Justia Civil Rights Opinion Summaries

Tam Steven Nguyen committed various crimes at the age of 22 and was convicted in 2003 of attempted murder, kidnapping, and assault with a firearm. He was sentenced to a determinate term of 14 years, an indeterminate term of 25 years to life, and a life term with the possibility of parole. While incarcerated, Nguyen earned various credits, including good conduct and educational merit credits. These credits were applied to his minimum eligible parole date (MEPD) and youth parole eligible date (YPED), respectively.Nguyen petitioned the trial court for a writ of habeas corpus in 2022, arguing that he should be able to use all types of credits to advance his YPED, not just educational merit credit. The trial court denied his petition. Nguyen then petitioned the California Court of Appeal, which summarily denied the petition. The California Supreme Court granted review, ordered the appellate court to vacate its order, and issued an order to show cause.The California Court of Appeal reviewed the case and held that Nguyen's right to equal protection was not violated. The court found that youth and nonyouth offenders are not similarly situated for the purposes of the challenged regulations, as youth offenders have two parole eligibility dates (MEPD and YPED) while nonyouth offenders have only one (MEPD). The court also determined that there is a rational basis for the regulation that limits the types of credits that can advance a youth offender's YPED, as it aligns with the legislative intent to provide a fixed and relatively stable parole eligibility date for youth offenders. Consequently, the court denied Nguyen's petition for writ of habeas corpus. View "In re Nguyen" on Justia Law

Plaintiffs Antonio Juarez, Jose Hinojosa, Jose Espinosa, and Maria Morfin filed a lawsuit against the San Bernardino City Unified School District following an incident involving Officer Alejandro Brown, a District employee. In February 2018, Juarez found a cell phone and later, Officer Brown, tracking his phone, confronted the plaintiffs, identifying himself as a District police officer. Brown, armed and displaying his badge, demanded compliance, struck Juarez with his firearm, and threatened the others. Brown later pled guilty to assault and battery and threatening the plaintiffs under color of law.The Superior Court of Riverside County sustained the District’s demurrer to the plaintiffs’ second amended complaint without leave to amend, leading to the dismissal of the case. The court found the complaint insufficient to establish that Officer Brown was acting within the scope of his employment with the District and dismissed the claims of negligence, battery, assault, negligent hiring, supervision, and retention, false arrest and imprisonment, intentional and negligent infliction of emotional distress, and violation of the Bane Act.The Court of Appeal, Fourth Appellate District, Division One, State of California, reversed and remanded the case. The appellate court held that the scope of employment is a factual issue that cannot be resolved as a matter of law on demurrer. The court found that Officer Brown’s off-duty misconduct, while investigating a suspected theft and wielding his authority as a peace officer, could be regarded as an outgrowth of his employment. The court directed the trial court to vacate its order sustaining the demurrer, enter a new order overruling the demurrer, and conduct further proceedings. The appellate court also rejected the District’s arguments regarding the Bane Act and found the plaintiffs’ allegations sufficient to state a cause of action for negligent hiring, supervision, and retention. View "Juarez v. San Bernardino City Unified Sch. Dist." on Justia Law

James Lamont Bagsby was convicted and sentenced to 107 years to life for violent crimes committed at age 15. After serving over 15 years, he petitioned for recall and resentencing under Penal Code section 1170(d), which applies to juveniles sentenced to life without parole. Bagsby argued his sentence was the functional equivalent of life without parole, citing People v. Heard, which held that denying such juveniles the opportunity to petition for resentencing violates equal protection. The trial court agreed, granted his petition, and ordered his release, but stayed the release pending appeal.The People appealed, asking the Court of Appeal to strike down the section 1170(d) resentencing provision or reconsider Heard. They also contended the trial court had jurisdiction to resentence Bagsby and erred by ordering his release. Bagsby cross-appealed the stay order.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court's orders. The court upheld Heard, finding no compelling reason to overturn it. The court rejected the People's arguments, noting that the Legislature had not repealed section 1170(d) despite amendments and that the trial court correctly applied Proposition 57 and Senate Bill 1391 retroactively, making Bagsby's judgment nonfinal and outside juvenile court jurisdiction. The court also found the stay order would expire upon remittitur, making Bagsby's release effective as of the original release date for custody credit purposes. View "P. v. Bagsby" on Justia Law

Robert Mann, a taxpayer, filed a lawsuit against the State of California and the California Highway Patrol (CHP), challenging CHP’s vehicle impound policies. Mann argued that the impoundment of vehicles without a warrant and inadequate notice procedures constituted illegal expenditures of public funds. He sought declaratory and injunctive relief to prevent what he characterized as wasteful, unlawful, and unconstitutional law enforcement policies. The trial court granted a permanent injunction requiring CHP to consider vehicle owners’ ability to pay towing and storage fees during impound hearings and vehicle release procedures, and to revise its notice form to advise owners of procedures for retrieving impounded vehicles.The Superior Court of Los Angeles County initially reviewed the case. At the close of the plaintiffs’ case, the trial court granted a motion for judgment against Youth Justice Coalition and entered judgment in favor of defendant Warren A. Stanley, who had retired before the trial. The court found that Stanley, as a former public officer, was no longer a proper defendant. The trial court issued a permanent injunction requiring CHP to revise its vehicle impound procedures, including considering the ability to pay and revising notice forms.The Court of Appeal of the State of California, Second Appellate District, Division Two, reviewed the case. The court reversed the trial court’s judgment, holding that the injunction improperly required CHP to contravene valid statutes, relied on inapplicable case law, conflicted with the existing statutory scheme, and mandated unnecessary revisions to its notice procedures. The appellate court concluded that the trial court erred in requiring CHP to conduct ability-to-pay hearings and revise its notice forms, as these requirements were not mandated by due process and conflicted with statutory provisions. The judgment was reversed, and costs on appeal were awarded to the appellant. View "Mann v. State" on Justia Law

The defendant, Eliseo Martinez, restrained Nicasio Calixto Pascual while his cousin, Valente Martinez, stabbed Calixto 18 times. During an interview with detectives, Martinez admitted his participation in the stabbing. Martinez claimed the trial court improperly denied an instruction on voluntary manslaughter based on heat of passion, arguing it was not supported by the evidence and was prohibited under Penal Code section 192, subdivision (f)(1) due to the victim’s sexual orientation. Martinez also contended that his constitutional and statutory rights were violated when the court found him voluntarily absent from the trial.The Superior Court of Los Angeles County found Martinez guilty of attempted murder and determined several aggravating circumstances, including that the crime was a hate crime. Martinez was sentenced to 23 years in state prison. Martinez appealed, arguing the trial court erred in not instructing the jury on attempted voluntary manslaughter and in proceeding with the trial in his absence.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. The court held that the trial court correctly denied the instruction on voluntary manslaughter because there was no substantial evidence that Martinez acted in the heat of passion due to sufficient provocation. The court also found that Penal Code section 192, subdivision (f)(1) rendered any provocation related to the victim’s sexual orientation objectively unreasonable. Additionally, the court determined that substantial evidence supported the trial court’s finding that Martinez voluntarily absented himself from the trial, and thus, his right to be present was not violated. The judgment of the lower court was affirmed. View "P. v. Martinez" on Justia Law

Enrique Sanchez, the petitioner, sought a writ of mandate to vacate a trial court order that directed the San Bernardino County Public Defender to assign a new attorney to represent him. This order was issued after the current deputy public defender made remarks during plea negotiations that invoked Sanchez's race, potentially violating the Racial Justice Act (RJA). Sanchez argued that the trial court abused its discretion in ordering the reassignment.The trial court received a motion from the prosecutor to disclose exculpatory evidence and evaluate a conflict of interest after the deputy public defender made racially charged comments. During a closed hearing, Sanchez expressed his desire to retain his current counsel. However, the trial court ordered the reassignment of the deputy public defender, citing potential issues under the RJA and the risk of ineffective assistance of counsel.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the trial court did not abuse its discretion in removing the deputy public defender. The appellate court noted that the RJA's provisions and the potential for implicit bias created an actual conflict of interest that the deputy public defender could not objectively investigate. Additionally, the court found that the trial court's decision to prevent a potential future RJA claim was within its discretion to avoid substantial impairment of the proceedings.The appellate court concluded that Sanchez's arguments regarding constitutional violations and the necessity of an actual conflict were without merit. The court emphasized that the trial court's order was narrowly tailored and did not violate Sanchez's rights. Consequently, the petition for writ of mandate was denied, and the stay on trial court proceedings was vacated. View "Sanchez v. Superior Court" on Justia Law

Jeannine Bedard, a Los Angeles Police Department (LAPD) officer, refused to comply with the City of Los Angeles’s COVID-19 vaccination mandate and did not sign a notice enforcing the mandate. Consequently, the Chief of Police sought to terminate her employment. The LAPD Board of Rights reviewed the proposed discipline, found Bedard guilty of failing to comply with conditions of employment, and upheld her discharge. The Board also found that the City violated Bedard’s due process rights by not providing sufficient time to respond to the charges and awarded her back pay, which the City did not pay.Bedard filed a petition for a writ of mandate in the Superior Court of Los Angeles County, arguing that the disciplinary action was procedurally and legally invalid and seeking reinstatement and back pay. The trial court found the termination justified but agreed that the City violated Bedard’s due process rights by giving her insufficient time to respond. The court awarded her back pay.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. Bedard argued that her termination was improper because it was based on her refusal to sign an allegedly illegal contract, was too harsh a penalty, and violated her due process rights under Skelly v. State Personnel Board. The appellate court affirmed the trial court’s decision, holding that Bedard’s refusal to comply with the vaccination mandate justified her termination. The court found substantial evidence supporting the trial court’s conclusion that Bedard’s termination was not solely based on her refusal to sign the notice but also on her refusal to comply with the vaccination requirement. The court also held that the appropriate remedy for the due process violation was back pay, not reinstatement. View "Bedard v. City of Los Angeles" on Justia Law

A transgender woman, who had legally changed her name and gender marker in 2018, sought to have the entire record of her name change and gender marker correction sealed in 2023. She argued that the public availability of these records had led to harassment and threats after her transgender status was disclosed on social media, revealing her personal information and former name. The trial court denied her request to seal the entire record but did seal her application to seal, its supporting documentation, and a physician’s letter attached to her initial petition.The Superior Court of Stanislaus County initially granted her petition for a name and gender change in 2018 without any objections. In 2023, she filed an application to seal the entire record, citing harassment and threats due to the public availability of her records. The trial court denied the request to seal the entire record, reasoning that there was no evidence the harassment was initiated by the court’s records and that sealing the records would not necessarily solve the problem. The court also noted the strong presumption that name changes be public to prevent fraud and ensure creditors and others can locate individuals who have changed their names.The California Court of Appeal, Fifth Appellate District, reviewed the case and found that the trial court’s findings were not supported by substantial evidence. The appellate court concluded that the appellant’s privacy and safety interests in concealing her transgender identity outweighed the public’s right of access to the records. The court held that the entire record should be sealed to protect her privacy and safety, as there was no less restrictive means to achieve these interests. The appellate court reversed the trial court’s order and remanded the case with instructions to seal all records revealing the appellant’s name change or gender marker correction. View "In re M.T." on Justia Law

Khyle Armando Briscoe, a youth offender, was sentenced to life without parole for a special circumstance murder committed when he was 21. The murder occurred during a robbery where Briscoe and an accomplice, Shaun P., attacked an acquaintance, Ben P. During the struggle, Ben P. managed to take Briscoe’s gun and fatally shot Shaun P. Briscoe was convicted of first-degree murder, robbery, and burglary, with the jury finding true the special circumstance that he acted with reckless indifference to human life and was a major participant in the underlying felonies.The trial court sentenced Briscoe to life without parole, and the conviction was affirmed on appeal. Briscoe later filed a motion for a parole hearing under Penal Code section 3051, which grants certain youth offenders the opportunity to seek parole but excludes those sentenced to life without parole. The trial court denied his motion, and Briscoe appealed.The California Court of Appeal, First Appellate District, reviewed the case. The court found that section 3051’s exclusion of youth offenders sentenced under section 190.2, subdivision (d) for special circumstance murder, while including those convicted of first-degree felony murder under section 189, subdivision (e)(3), violated equal protection. Both statutes employ the same standard of liability, and the underlying felonies were the same. The court held that there was no rational basis for treating these offenders differently under section 3051.The court reversed the trial court’s order denying Briscoe a section 3051 hearing and remanded the case for the trial court to conduct a Franklin proceeding and a parole hearing. The court reformed section 3051 to include youth offenders like Briscoe, who were sentenced to life without parole under section 190.2, subdivision (d) for murder during a robbery or burglary. View "P. v. Briscoe" on Justia Law

Two defendants, Martin Field and John Asher, were found to be sexually violent predators (SVPs) by separate juries and committed indefinitely to a state hospital. They were compelled to testify against themselves during their commitment trials. Both argued on appeal that they were similarly situated to individuals found not guilty by reason of insanity (NGIs), who are not required to testify against themselves at their commitment trials. They claimed that this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, had previously determined that Field’s equal protection argument had merit and remanded the case to the Superior Court of San Bernardino County for an evidentiary hearing. The same conclusion was reached for Asher’s case by Division Three of the Fourth Appellate District. The trial court held an evidentiary hearing and found that the People had not satisfied their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated by requiring Field and Asher to testify during their commitment trials and ordered new commitment trials for both.The People appealed the new trial orders, arguing that the trial court erred in finding that the disparate treatment of SVPs was not justified. The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court’s orders. The appellate court held that the People had not demonstrated that the testimony of SVPs was more necessary than that of NGIs to justify the disparate treatment under the strict scrutiny standard. The court emphasized that there were sufficient records and other means to evaluate SVPs without compelling their testimony, and thus, the orders for new trials were affirmed. View "P. v. Field" on Justia Law