Justia Civil Rights Opinion Summaries

Anthony Frank Romane, Jr. was arrested for driving under the influence after being found unconscious in his car. He exhibited signs of intoxication and failed field sobriety tests. At the police station, he refused to submit to a chemical test after being read the Chemical Test Admonition. The Department of Motor Vehicles (DMV) initiated proceedings to suspend his license for one year due to his refusal to submit to testing. Romane requested an Administrative Per Se (APS) hearing to challenge the suspension.The APS hearing was conducted by a single hearing officer, Trena Leota, who introduced three documents into evidence: the arresting officer’s sworn DS 367 form, the unsworn arrest report, and Romane’s driving record. Romane’s counsel objected, arguing that the hearing officer was acting as an advocate, violating due process as explained in California DUI Lawyers Association v. Department of Motor Vehicles. The hearing officer overruled the objections and admitted the documents. Romane’s bodyworn camera footage was also admitted into evidence. The hearing officer ultimately sustained the suspension of Romane’s license.Romane filed a petition for writ of administrative mandate in the Superior Court of San Diego County, arguing that his due process rights were violated because the hearing officer acted as both advocate and adjudicator. The superior court agreed and ordered the DMV to set aside the suspension unless a new hearing was conducted with separate individuals acting as advocate and adjudicator.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case and reversed the superior court’s decision. The appellate court held that the hearing officer did not act as an advocate but merely collected and developed evidence, which is constitutionally permissible. The case was remanded to the superior court to consider Romane’s contention that the evidence did not support the hearing officer’s findings. View "Romane v. Dept. of Motor Vehicles" on Justia Law

Matthew Morrison was convicted of a sexually violent offense and sentenced to prison. Before his release, the Santa Clara County District Attorney filed a petition to commit him as a sexually violent predator under the Sexually Violent Predator Act (SVPA). The trial court found the petition true, declared Morrison a sexually violent predator, and committed him to the State Department of State Hospitals for an indeterminate term.Morrison appealed, arguing that the trial court violated his constitutional rights by not personally advising him of his right to a jury trial and securing a personal waiver of that right. He claimed that the SVPA’s failure to require a personal jury trial advisement and waiver, unlike other civil commitment statutes, violated the constitutional equal protection guarantee.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court determined that Morrison’s equal protection challenge was subject to rational basis review. Since Morrison did not raise the issue in the trial court, the appellate court conditionally affirmed the commitment order and remanded the matter to allow Morrison to raise his equal protection claim before the trial court. The appellate court provided guidance on the principles the trial court should apply when resolving Morrison’s constitutional claim. View "P. v. Morrison" on Justia Law

L.H. pled no contest to first-degree murder and was committed to a secure youth treatment facility by the juvenile court. The court set his maximum term of confinement to 25 years to life or until he turns 25, whichever comes first, and applied 734 days of precommitment credits to this term. L.H. appealed, arguing that the court incorrectly applied Welfare and Institutions Code section 875 in setting his maximum term of confinement beyond his 25th birthday and erred in applying his precommitment credits against a theoretical maximum term of 25 years. He also claimed that equal protection principles require his precommitment credits to be applied against a term that does not exceed his 25th birthday.The juvenile court adjudged L.H. a ward of the court and committed him to Briones Youth Academy, Secure Pathway. The court determined that L.H.'s remaining custody time was 22 years and 361 days after applying the precommitment credits.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the juvenile court correctly applied section 875 in setting the maximum term of confinement. The court interpreted section 875, subdivision (c)(1)(A) as providing a separate cap on the length of a ward’s physical confinement, independent of the maximum term of confinement set by the juvenile court. The court also held that the juvenile court did not err in applying L.H.'s precommitment credits against the maximum term of confinement of 25 years, as required by section 875, subdivision (c)(1)(C). The court found no equal protection violation, as the application of precommitment credits was consistent with the statutory requirements.The Court of Appeal affirmed the juvenile court’s disposition order. View "In re L.H." on Justia Law

Robert Arthur McIntosh, a Black man, sought the appointment of counsel to assist him in prosecuting a petition for writ of habeas corpus in superior court, raising claims under the California Racial Justice Act (RJA). He alleged that the San Diego District Attorney’s Office charged gang and firearm enhancements more frequently against Black individuals and imposed longer sentences on them compared to similarly situated individuals of other races. McIntosh supported his claims with statistical data and reports. The trial court denied his request for counsel, stating he had not made the prima facie showing required for an order to show cause (OSC).The trial court ruled that section 1473(e) of the Penal Code required a prima facie showing of a violation for the appointment of counsel and issuance of an OSC. McIntosh then petitioned the California Court of Appeal, Fourth Appellate District, Division One, for a writ of habeas corpus. The appellate court issued an OSC limited to whether McIntosh was entitled to appointed counsel under section 1473(e).The California Court of Appeal, Fourth Appellate District, Division One, held that section 1473(e) imposes a duty on trial courts to assess the adequacy of the factual allegations in the habeas petition to determine if an indigent petitioner is entitled to appointed counsel, independent of the prima facie showing required for an OSC. The court found that the trial court erred by conflating these two inquiries. The appellate court exercised its discretion to construe McIntosh’s petition for writ of habeas corpus as a petition for writ of mandate and issued a writ directing the trial court to conduct the required inquiry to determine if McIntosh is entitled to appointed counsel. View "McIntosh v. Super. Ct." on Justia Law

Elijah Jackson, a Black man, was charged with carrying a loaded firearm after police found a handgun during a search of the car he was driving. Jackson filed a motion under the California Racial Justice Act of 2020, arguing that the police stopped and searched his car due to racial bias. The superior court denied Jackson’s motion, stating he failed to establish a prima facie violation under the Racial Justice Act.The superior court found that the police had observed Jackson driving with illegally tinted windows, followed him, and conducted a traffic stop. During the stop, officers noticed a baseball bat in the car and asked Jackson and his brother to exit the vehicle for a pat-down and search, which led to the discovery of the firearm. Jackson argued that the stop and search were racially motivated, supported by statistical evidence showing racial disparities in traffic stops and searches by the San Diego Police Department (SDPD).The California Court of Appeal, Fourth Appellate District, reviewed the case. The court noted that the Racial Justice Act aims to eliminate racial bias, including implicit bias, from the criminal justice system. The court found that Jackson had produced sufficient evidence, including statistical data and personal accounts of repeated stops by the same officers, to establish a substantial likelihood of implicit racial bias. The court concluded that Jackson met the prima facie standard for a violation of the Racial Justice Act and directed the superior court to hold an evidentiary hearing to consider Jackson’s motion.The Court of Appeal issued a writ of mandate, vacating the superior court’s denial of Jackson’s motion and ordering an evidentiary hearing to determine whether the stop and search were influenced by implicit racial bias. View "Jackson v. Superior Ct." on Justia Law

Plaintiff K.C. alleged that she was sexually abused while in foster care under the custody of the County of Merced. The abuse occurred in two separate foster homes between 1971 and 1977. K.C. claimed that she reported the abuse to her social worker, but no corrective action was taken, resulting in continued abuse. She filed a complaint citing negligent acts and omissions by the County and its employees, which she argued proximately caused her injuries.The Superior Court of Merced County sustained the County's demurrer without leave to amend, leading to the dismissal of K.C.'s complaint with prejudice. The court found that the County and its employees were protected by discretionary immunity under Government Code sections 815.2 and 820.2, which shield public employees and entities from liability for discretionary acts.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case and affirmed the lower court's judgment. The appellate court held that the social workers' decisions regarding the investigation of child abuse and the continuation of foster home placements were discretionary acts protected by immunity. The court emphasized that these decisions involved the exercise of judgment and policy considerations, which are shielded from liability to ensure that public employees can perform their duties without fear of civil suits. Consequently, the County was also immune from liability under the derivative immunity provided by Government Code section 815.2, subdivision (b). View "K.C. v. County of Merced" on Justia Law

A bakery, owned by Catharine Miller, refused to sell a predesigned, plain white cake to a same-sex couple, the Rodriguez-Del Rios, for their wedding reception. The bakery's policy prohibited the sale of any preordered cake for same-sex weddings based on Miller's religious beliefs that marriage is between a man and a woman. The couple ultimately obtained a similar cake from another bakery.The Civil Rights Department (CRD) filed a lawsuit against the bakery and Miller, alleging discrimination under the Unruh Civil Rights Act (UCRA). The Kern County Superior Court ruled in favor of the bakery, concluding there was no intentional discrimination and that Miller's referral of the couple to another bakery constituted full and equal access under the UCRA. The court also found that the bakery's refusal was protected by the First Amendment as both pure speech and expressive conduct.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court determined that the bakery's policy was facially discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court concluded that the trial court erred in its determination that the policy was facially neutral and in its application of the intentional discrimination standard. The court also found that Miller's referral to another bakery did not satisfy the UCRA's full and equal access requirement.Regarding the First Amendment defenses, the appellate court held that the plain white cake was not pure speech or expressive conduct protected by the First Amendment. The court reasoned that the cake was a generic, multi-purpose product and did not convey any particularized message about marriage. The court also upheld the UCRA's application under the federal and state Constitutions' free exercise clauses, concluding that the law is neutral and generally applicable and that there are no less restrictive means to achieve the state's compelling interest in ensuring full and equal access to goods and services irrespective of sexual orientation. The appellate court reversed the trial court's judgment and remanded the case for further proceedings. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

Elijah Jackson, a Black man, was charged with carrying a loaded firearm after police found a handgun during a search of the car he was driving. Jackson filed a motion under the California Racial Justice Act of 2020, arguing that the police stopped and searched his car due to racial bias. The superior court denied his motion, stating that Jackson failed to establish a prima facie violation under the Racial Justice Act.The superior court found that the police officers were conducting a saturation patrol in a high-crime area and stopped Jackson for having illegally tinted windows. The officers observed Jackson and his brother, who were wearing clothing associated with gang members, and conducted a traffic stop. During the stop, the officers found a baseball bat in the car and, after a search, discovered an unregistered loaded firearm. Jackson argued that the stop and search were racially motivated, supported by statistical evidence showing racial disparities in traffic stops and searches by the San Diego Police Department (SDPD).The Court of Appeal, Fourth Appellate District, reviewed the case and concluded that Jackson had produced facts that, if true, established a substantial likelihood of a violation of the Racial Justice Act. The court noted the statistical evidence showing racial disparities in SDPD's traffic stops and searches, as well as Jackson's and his brother's repeated stops for the same tinted windows without receiving citations. The court also considered the officers' focus on Jackson's and his brother's appearance and the neighborhood they were in, which suggested implicit bias.The Court of Appeal issued a writ of mandate directing the superior court to grant an evidentiary hearing to consider Jackson's motion under the Racial Justice Act. The court emphasized the importance of addressing implicit bias in the criminal justice system and ensuring that race does not play a role in seeking or obtaining convictions. View "Jackson v. Super. Ct." on Justia Law

David Paul Planchard was convicted by a jury of stalking Debra Doe and violating a protective order. Planchard and Doe had a relationship from 1997 to 2000 and had a son together in 2006. Despite a restraining order issued in 2020, Planchard continued to harass Doe through public Facebook posts from 2016 to 2023. These posts included threats, derogatory comments, and references to Doe's past trauma. Planchard also showed up at Doe's house in May 2023, violating the protective order.The Superior Court of Sacramento County found Planchard guilty of stalking and violating a protective order. The jury determined that Planchard's actions, including his Facebook posts and visit to Doe's house, constituted a credible threat and harassment. The court sentenced him to five years for stalking and a stayed term of six months for violating the protective order.The California Court of Appeal, Third Appellate District, reviewed the case. Planchard argued that his Facebook posts did not constitute direct contact and thus could not be considered harassment under the stalking statute. The court disagreed, citing precedent that indirect threats and harassment through third parties or public posts can still meet the statutory requirements for stalking. The court found sufficient evidence to support the jury's verdict, noting that the posts were intended to harass and threaten Doe, and it was reasonably foreseeable that she would see them.The court also addressed Planchard's claims of ineffective assistance of counsel, finding no merit in his arguments. The court concluded that the Facebook posts were relevant and admissible, and that any failure to object by his counsel did not constitute ineffective assistance. The judgment of the Superior Court was affirmed. View "P. v. Planchard" on Justia Law

The defendant, Aquil Qadir Lawson, was convicted of murder after shooting Madison Rose Weiss while she was in her car. Lawson, who is Black, argued that the trial court's evidentiary rulings were influenced by implicit racial bias, violating the California Racial Justice Act of 2020. He claimed that the court's decisions emphasized his criminality while minimizing the victim's, who was white. Specifically, Lawson contended that the exclusion of evidence regarding Weiss's illegal activities and the inclusion of his Instagram posts and fraud activities demonstrated racial bias.In the Superior Court of Los Angeles County, the jury found Lawson guilty of second-degree murder and the firearm allegation true. The court excluded evidence of Weiss's involvement in sex work, vaccination card fraud, and other illegal activities, deeming them irrelevant to the case. The court also excluded evidence of a gun found near the crime scene, as it was not connected to the shooting. Conversely, the court admitted Lawson's Instagram posts, which contained statements related to the shooting, and evidence of his involvement in fraud, which was used to impeach his credibility.The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that the trial court's evidentiary rulings were based on relevance and did not demonstrate implicit racial bias under the Racial Justice Act's preponderance-of-the-evidence standard. The appellate court found that the trial court's decisions were ordinary evidentiary rulings and that Lawson failed to show by a preponderance of the evidence that the rulings were motivated by racial bias or animus. Consequently, the appellate court affirmed the judgment of the Superior Court. View "P. v. Lawson" on Justia Law