Justia Civil Rights Opinion Summaries

The case centers on Taiwan Orran Reed, who was convicted by a jury in August 2020 of multiple offenses, including pimping, pandering, human trafficking, and rape involving two victims. The jury also found special circumstances under California’s one strike law, resulting in Reed’s sentence of 21 years four months in prison, plus 30 years to life. Reed, who is African American, later filed a petition for writ of habeas corpus in the Riverside County Superior Court, seeking relief under the California Racial Justice Act of 2020. He alleged that racially discriminatory language—specifically being referred to as a “gorilla pimp”—was used by the prosecutor and expert law enforcement witnesses during his trial.After Reed’s retained counsel withdrew due to personal reasons and lack of payment, the superior court appointed the Riverside County Public Defender to represent Reed at an evidentiary hearing on his habeas petition. The Public Defender objected to the appointment, arguing that under Government Code section 27706, subdivision (g), his office has discretionary authority to decline representation in postconviction habeas matters, unlike mandatory representation required in trial proceedings under subdivision (a). The trial court disagreed and compelled the Public Defender to accept the appointment, finding that the Public Defender had not demonstrated unavailability.The California Court of Appeal, Fourth Appellate District, Division Two, granted the Public Defender’s petition for writ of mandate. The appellate court held that section 27706(g) governs public defenders’ representation of habeas petitioners, granting them discretion to decline such appointments without a showing of unavailability. The trial court’s order compelling the Public Defender to represent Reed was vacated, and the superior court was directed to appoint alternate counsel for Reed’s habeas petition. View "Harmon v. Superior Ct." on Justia Law

Enrique Aguilar was involved in a shootout with San Diego Police Department officers after leading one officer on a foot chase during which he brandished a gun. Although Aguilar was wounded, none of the officers were hit, and a bullet fired from Aguilar’s direction struck a nearby store door. Aguilar was charged with multiple offenses, including attempted voluntary manslaughter, assaulting peace officers with a semiautomatic firearm, shooting at an occupied building, possessing methamphetamine while armed, and being a felon in possession of a firearm. At trial in September 2023, a jury convicted him of all charges and the court sentenced him to a lengthy prison term.During jury selection in the Superior Court of San Diego County, the prosecutor used a peremptory challenge to strike a Latina juror (Juror 1), claiming she struggled to understand the concept of intent, as revealed by her responses to a hypothetical question. Aguilar objected, arguing that the prosecutor was improperly excluding Hispanic and Latina jurors. The trial court accepted the prosecutor’s explanation, found Juror 1’s answers equivocal and overruled Aguilar’s objection, determining that ethnicity was not a factor in the challenge.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of Aguilar’s objection de novo, as required by Code of Civil Procedure section 231.7. The appellate court found no substantial evidence supporting the trial court’s finding that Juror 1 was confused about intent; her answers were clear and consistent. The court held that “juror confusion” is a presumptively invalid reason for a peremptory challenge under section 231.7, and that the prosecution failed to rebut this presumption. The judgment was reversed and the case remanded for a new trial. View "P. v. Aguilar" on Justia Law

An inmate serving an indeterminate sentence of 45 years to life for first degree murder challenged the calculation of the timing for his initial youth offender parole hearing. His main contention was that under California law, youth offenders like himself should be entitled to the same categories of prison conduct credits to advance their parole hearing date as are available to other indeterminately sentenced inmates. Specifically, he argued that the California Department of Corrections and Rehabilitation (CDCR) unfairly limited the use of credit categories for youth offenders, allowing only educational merit credits (EMCs) to count towards advancing the youth parole eligible date (YPED), while non-youth inmates could use a broader range of credits to accelerate their minimum eligible parole date (MEPD).The Marin County Superior Court previously denied his habeas petition. After the California Supreme Court granted review and transferred the case back to the California Court of Appeal, First Appellate District, Division Four, with instructions to issue an order to show cause, the matter was reconsidered. The focus of the appeal was whether the CDCR’s regulations violated statutory or constitutional rights by distinguishing between youth and non-youth offenders in the application of parole-advancing credits.The California Court of Appeal, First Appellate District, held that the CDCR’s distinction did not violate statutory or constitutional principles. The court found that the regulatory scheme giving only EMCs to youth offenders for YPED calculations, while affording more credit categories for MEPD calculations for other inmates, was rationally related to legitimate governmental objectives, including administrative efficiency and the structure of the youth parole scheme. The court also rejected due process and equal protection arguments, applying rational basis review, and concluded that the distinction was constitutionally permissible. The petition for habeas corpus relief was denied and the petition discharged. View "In re Thai" on Justia Law

A disabled individual, who uses a wheelchair, visited a toy store owned by a business entity in Los Angeles. He claimed that the sales counter was too high for him to use comfortably, allegedly deterring him from making a purchase. The individual subsequently filed lawsuits under both federal and state law, alleging violations of the Americans with Disabilities Act (ADA) and the Unruh Civil Rights Act. The federal court dismissed the ADA claim as moot after the store remedied the alleged violation, and the state court tried the Unruh Act claim. During trial, the plaintiff testified about his intent to shop and the difficulties encountered, but the store presented evidence that no such customer was seen and that employees would have greeted him.The Superior Court of Los Angeles County presided over the state Unruh Act action. The judge found the plaintiff's testimony not credible, determining that he entered the store solely to look for ADA violations rather than to shop, and did not suffer any difficulty or denial of access. Judgment was entered for the store, and the plaintiff did not appeal. The store then filed a malicious prosecution action against the plaintiff and his attorneys, alleging they pursued claims knowing essential facts refuted their allegations. The defendants moved for summary judgment, arguing they had probable cause and acted without malice. The trial court granted summary judgment for all defendants, declining to apply issue preclusion to the prior judge’s factual findings.Upon appeal, the Court of Appeal of the State of California, Second Appellate District, Division Three, held that the prior judge’s findings regarding the plaintiff’s intentions and actions were entitled to preclusive effect and sufficient to raise triable issues of fact about probable cause and malice as to the plaintiff. However, the appellate court found no similar evidence against the attorneys, as they relied on information provided by the plaintiff. The judgment was reversed as to the plaintiff and affirmed as to the attorneys. View "Landis' Labyrinth v. Whitaker" on Justia Law

The defendant was originally convicted in 2011 of felony possession of child pornography, which required him to register as a sex offender. In 2015, he was convicted of failing to register a change of address, an offense classified as a felony because his registration requirement was based on his prior felony conviction. Years later, after his child pornography conviction was reduced to a misdemeanor and dismissed, he sought to have his 2015 failure to register conviction likewise reduced to a misdemeanor and dismissed, citing his rehabilitation, lack of subsequent offenses, and support from family and associates.The Santa Cruz County Superior Court had previously granted the defendant’s motion to reduce his 2011 conviction to a misdemeanor and dismissed that case. However, when the defendant petitioned to reduce and dismiss his 2015 felony registration offense, the court denied the motion, finding that the offense was a straight felony, not a wobbler, and that it was not appropriate to dismiss the case. The defendant appealed, arguing that the later reduction of his underlying offense should retroactively affect the status of his 2015 conviction, or that the court should have exercised discretion to reduce or dismiss it in the interest of justice.The California Court of Appeal, Sixth Appellate District, affirmed the trial court’s order. The court held that the 2015 failure to register conviction was a straight felony under Penal Code section 290.018(b), and not subject to reduction under Penal Code section 17(b), which only applies to wobblers. The reduction of the underlying 2011 offense did not retroactively convert the 2015 conviction to a misdemeanor. The court also found no substantive due process violation, as the legislative scheme had a rational basis. Finally, the court found no abuse of discretion in denying dismissal under Penal Code section 1203.4. View "People v. Woodward" on Justia Law

A man was charged with illegal possession of ammunition after police stopped a car in which he was a passenger late at night, citing a non-functioning license plate light and tinted windows. During the stop, officers asked both occupants if they were on parole or probation, ordered them out of the vehicle, and conducted pat searches, citing low lighting and baggy clothing as reasons. A search of a backpack near the passenger seat revealed ammunition and documents with the passenger’s name. The passenger, who had prior felony convictions, was arrested. During the encounter, officers used slang and whistled at both the passenger and two Latino men passing by.The Santa Clara County Superior Court initially denied the passenger’s motion under the California Racial Justice Act (RJA), finding he had not made a prima facie showing that the officers’ actions were motivated by racial bias. After the California Court of Appeal issued an alternative writ requiring reconsideration and a detailed ruling on all claims, the trial court again denied the motion, concluding that the allegations were conclusory or unsupported.The California Court of Appeal, Sixth Appellate District, reviewed the case de novo and held that the passenger had made a prima facie showing under the RJA. The court found that, when considering the totality of the facts—including expert testimony, statistical evidence, and the officers’ language and conduct—there was a substantial likelihood that law enforcement exhibited bias based on race, ethnicity, or national origin. The court clarified that at the prima facie stage, the trial court should not weigh evidence or make credibility determinations, but should accept the truth of the movant’s factual allegations unless they are conclusory or contradicted by the record. The appellate court issued a writ directing the trial court to hold an evidentiary hearing on the RJA motion. View "Hernandez v. Superior Court" on Justia Law

A Black man was charged with multiple offenses, including felony false imprisonment, after a domestic violence incident in which his girlfriend alleged he struck her and prevented her from leaving his car. Witnesses observed the girlfriend attempting to exit the moving vehicle and heard shouting. The girlfriend initially told police that the defendant hit her and threatened her if she tried to leave, but later recanted, claiming she fabricated the story out of anger. The prosecution introduced both her initial statements and her recantation at trial. The jury found the defendant guilty of felony false imprisonment and other related charges, but acquitted him of attempted robbery. He admitted a prior conviction, and the trial court imposed a total sentence of nine years and four months, including time for an unrelated prior case.During trial, the defendant’s counsel raised concerns under the California Racial Justice Act (RJA) regarding the racial composition of the jury venire and the prosecution’s peremptory challenge of a Black prospective juror. The Santa Clara County Superior Court denied these motions, finding no evidence of bias or violation of the RJA. At sentencing, the court made comments referencing the defendant’s race and background, but defense counsel did not object to these statements under the RJA.The California Court of Appeal, Sixth Appellate District, reviewed the case. It held that the defendant forfeited his RJA claims on appeal by failing to object to the trial court’s statements at the appropriate time. The court also found no merit in the claim of ineffective assistance of counsel, as there was a conceivable tactical reason for not objecting. Additionally, the appellate court determined that the trial court did not err in failing to instruct the jury on misdemeanor false imprisonment, as there was no substantial evidence to support that lesser offense. The judgment of conviction and sentence was affirmed. View "People v. Wagstaff" on Justia Law

Shawn Otis Hernandez was convicted by a jury of conspiracy to commit first degree residential burglary and attempted first degree residential burglary, following an incident in which multiple individuals attempted to break into a home late at night. Evidence against Hernandez included cell phone records, home security video, DNA analysis, and a prior conviction for a similar crime. During jury selection, the prosecution exercised several peremptory challenges against jurors under the age of 25, prompting Hernandez to object on the basis that these challenges were discriminatory.The Ventura County Superior Court reviewed Hernandez’s objection under Code of Civil Procedure section 231.7, which prohibits discrimination in jury selection based on certain protected categories. The trial court found that the prosecution’s reasons for excusing the young jurors were valid and supported by the record, and that age was not a substantial factor in the use of peremptory challenges. The court also noted that neither party raised objections based on ethnicity or gender during trial, and that the empaneled jury included several males and individuals with Spanish surnames.The California Court of Appeal, Second Appellate District, Division Six, affirmed the judgment. The court held that youth alone is not a cognizable group under section 231.7, and neither Batson v. Kentucky nor Wheeler prohibits excusing jurors solely based on youth. The court further held that objections to the dismissal of jurors based on protected class membership under section 231.7 must be made in the trial court, or the claim is forfeited on appeal. Hernandez’s claims regarding ethnicity and gender were deemed forfeited, and his ineffective assistance of counsel claim was rejected due to lack of deficient performance and prejudice. The judgment was affirmed. View "People v. Hernandez" on Justia Law

A man was charged in 2002 with multiple sexual offenses involving three minor males. In 2003, he entered a plea agreement, pleading no contest to several counts of committing lewd acts on children aged 14 or 15 and one count of oral copulation with a victim under 16, which was amended from a charge of forcible oral copulation to a nonforcible offense. He did not admit to using force or violence in his plea, but the factual basis for the plea referenced police reports describing acts involving force. He was sentenced to state prison in accordance with the plea agreement.In 2005, two psychologists evaluated him for commitment as a Mentally Disordered Offender (MDO) under California Penal Code section 2962. A chief forensic psychiatrist certified that he met the criteria, including having committed a crime involving force or violence, based on documentary evidence such as probation and police reports. The Board of Parole Hearings affirmed the certification. He did not challenge the certification in superior court at that time. He remained in custody under annual recommitment petitions, and his only prior challenge was an unsuccessful appeal of a 2022 recommitment order.After that, he filed a habeas corpus petition in Fresno County Superior Court in 2023, arguing that his conviction did not qualify as an MDO offense and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is a proper vehicle to challenge an initial MDO certification based on static factors, even years later. The court found that the evidence was sufficient under the law at the time of certification, and that subsequent changes in evidentiary standards were not retroactive. The court also found no ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

A county public guardian filed a petition in February 2023 to establish a conservatorship over an individual, A.H., under the Lanterman-Petris-Short (LPS) Act, alleging grave disability due to mental disorder. The trial court imposed a temporary conservatorship, which was extended as A.H. demanded a trial. However, the trial did not begin within the statutory 10-day period and was repeatedly continued, often due to court and counsel unavailability. While the first petition was still pending and as the initial temporary conservatorship was expiring, the public guardian filed a second petition and obtained a new temporary conservatorship, further extending A.H.’s involuntary confinement. A.H. opposed the continuances and requested dismissal of both petitions, but the court denied these requests. The first petition was eventually dismissed at the public guardian’s request, and trial on the second petition began about ten weeks after the statutory deadline. In January 2024, the court found A.H. gravely disabled and ordered a one-year conservatorship, which was not renewed after expiration.The Superior Court of Contra Costa County presided over the initial proceedings, including the imposition of temporary conservatorships, the granting of continuances, and the eventual trial and conservatorship order. A.H. appealed, arguing that statutory amendments required dismissal for untimely trial, that the court abused its discretion in granting continuances, and that the delays violated his due process rights.The California Court of Appeal, First Appellate District, Division Five, held that the statutory amendment to section 5350, subdivision (d)(2), does not mandate dismissal for untimely trial but gives the court discretion. The court found no reversible error in the continuances or denial of dismissal under the statute. However, the appellate court concluded that the cumulative 10-month delay in adjudicating the conservatorship petitions, none of which was attributable to A.H., violated his due process rights. The order of conservatorship was therefore reversed. View "In re Conservatorship of A.H." on Justia Law