to place the referendum on the ballot. The trial court denied the petition. The Court of Appeal reversed, concluding that the exemption did not apply because the water charges were a "property-related fee" and not a "tax." The Supreme Court reversed, holding that the City's water rates, adopted in the Resolution, fall within the exemption for "tax levies" and therefore are not subject to referendum. View "Wilde v. City of Dunsmuir" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of first degree murder, attempted deliberate and premeditated murder, and other crimes, holding that Defendant's statements were improperly admitted in violation of Miranda v. Arizona, 384 U.S. 436 (1966) and Edwards v. Arizona, 451 U.S. 477 (1981), and the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued that his statements to police were taken in violation of his Fifth Amendment right to counsel. Specifically, Defendant argued that his unequivocal request for counsel was not honored. The Supreme Court agreed, holding (1) under Edwards, the officers were required to stop the interrogation once Defendant unequivocally requested counsel, but because the officers did not do so Defendant's statements were inadmissible as substantive evidence at trial; and (2) the erroneous admission of Defendant's statements was not harmless beyond a reasonable doubt as to any of the jury's findings. View "People v. Henderson" on Justia Law

The Supreme Court held that the California Public Employees' Pension Reform Act's (PEPRA), Stats. 2012, ch. 296, 1, amendment of the County Employees Retirement Law (CERL), Cal. Gov. Code 31450 et seq., did not violate the contract clause under a proper application of the California Rule and declined to reexamine and revise the California Rule.At issue was whether a provision of PEPRA amending CERL's definition of "compensation earnable," which affected the pensions of persons who were first employed by a county prior to the effective date of PEPRA, violated the contract clause. The Supreme Court held (1) county employees have no express contractual right to the calculation of their pension benefits in a manner inconsistent with the terms of the PEPRA amendment; (2) the challenged provisions added by PEPRA met contract clause requirements; and (3) the test announced in Allen v. City of Long Beach, 45 Cal.2d 128 (1955), as explained and applied in this case, remains the law of California. View "Alameda County Deputy Sheriff's Ass'n v. Alameda County Employees' Retirement Ass'n" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and other crimes and sentence of death, holding that there was no prejudicial error in the trial proceedings.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized during a warrantless probation search of his home; (2) the trial court did not abuse its discretion in denying Defendant's motion to sever the capital charges from his remaining charges; (3) the evidence was sufficient to support the convictions; (4) Defendant's challenges to the trial court's guilt phase instructions lacked merit; (5) a failure of consular notification under the Vienna Convention occurred in this case, but no prejudice resulted from it; (6) the trial court did not err in denying Defendant's motion to modify the verdict; and (7) Defendant's challenges to California's death penalty law were unavailing. View "People v. Vargas" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to modify the jury's verdicts of burglary and first degree murder, first degree forcible rape, second degree robbery and false imprisonment by violence and sentencing Defendant to death, holding that considering assumed errors altogether, reversal was not warranted.Defendant, an African-American, was charged with raping and murdering a White woman. On appeal, Defendant argued, among other things, that the prosecutor improperly exercise peremptory challenges to excuse two prospective jurors, who were African-American, in violation of Batson v. Kentucky, 476 U.S. 79, and People v. Wheeler, 22 Cal.3d 258, 276-277. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) substantial evidence supported the trial court's conclusion that the prosecutor struck the potential jurors for reasons other than his race; (2) there was no error in the trial court's decision to excuse two jurors for cause; (3) there was no merit to Defendant's allegations of error during the guilt phase; and (4) any assumed errors during the competency phase and penalty phase were not prejudicial and, considered cumulatively, did not require reversal. View "People v. Miles" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of first degree murder and his sentence of death, holding that the three or four minor errors at Defendant's trial were harmless and did not interfere with his due process right to a fair trial.Specifically, the Supreme Court held (1) no error occurred during jury selection; (2) Defendant was not prejudiced by any misstatements by the prosecutor; (3) assuming certain evidence was inadmissible, the court's admonition to the jury and the court's instruction cured the resultant harm; (4) the trial court erred in admitting testimony that the victim was afraid of Defendant, but the error was harmless; and (5) Defendant's remaining allegations of error were without merit. View "People v. Flores" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first degree murder and of conspiracy to commit murder and sentencing Defendant to death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the admission of Defendant's surreptitiously recorded jailhouse statement did not violate Defendant's Sixth Amendment right to counsel, his Fifth Amendment right to counsel and privilege against self-incrimination, his Fourth Amendment right to be free from unreasonable detention, his rights under the Sixth Amendment's confrontation clause, or attendant protections under Evidence Code sections 352 and 1101; (2) one instance of prosecutorial misconduct committed at the guilt phase was not prejudicial; and (3) Defendant was not entitled to relief on his remaining claims of guilt phase and penalty phase error. View "People v. Fayed" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that a defense counsel's failure to object at trial, before People v. Sanchez, 63 Cal.4th 665 (2016), was decided, forfeited a claim that a gang expert's testimony related case-specific hearsay in violation of the confrontation clause, holding that a defense counsel's failure to object under such circumstances does not forfeit a claim based on Sanchez.Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for her opinion unless the facts are independently proven or fall within a hearsay exception. Defendants in the instant case were each convicted of two counts of first degree special circumstance murder and other crimes. Before Defendants' appeals were resolved, the Supreme Court issued its opinion in Sanchez. On appeal, one of the defendants argued that a gang expert testified to case-specific hearsay in violation of the confrontation clause. The court of appeal held that the defendant's failure to object to case-specific hearsay in expert testimony at trial forfeited any Sanchez claim on appeal. The Supreme Court reversed, holding that the court of appeal erred in finding that the defendant forfeited his claim on appeal based on Sanchez by failing to object at a trial that occurred before Sanchez was decided. View "People v. Perez" on Justia Law

The Supreme Court granted Petitioner habeas corpus relief, holding that Petitioner was denied his constitutional right to the assistance of competent counsel at the guilt phase of his criminal trial, and trial counsel's deficient performance undermined the reliability of the jury's guilty verdict.Petitioner was convicted of the first degree murder of a police officer and sentenced to death. While his appeal was pending, Petitioner filed his first petition for a writ of habeas corpus, arguing that the judgment should be vacated because he had received constitutionally ineffective assistance of counsel. During the habeas proceedings, the Supreme Court found that Petitioner's trial counsel had defrauded Petitioner in order to induce Petitioner to retain him instead of the public defender. Counsel went on to commit serious errors during the penalty phase undermining the reliability of the death verdict. The Supreme Court granted the petition and ordered a new penalty phase trial. Petitioner later filed this petition for a writ of habeas corpus challenging his convictions. The Supreme Court granted the writ and vacated Defendant's conviction for first degree murder, holding that Petitioner was denied the effective assistance of counsel at the guilt phase of his trial. View "In re Gay" on Justia Law