Justia Civil Rights Opinion Summaries

Brandon Duane Wagstaff was convicted by a jury of felony false imprisonment and related offenses stemming from a domestic violence incident. The trial court sentenced him to 16 months in prison. Wagstaff, who is Black, claimed that the trial court violated the California Racial Justice Act of 2020 (RJA) during various stages of the proceedings. However, his trial counsel did not object to these statements under the RJA, leading to the forfeiture of these claims on appeal. Wagstaff also argued that his trial counsel was ineffective for not objecting to a specific statement made by the trial court at sentencing, but the appellate court found this claim to be without merit.In the lower court, the prosecution charged Wagstaff with five counts, including felony false imprisonment, attempted second-degree robbery, contempt of court, threatening to commit a crime, and battery upon a person in a dating relationship. The jury found him guilty on four counts but acquitted him of attempted robbery. Wagstaff admitted to a prior conviction, and the trial court imposed an aggregate sentence of nine years and four months, including a term from a separate case.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that Wagstaff's claims under the RJA were forfeited due to the lack of objections by his trial counsel. The court also concluded that the trial court's failure to instruct the jury on misdemeanor false imprisonment as a lesser included offense was not erroneous because there was no substantial evidence to support such an instruction. The appellate court affirmed the judgment, finding no merit in Wagstaff's claims. View "P. v. Wagstaff" on Justia Law

Gregory Wilson was convicted by a jury of multiple charges, including human trafficking of a minor by force or fear, human trafficking to commit another crime, kidnapping, and criminal threats. He was sentenced to an aggregate determinate term of 31 years and eight months, followed by an indeterminate term of 30 years to life. Wilson appealed, arguing that his defense counsel was ineffective for not objecting to the prosecutor's use of the term "gorilla pimp" during closing arguments, which he claimed violated the Racial Justice Act (RJA).The trial court had found Wilson guilty based on substantial evidence, including testimonies from victims B.W., K.W., and B.C., who described being forced into prostitution through violence and threats. The jury found Wilson not guilty of rape and forcible oral copulation but convicted him on other charges. The trial court sentenced him accordingly.The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that defense counsel was not ineffective as a matter of law for failing to object to the prosecutor's use of the term "gorilla pimp." The court reasoned that the term is a recognized term of art in the sex trafficking subculture, describing a pimp who uses force and violence. The court also noted that the issue of ineffective counsel should be resolved in a habeas corpus proceeding, where defense counsel can explain their conduct.The appellate court affirmed the trial court's judgment, finding substantial evidence supporting Wilson's convictions for human trafficking and kidnapping. The court also rejected Wilson's claims regarding sentencing, including the argument that the trial court abused its discretion and violated section 654's prohibition against multiple punishments. View "People v. Wilson" on Justia Law

In June 2018, Leslie Davies and volunteers from the Animal Protection and Rescue League, Inc. protested against a pet store in a Temecula shopping mall, alleging the store sourced dogs from puppy mills. They were asked by mall officials to move their protest due to a table reservation conflict. When Davies refused, Riverside Sheriff’s Deputy Rudy Leso threatened her with arrest if she did not comply. Davies requested a citation instead, but Leso insisted on arrest. Consequently, Davies and the volunteers left the area.The plaintiffs, Davies and the League, filed a lawsuit against the County of Riverside and Deputy Leso in August 2019. The Superior Court of Riverside County sustained demurrers without leave to amend for several causes of action, including negligence, Bane Act, and Ralph Act claims. The court also granted summary judgment in favor of the defendants on the remaining cause of action for declaratory relief.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court affirmed the lower court’s decisions, finding no error. It held that Davies’s negligence claim failed because she did not allege physical injury or a breach of duty. The Ralph Act claim was dismissed as the threat of arrest did not constitute violence. The Bane Act claim was also dismissed because the threat of arrest alone did not amount to coercion or intimidation. Lastly, the court upheld the summary judgment on the declaratory relief claim, noting there was no actual controversy since the County agreed that mall rules are not laws and cannot provide probable cause for arrest. The appellate court affirmed the judgment in favor of the County and Deputy Leso. View "Animal Protection and Rescue v. County of Riverside" on Justia Law

Robert Schneider, charged with murder, filed a discovery motion under Pitchess v. Superior Court and Brady v. Maryland, seeking Brady information from the confidential personnel records of six deputies with the Los Angeles County Sheriff’s Department (LASD). The trial court found good cause for an in camera review and determined that four of the six deputies' files contained Brady material. However, the court only ordered the disclosure of the names, addresses, and phone numbers of individuals who had witnessed or complained about the conduct, not the Brady material itself.Schneider petitioned for a writ of mandate, challenging the limited disclosure. The Court of Appeal of the State of California, Second Appellate District, Division Seven, reviewed the case. The court concluded that the trial court should have ordered LASD to disclose all Brady material in the four deputies’ personnel files, including documents and any audio-video materials.The Court of Appeal held that while the Pitchess procedures must be followed to obtain Brady information in officers’ confidential personnel files, the limitations on disclosure under Pitchess do not apply to Brady material. The court emphasized that Brady material must be fully disclosed, including any relevant complaints, reports, or audio-visual evidence, to ensure the defendant's right to a fair trial. The petition was granted, directing the trial court to vacate its previous order and conduct a further in camera review to identify and produce all Brady material to Schneider’s counsel. View "Schneider v. Superior Court" on Justia Law

Petitioner Jayden Demarko McDaniel, a Black individual, was charged with multiple felonies, including attempted first-degree murder and gang-related offenses. McDaniel alleged that he was disparately charged with gang enhancements due to his race, in violation of the California Racial Justice Act of 2020 (RJA). He sought discovery of evidence from the prosecution to support his claim, arguing that statistical evidence indicated a racial disparity in the application of gang enhancements in San Mateo County.The San Mateo County Superior Court denied McDaniel's motion for discovery, concluding that he failed to demonstrate "good cause" as required by the RJA. The court found that McDaniel's statistical evidence lacked context and did not provide specific facts about his case or other similar cases involving non-Black defendants. McDaniel then filed a petition for writ of mandate with the Court of Appeal, which was initially denied without prejudice. He subsequently refiled his petition, which was again denied by the superior court.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and concluded that McDaniel had met the low threshold for demonstrating good cause for discovery under the RJA. The court held that McDaniel's county-specific statistical evidence, supported by an expert declaration, presented a plausible factual foundation for his claim of racial bias in charging decisions. The court emphasized that the RJA's discovery standard is intended to be broad and flexible, allowing for various types of evidence, including statistical data, to support a claim of racial disparity.The Court of Appeal vacated the trial court's order and remanded the case for a new hearing to reconsider McDaniel's discovery motion, directing the trial court to weigh the potential probative value of the requested information against the burdens of gathering it. View "McDaniel v. Superior Court" on Justia Law

A mother was shot and killed by a deputy sheriff while her young children watched. The mother, who had been acting erratically and wielding a knife, advanced towards the deputies despite repeated requests to drop the weapon. The lead deputy fired his service pistol after a backup deputy's taser failed to stop her. The children, through their guardian ad litem, sued the deputies and Nevada County, claiming the use of force was unreasonable.The trial court ruled that the lead deputy acted reasonably and granted summary judgment in his favor, but allowed the claims against the backup deputy to proceed, finding that a reasonable juror could conclude his actions were unreasonable. The backup deputy and the County petitioned for a writ of mandate, arguing that the trial court should have granted their summary judgment motion as well.The California Court of Appeal, Third Appellate District, reviewed the case. The court emphasized the need to assess reasonableness from the perspective of a reasonable officer at the scene, considering the split-second decisions officers must make. The court concluded that the backup deputy acted reasonably as a matter of law, noting that the mother advanced towards the deputies with a deadly weapon and that the backup deputy's use of a taser was a reasonable response under the circumstances.The court issued a writ of mandate directing the trial court to set aside its partial denial of the summary judgment motion and to enter a new order granting the motion in its entirety, thus ruling in favor of the backup deputy and the County. View "County of Nevada v. Super. Ct." on Justia Law

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