Justia Civil Rights Opinion Summaries

Articles Posted in California Courts of Appeal
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The case involves David Arias, who was convicted of two counts of sexual abuse against a minor. During the trial, the defense challenged the prosecutor's use of a peremptory strike against a prospective Black female juror. The trial court ruled that a prima facie case of discrimination was established, but accepted the prosecutor's reasons for the strike without further discussion. Arias was convicted and sentenced to 15 years to life in prison.The trial court's decision was appealed to the Court of Appeal of the State of California, First Appellate District. The appellate court found that the trial court's denial of the defense's challenge to the prosecutor's peremptory strike was improper. The prosecutor's reasons for the strike did not withstand scrutiny. The appellate court concluded that the record lacked sufficient evidence on which the trial court could have reasonably relied to accept the prosecutor's reasons for striking the juror without further probing and explanation. As a result, the appellate court reversed the trial court's decision. View "P. v. Arias" on Justia Law

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The case involves a defendant who was convicted of first-degree murder with special circumstances and an enhancement for personally and intentionally discharging a firearm causing great bodily injury or death. The defendant appealed his conviction, arguing that his trial counsel exhibited racial bias towards him in violation of the California Racial Justice Act of 2020 (RJA) by advising him to use Ebonics and slang when he testified. He also contended that the trial court erred in imposing two sentence enhancements and a parole revocation restitution fine after sentencing him to life without the possibility of parole.The Court of Appeal of the State of California, First Appellate District, Division Five, found that the defendant's trial counsel did not exhibit racial bias. The court noted that the counsel's advice to the defendant to "speak how you speak" when testifying was a valid tactical decision aimed at ensuring the defendant appeared authentic and genuine before the jury. The court also found that the defendant had not demonstrated by a preponderance of the evidence that his counsel's advice indicated racial animus or bias towards him. Therefore, the court concluded that there was no violation of the RJA.The court also found that the defendant's claim that his enhancements should have been stricken was forfeited for failure to request that the trial court strike the enhancements under section 1385. However, the court agreed with the defendant and the People that the trial court improperly imposed a parole revocation restitution fine. The court modified the judgment to strike the parole revocation restitution fine and affirmed the judgment in all other respects. View "P. v. Coleman" on Justia Law

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The case revolves around June LaMarr, an employee at the University of California Davis Medical Center, who was transferred to a different department following performance issues and conflicts with her supervisor. The transfer was initially temporary, but later became permanent, resulting in a decrease in LaMarr's pay. LaMarr sued the Regents of the University of California, alleging that her due process rights were violated as she was not provided a hearing under Skelly v. State Personnel Bd. before her demotion.The trial court found in favor of the Regents. It concluded that LaMarr was not deprived of due process when she was offered the option to either transfer to a non-supervisory position with reduced pay or return to her higher paying supervisory position and face possible termination proceedings. The court reasoned that the Regents never issued a notice of intent to dismiss and that LaMarr's feeling of duress did not trigger due process protections.In the Court of Appeal of the State of California Third Appellate District, LaMarr appealed the trial court's decision, arguing that the finding lacked substantial evidence. She contended that she was not informed of the adverse consequences of accepting a transfer and that her acceptance of the transfer was not voluntary.The appellate court affirmed the trial court's decision. It found substantial evidence that the Regents did not violate LaMarr's due process rights because she was never notified of an intent to terminate and any demotion was voluntary. The court also noted that a difficult choice is not the same as an involuntary choice. It concluded that there was substantial evidence supporting the trial court's finding that the Regents did not deprive LaMarr of due process. View "LaMarr v. The Regents of the University of California" on Justia Law

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The case revolves around Israel Marcial Uriostegui, who was convicted of first-degree residential burglary by a jury. Uriostegui appealed the judgment, arguing that the trial court erred in denying his objection under section 231.7 of the Code of Civil Procedure. This section aims to prevent the improper removal of jurors based on their actual or perceived race, ethnicity, gender, or membership in another protected group. Uriostegui's objection was based on the prosecutor's peremptory challenge against a prospective juror, T.N., who appeared to be Hispanic.Previously, the trial court had asked T.N. for basic information during voir dire. T.N. disclosed her employment at Taco Bell, her current unemployment due to an injury, and her lack of prior jury service. She also revealed that two of her family members had been convicted of a crime, but she was not close to them. When the prosecutor exercised a peremptory challenge against T.N., Uriostegui's counsel objected, arguing that the basis for excusing T.N. was presumptively invalid under section 231.7. The prosecutor justified the challenge by citing T.N.'s "lack of life experience," her unemployment, and her demeanor. The trial court denied Uriostegui's objection, finding no substantial likelihood that T.N.'s perceived membership in a protected class was a factor in the peremptory challenge.In the Court of Appeal of the State of California Second Appellate District, Uriostegui contended that the trial court erred in denying his objection under section 231.7. The court agreed with Uriostegui, stating that the prosecutor's reasons for excusing T.N. were presumptively invalid under section 231.7. The court found that the prosecutor's reasons and the trial court's findings did not overcome the presumption of invalidity. The court concluded that the trial court erred in denying Uriostegui's objection under section 231.7. As a result, the judgment was reversed, and the case was remanded for a new trial. View "People v. Uriostegui" on Justia Law

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The appellant, Samantha Wood, sought to legally change her name to Candi Bimbo Doll, an identity she had pursued for over a decade. Despite no opposition to her request, the trial judge of the San Francisco County Superior Court denied Wood's petition based on the judge's interpretation of the term "bimbo" as inherently offensive. The judge derived this interpretation from various sources, including the Oxford English Dictionary, a law review article, and trends on the social media platform, TikTok.Upon appeal, the Court of Appeal of the State of California First Appellate District Division Two reversed the trial court's decision. The appellate court held that the trial court erred by denying Wood's petition for a name change. The court established that the trial court had incorrectly applied the principle that a name change may be denied only upon a "substantial reason".The appellate court determined that the term "bimbo" was not universally offensive or vulgar. They found that the term was being reclaimed and used as a means of empowerment in certain contexts, including on TikTok. The court also highlighted that the term did not appear to cause any confusion, as evidenced by its use in various business names and personalized license plates.Consequently, the court concluded that the trial court had abused its discretion by not adhering to the applicable legal principles that favor granting a name change, and by failing to identify substantial and principled reasons for denying the name change. The case was remanded to the trial court with instructions to grant Wood's petition for a name change. View "Wood v. S.F. Superior Court" on Justia Law

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Samantha Wood, a California resident, petitioned the state's superior court to legally change her name to Candi Bimbo Doll, an identity she had embraced for over a decade. The trial court denied her petition, citing a California case and a law review article to argue that the proposed name could be considered offensive. The trial judge also referenced a 2020's TikTok trend of "Bimbofication," which encourages self-love and reclaims the term "bimbo." The judge, however, viewed the term as offensive and a setback for women's empowerment.Wood appealed this decision to the Court of Appeal of the State of California First Appellate District Division Two. The court found that the trial court had erred in its decision. It cited several precedents emphasizing that a name change should only be denied for "substantial and principled reasons," such as potential confusion or fraud. The court reasoned that "bimbo" is not a fighting word, is not necessarily offensive, and is not inherently confusing. Furthermore, the court underscored that the term is being reclaimed in a positive way as part of a women's empowerment trend. Consequently, the appellate court reversed the trial court's decision and directed it to grant Wood's petition for a name change. View "Wood v. Superior Court" on Justia Law

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Samantha Wood, a resident of California, filed a petition to legally change her name to Candi Bimbo Doll, a name she had been using for over a decade. There was no opposition to her petition and no hearing was held. However, the trial judge denied her petition, citing a California case, a law review article, and a TikTok trend. The court asserted that no person has a statutory right to officially change their name to a term that is universally recognized as offensive.Wood appealed the decision. The Court of Appeal of the State of California First Appellate District examined previous case law and found that a change of name may only be denied when there is a 'substantial reason.' In this case, the court ruled that the term 'Bimbo,' while historically derogatory, is not universally recognized as offensive. The court also noted that the term is being reclaimed in a positive way through social media trends, such as on TikTok.The court found that the trial judge had not provided a substantial reason to deny the name change and had not properly exercised discretion according to the legal principles of the subject. Therefore, the Court of Appeal reversed the trial court's decision and remanded the case to the trial court to grant the name change. View "Wood v. Super. Ct." on Justia Law

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The case revolves around plaintiff Rynold Dwayne Jackson, who alleged malicious prosecution and unfair business practices after an altercation at a hotel lounge. Jackson was refused service on the basis of intoxication. Following a dispute, Jackson and the hotel's director of security, Mario Lara, had physical contact leading to Jackson's prosecution for battery. After being found not guilty, Jackson filed a civil complaint against Lara and DT Management, LLC, the company managing the hotel and lounge.Jackson alleged malicious prosecution against Lara, claiming the criminal prosecution was based on a false assault accusation. He also alleged DT Management violated the Unfair Competition Law by denying equal access, permitting discriminatory behavior by employees, and selectively deleting incident footage.The defendants filed a motion for summary judgment, which the lower court granted. The court considered Jackson's failure to appear at the motion hearing as a submission on the tentative ruling. Jackson appealed this judgment.The Court of Appeal, Fourth Appellate District Division One, State of California, affirmed the lower court's judgment. They cited the interim adverse judgment rule, which establishes that a trial court judgment in favor of the plaintiff or prosecutor, unless obtained fraudulently, forms probable cause to bring the underlying action. The court found this rule applicable as Jackson's motion for acquittal in his criminal trial was denied, thus establishing probable cause for Lara's accusation.As for the unfair business practices claim, Jackson failed to substantiate his allegations with legal authority or argument, resulting in the dismissal of his claim. Furthermore, a new theory he proposed on appeal was disregarded as it was raised for the first time and not considered in the trial court. View "Jackson v. Lara" on Justia Law

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This case pertains to Jeremiah Paul, a parolee, who was convicted of possession of a firearm due to his prior violent conviction, after police officers discovered a firearm in his vehicle. The discovery occurred after the officers asked him about his parole status during an encounter, which he contends was an unlawful detention that led to the discovery of the firearm. Paul argued that the evidence of the firearm should have been suppressed as it was only discovered following his unlawful detention.The Court of Appeal of the State of California, Second Appellate District, Division Five, disagreed with the trial court's ruling that the initial encounter between Paul and the police officers was consensual. The appellate court highlighted several factors such as the positioning of the police officers, their use of flashlights on Paul, the fact that Paul was engaged in a phone conversation when the officers approached, and the opening of the vehicle's door, which would have led a reasonable person to believe that they were not free to leave. This, they concluded, constituted an unlawful detention.Consequently, the appellate court reversed the trial court's ruling stating the initial encounter was consensual. The court held that Paul's motion to suppress the evidence of the firearm, which was discovered as a result of the unlawful detention, should have been granted. The court reversed the judgment, vacated the conviction, and remanded the case to the trial court with instructions to grant Paul's motion to suppress the evidence of the firearm. View "People v. Paul" on Justia Law

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The case involves Jeremiah Paul, who was convicted of possession of a firearm with a prior violent conviction. Paul had pleaded no contest following the denial of his motion to suppress evidence of a firearm by the trial court, pursuant to Penal Code section 1538.5. He contended that the evidence of the firearm should have been excluded because law enforcement officers discovered it only after they unlawfully detained him to verify his parole status. The Court of Appeal of the State of California Second Appellate District Division Five found that the initial encounter between Paul and the officers was indeed an unlawful detention. The court pointed to several factors leading to this conclusion such as the positioning of the officers that blocked Paul from leaving, the officers approaching Paul from both sides of his car and shining their flashlights into his car, and the fact that the officers approached Paul while he was on his phone in a legally parked vehicle. The court held that these factors would lead a reasonable person to believe they are not free to leave, thus constituting a detention. Therefore, the court reversed the trial court’s judgment and vacated its order denying Paul's motion to suppress evidence. The court concluded that the officers would not have obtained Paul's parole status if they had not first unlawfully detained him and thus, the firearm was not lawfully obtained and should be suppressed. View "P. v. Paul" on Justia Law