Justia Civil Rights Opinion Summaries

Christopher Davis, a Black man, was convicted in 2004 of being an ex-felon in possession of a firearm and unlawfully possessing ammunition after police found a loaded handgun and bullets in his apartment. The jury convicted him on those charges, and the trial court found true all 10 prior strike convictions and two prior prison terms. He was sentenced to two years plus 25 years to life under California’s three strikes law. In November 2023, the court struck the two prior prison terms, imposed a 25-year-to-life sentence, and scheduled further resentencing.Afterward, Davis filed a motion with the Superior Court of Riverside County in August 2024 seeking discovery under the Racial Justice Act (RJA), arguing he may have received harsher charging or sentencing than similarly situated non-Black defendants. He requested records of comparable cases in Riverside County, including defendants' racial backgrounds and sentencing outcomes. The People objected, arguing Davis’s evidence was insufficient and that the RJA does not apply to third-strike sentences. On April 28, 2025, the Superior Court granted Davis’s motion for discovery, finding he met the minimal burden for such a request.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. It held Davis failed to present a plausible factual foundation, based on specific facts, that a violation of the RJA could or might have occurred, because the supposed comparator cases were not sufficiently similar and the statistical evidence was unreliable, irrelevant, and lacking expert explanation. The Court also concluded the data Davis presented failed to demonstrate racial disparity specific to his circumstances. The Court granted the People’s petition, directing the superior court to vacate its order granting discovery and to enter an order denying the motion. View "People v. Super. Ct." on Justia Law

The case concerns a defendant convicted in 2014 of first degree murder and possession of a firearm by a felon, along with firearm and gang enhancements, following the fatal shooting of a victim in an apartment complex parking lot. The defendant, a self-admitted member of the Grape Street gang, initially denied involvement but later admitted to shooting the victim after alleging prior conflicts. Evidence contradicted some of his claims, including the absence of a weapon allegedly belonging to the victim and prison records showing no prior shared incarceration. After resentencing proceedings reduced part of his sentence due to legislative changes, the defendant repeatedly sought relief under the California Racial Justice Act (CRJA), alleging racial bias and discriminatory charging and sentencing.Following conviction in San Bernardino County Superior Court, the defendant filed several habeas corpus petitions and CRJA motions. He argued that a juror exhibited racial bias, that a prosecutor made racially discriminatory statements, and cited statistical disparities in sentence enhancements for Black defendants. Each petition was denied by the Superior Court, and appellate review of one denial was dismissed as no appeal lies from such an order. Subsequent motions, including those based on new facts and law, were also denied. The defendant was resentenced to a total indeterminate term of 50 years to life, and a concurrent determinate term of two years, with gang enhancements struck.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the trial court’s denial of the CRJA motion. It held that the defendant had not set forth a prima facie case under the CRJA. Specifically, the evidence provided did not establish juror or prosecutorial bias or discriminatory charging, nor did the statistical data or other evidence demonstrate that similarly situated nonminority defendants were treated more favorably. The trial court’s orders were affirmed. View "People v. Williams" on Justia Law

A patient at Coalinga State Hospital challenged a policy and regulation that permitted hospital staff to x-ray and open all incoming mail outside the presence of patients. He argued that this policy conflicted with certain provisions of the Welfare and Institutions Code and regulations, which he claimed guaranteed patients the right to receive unopened correspondence. The patient, who is civilly committed as a sexually violent predator (SVP), alleged his mail had been opened and contents withheld without his permission, and he sought a judicial declaration concerning his rights under state law.The Superior Court of Fresno County sustained a demurrer filed by the Department of State Hospitals Coalinga and its Hospital Police Chief. The court concluded that the statutory rights cited by the patient, specifically those in Welfare and Institutions Code section 5325, applied only to individuals committed under the Lanterman-Petris-Short (LPS) Act, not to SVPs. The court also found that the regulation authorizing inspection of mail for non-LPS patients did not conflict with the statute, as they applied to different populations. The patient's amended petition was dismissed without leave to amend.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the lower court’s judgment. The appellate court held that Welfare and Institutions Code section 5325 confers mail rights only to LPS patients and that sexually violent predators, as non-LPS patients, are governed by separate regulations under title 9, section 884, which specifically allows for the inspection of their mail. The court found no irreconcilable conflict between the statute and the regulation and concluded that the Department of State Hospitals has authority to adopt regulations necessary for institutional security. The judgment dismissing the patient’s amended petition was affirmed. View "Seeboth v. State Dept. of State Hospitals" on Justia Law

The plaintiff, who was the CEO of a private company with government contracts and a security clearance, was arrested in December 2021 for felony domestic violence. Although no charges were filed, police prepared an investigative report. In February 2022, the San Francisco Superior Court ordered the arrest and related records sealed under California Penal Code sections 851.91 and 851.92. Despite this, the police department released the incident report to a third party without restriction, and it was later sent anonymously to an independent journalist who published articles about the plaintiff’s arrest online, including the report. The plaintiff sought to have the posts removed and subsequently sued the journalist, the platform hosting the articles, and another entity associated with the journalist, alleging multiple causes of action including privacy violations and statutory breaches.The San Francisco County Superior Court reviewed anti-SLAPP motions filed by all defendants, which argued the suit arose from constitutionally protected activity and was barred by the First Amendment and the Communications Decency Act (CDA). The court found that the plaintiff’s claims were based on the defendants’ speech—specifically, online publication in a public forum about a matter of public interest, given the plaintiff’s role and the company's government work. It also determined that statutory protections for sealing did not override constitutional protections, and rejected the argument that defendants’ actions were illegal as a matter of law. The court granted the anti-SLAPP motions and awarded attorney fees to the defendants.The Court of Appeal of the State of California, First Appellate District, Division Four affirmed the trial court’s orders. The main holding was that the First Amendment protects the lawfully obtained, truthful publication of information of public significance, even if the information was originally subject to statutory sealing, and that section 230(c)(1) of the CDA bars claims against interactive computer service providers for hosting such content. The attorney fee award was also affirmed. View "Blackman v. Substack" on Justia Law

In this case, the defendant made threats of mass violence on social media targeting a university, prompting law enforcement to investigate. In 2020, officers searched his bedroom and found parts to assemble an assault rifle, ammunition, and 22 large-capacity magazines (LCMs), all of which he was barred from possessing. He was initially charged with attempted unlawful possession of a firearm, unlawful possession of ammunition, and 22 counts relating to LCMs. The trial court dismissed the LCM charges due to a Ninth Circuit decision at the time declaring California’s LCM ban unconstitutional. The defendant was convicted of the remaining charges and served a prison sentence.After his release, the defendant again posted threats online. Law enforcement searched a storage unit he used and found a receipt showing he had purchased five LCMs in Arizona just before the 2020 search. By this time, the Ninth Circuit had reversed its earlier decision and upheld the LCM statute as constitutional. Prosecutors filed new charges: two counts of extortion and five counts of importing LCMs into California. The defendant moved to dismiss the new LCM charges, arguing that prosecuting them violated the Kellett rule, which generally bars successive prosecutions for offenses arising from the same act or course of conduct. The Superior Court of Orange County denied his motion, and a jury convicted him on the LCM charges but deadlocked on extortion.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the conviction. The court held that the Kellett rule did not bar the new prosecution because the LCM charges had been dismissed in the initial case in the interests of justice, and additional evidence (the Arizona receipt) was not available earlier despite due diligence. The court found both that the statutory exceptions and the unavailable evidence exception to the Kellett rule applied, and thus affirmed the judgment. View "P. v. Dumbrava" on Justia Law

A group of unmarried automobile insurance policyholders challenged a California Department of Insurance regulation that allows private auto insurers to use marital status as a factor in setting rates, so long as there is a substantial relationship between marital status and risk of loss. Their argument was that after legislative amendments in 2005 and 2008, the regulation conflicted with the Unruh Civil Rights Act—which was amended to prohibit businesses from discriminating based on marital status—and the Rosenthal Auto Insurance Nondiscrimination Law (RAIN law), which similarly restricted insurers from using protected characteristics for rate-setting.The Superior Court of Alameda County denied the petition for a writ of mandate, concluding that a limiting clause in the Unruh Civil Rights Act—stating it confers no right or privilege “conditioned or limited by law”—meant the preexisting marital status regulation, which specifically addressed insurance rating factors, was not overridden by the later amendments to the Act. The court found that the regulation could be harmonized with the Act and that Proposition 103, which authorized the regulation, anticipated that the Unruh Act might be amended but included the limiting language to avoid conflict.The Court of Appeal of the State of California, First Appellate District, Division Three, affirmed the lower court’s decision. It held that the regulation does not conflict with the Unruh Civil Rights Act or the RAIN law. The court found that the Act’s limiting provision requires deference to the specific insurance regulation on marital status, which has the force of law and was validly adopted under Proposition 103. It also determined that legislative history of the RAIN law showed no intent to strip the Insurance Commissioner of authority over rating factors. The judgment denying the writ of mandate was affirmed. View "Ison v. Lara" on Justia Law

Two individuals, both members of the Lincoln Park Bloods gang, were convicted in San Diego County Superior Court of two murders, conspiracy to commit murder, and attempted murder, with special circumstance and gang-related enhancements, for their roles in two gang-related shootings that occurred in 2011 and 2013. The prosecution’s theory was that higher-ranking gang members directed the killings, and a rap song performed by an uncharged coconspirator was introduced as evidence of gang motive and hierarchy. The jury found the defendants guilty on all counts and enhancements, and the trial court sentenced each to consecutive life terms without parole plus additional years.On prior appeal, the California Court of Appeal, Fourth Appellate District, Division One, vacated the gang and gang-related firearm enhancements and remanded for further proceedings. On remand, the prosecution did not retry those enhancements. The defendants moved for a new trial under the California Racial Justice Act (RJA) and newly enacted Evidence Code section 352.2, also seeking discovery under the RJA. The trial court denied all motions, finding the rap song admissible and concluding that the defendants had not demonstrated a miscarriage of justice or substantiated their claims that the song’s introduction—allegedly containing prejudicial, racially charged language—was played for the jury.The California Court of Appeal, Fourth Appellate District, Division One, held that while the trial court properly denied the new trial motions based on section 352.2, it erred by not recognizing that the defendants had established a prima facie RJA violation and by applying an overly restrictive standard to the discovery request. The Court conditionally reversed the judgments and remanded for an evidentiary hearing on the RJA claims and for reconsideration of the discovery motion in accordance with correct legal standards. If relief is denied on remand, the judgments are to be reinstated. View "People v. Haddock" on Justia Law

A public hospital district in California established and recorded covenants, conditions, and restrictions (CC&Rs) in 1991 for a common interest development known as the Tulare Medical Center. These CC&Rs included a prohibition on abortion clinics within the development. In 2001, certain property subject to these CC&Rs was transferred to individual owners, who later sought to lease it to a family planning organization that provides a range of services, including abortion. The property owners association, comprised of all parcel owners and authorized to enforce the CC&Rs, objected to the lease and sought to enjoin the operation of the clinic, arguing that any abortion services would violate the CC&Rs.The Superior Court of Tulare County reviewed the association’s request for a preliminary injunction. After considering the parties’ submissions and arguments, the court denied the injunction. The court found there was a credible threat that abortion services would be provided but concluded the association had not shown a likelihood of prevailing on the merits. Specifically, the trial court noted unresolved legal questions regarding whether restrictions on abortion clinics in CC&Rs violated the Unruh Civil Rights Act or California constitutional protections, and found the association failed to demonstrate that the balance of harms favored an injunction.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that the prohibition on abortion clinics, adopted by a public entity, constituted government action that interfered with the fundamental constitutional right to reproductive choice under the California Constitution. The court applied the compelling interest test, found no compelling interest justifying the restriction, and concluded the prohibition violated fundamental public policy. Additionally, the court held that the prohibition was void under Civil Code section 53 because it indirectly limited property use based on a characteristic protected by the Unruh Act. The order denying the preliminary injunction was affirmed. View "Tulare Medical Center Property v. Valdivia" on Justia Law

Two men approached a van in a Denny’s parking lot in Los Angeles in the early morning hours of December 19, 1981. One of the men, holding a gun, demanded valuables from the occupants, Toney Lewis and Carolyn Spence. After robbing them, the gunman shot Lewis, who died from the wound. At trial, there was conflicting eyewitness identification as to whether the defendant or his brother was the shooter. An accomplice, who testified in exchange for a plea deal, stated that the defendant was the gunman and shot Lewis. Other witnesses recounted statements by the defendant suggesting his brother was not the killer and that he was the one who shot Lewis.The defendant was convicted in the Superior Court of Los Angeles County of murder, robbery, and attempted robbery, with the jury finding true that a principal was armed with a firearm but not true that the defendant personally used a firearm or that the robbery special circumstance (which, as instructed, required the defendant to have personally killed the victim) applied. On direct appeal, the California Court of Appeal affirmed the conviction. Subsequently, the defendant petitioned for resentencing under Penal Code section 1172.6 (formerly 1170.95), which provides relief for certain felony-murder convictions. The resentencing court initially denied relief, finding the defendant aided and abetted the murder. The Court of Appeal reversed and remanded, instructing reconsideration under the theories that the defendant was either the actual killer or a major participant acting with reckless indifference.In the most recent proceeding, the California Court of Appeal, Second Appellate District, Division One, held that the jury’s not-true findings on the firearm enhancement and special circumstance did not preclude the resentencing court from finding the defendant was the actual killer. The court found substantial evidence supported that finding and affirmed the denial of resentencing. View "People v. Player" on Justia Law

Two married tenured professors at California State University, Chico alleged that they were subjected to harassment and discrimination by their department chair, with one professor experiencing conduct targeted at her gender and Korean ancestry. Despite their reports to university administration, the university did not intervene. As a result, one professor suffered serious mental health consequences, leading their doctor to recommend that she not work in the same environment as the chair. The university’s lack of response allegedly forced both professors to resign and accept positions at another university. After their resignation, the university initiated an investigation into one professor for an alleged violation of student privacy laws and communicated these allegations to the new employer, which the professors claimed was intended to sabotage their new employment. There were also alleged delays in transferring their lab equipment.The professors filed suit in the Superior Court of Butte County, asserting, among other claims, retaliation and whistleblower retaliation under California law. The university filed a special motion to strike these two causes of action under California’s anti-SLAPP statute, arguing that the claims were based in part on communications protected by the statute. The trial court denied the motion, finding the university’s actions involved an official proceeding but also concluding that the professors demonstrated a likelihood of prevailing on their claims.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court’s denial of the anti-SLAPP motion. The appellate court held that the university failed to carry its burden to show that all actions underlying the challenged causes of action were protected activity. The court clarified that the presence of some protected communications within the allegations does not mean the entire cause of action arises from protected activity. The judgment denying the anti-SLAPP motion was therefore affirmed. View "Pechkis v. Trustees of the Cal. State University" on Justia Law