Justia Civil Rights Opinion Summaries

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 of Cal." on Justia Law

Two defendants, Fredi Analberto Lopez-Flores and Christian Alejandro May Quintero, were convicted of multiple sex crimes, including forcible rape, sodomy, and oral copulation in concert, after they abducted an inebriated woman, Jane Doe, from the streets of San Francisco, drove her 50 miles away, and assaulted her. The prosecution used terms like "monsters" and "predators" during closing arguments, which the defendants later claimed violated the California Racial Justice Act (RJA) and constituted prosecutorial misconduct.In the lower court, the jury found both defendants guilty on all counts. Lopez-Flores was also found to have a prior conviction, which was considered during sentencing. The trial court imposed consecutive sentences under section 667.6, subdivision (d), finding that the offenses occurred on separate occasions. The court also stated that even if this finding was incorrect, it would impose consecutive sentences under section 667.6, subdivision (c), based on the nature of the crimes and aggravating factors.The California Court of Appeal, First Appellate District, reviewed the case. The court concluded that the prosecution's use of the terms "monsters" and "predators" did not violate the RJA, as these terms were race-neutral and based on the defendants' conduct. The court also found no prosecutorial misconduct, determining that the comments were within the permissible range of descriptive commentary based on the evidence. The court held that the trial court did not err in imposing consecutive sentences under section 667.6, subdivision (c), and any potential error under subdivision (d) was harmless because the court provided adequate reasons for its discretionary decision. The judgments were affirmed. View "P. v. Quintero" on Justia Law

A Black man, known for his career in the NFL, was accused by an intellectually disabled woman of raping her at gunpoint during a babysitting job interview at his home. The jury found him guilty of forcible rape, forcible oral copulation, and false imprisonment, with firearm use in the first two offenses. He was sentenced to 15 years to life in prison. The prosecution argued that the police did not search his house due to his fame and race, suggesting a search would have caused controversy.The trial began in March 2020 but was paused due to the COVID-19 pandemic, resuming three months later. The jury acquitted him on two counts related to the victim's incapacity to consent. The trial court sentenced him in October 2020. The defendant appealed, arguing that the prosecution's statements violated the California Racial Justice Act of 2020 by appealing to racial bias.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the prosecution violated the Racial Justice Act by explicitly asserting that the defendant's race influenced the police's decision not to search his house, implying he gained an undeserved advantage at trial because he was Black. The court concluded that the prosecution's statements constituted racially discriminatory language under Penal Code section 745, subdivision (a)(2). The court held that Penal Code section 745, subdivision (e)(2)(A) precludes harmless error analysis and mandates vacating the conviction and sentence. Consequently, the court reversed the judgment, vacated the conviction and sentence, and remanded for new proceedings consistent with the Racial Justice Act. View "P. v. Stubblefield" on Justia Law

The case involves Lori Ann Wiley, who, along with Charles Wallace Hanson, engaged in a verbal altercation at a Kern High School District (KHSD) high school. The incident began when a school employee blocked a handicap parking spot they intended to use. Wiley later submitted a written complaint about the incident to the school. Subsequently, KHSD police officer Michael Whiting recommended various misdemeanor charges against Wiley, leading to her being cited and a prosecutor filing a criminal complaint with three misdemeanor charges. After a mistrial, the court dismissed Wiley’s charges in the interest of justice.Wiley sued KHSD police officers Edward Komin, Michael Whiting, Luis Peña, and Steven Alvidrez, alleging violations of her First Amendment rights, malicious prosecution, and abuse of process. She brought causes of action under 42 U.S.C. section 1983, the Bane Act, and common law torts for intentional infliction of emotional distress and negligence. The trial court sustained the defendants’ demurrer to Wiley’s causes of action in the second amended complaint on multiple grounds without leave to amend and granted a motion to strike Wiley’s punitive damages allegations without leave to amend.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court affirmed the trial court’s decision in part and reversed it in part. The appellate court held that Wiley failed to adequately plead her claims under section 1983 for malicious/retaliatory prosecution and abuse of process, as well as her claims under the Bane Act. The court also found that the defendants were entitled to qualified immunity and that Wiley did not sufficiently allege facts to support her claims for intentional infliction of emotional distress and negligence. However, the court granted Wiley leave to amend her section 1983 claim but denied leave to amend her other causes of action. The court affirmed the trial court’s order granting the motion to strike without leave to amend. View "Wiley v. Kern High School District" on Justia Law

The appellant, Shawn Lee Perrot, was convicted in 2004 of multiple sexual offenses involving minors, including forcible rape, lewd acts on a child, and distribution of lewd material to a minor. After serving over 16 years of a 21-year sentence, he was paroled with specific conditions. Perrot violated three parole conditions: accessing and using computer devices, associating with known sex offenders, and possessing sexually stimulating devices. He challenged these conditions as unconstitutionally vague and overbroad.Upon his release, Perrot refused to sign parole conditions, leading to civil commitment proceedings, which were later dismissed. He was evaluated as high risk for reoffending. Perrot signed parole conditions, including prohibitions on computer access, associating with sex offenders, and possessing sexually stimulating devices. He filed grievances and a habeas corpus petition challenging these conditions, which were largely denied, though he was temporarily allowed limited computer use for legal research.The Department of Adult Parole Operations filed a petition for parole revocation, alleging Perrot violated the conditions. Evidence showed he possessed multiple unauthorized devices, operated a business assisting sex offenders, and had sexually stimulating devices. The court found probable cause and revoked his parole, sentencing him to a 60-day jail term, followed by reinstatement to parole.The California Court of Appeal, First Appellate District, reviewed the case. The court rejected Perrot's claims, holding that the parole conditions were not unconstitutionally vague or overbroad. The court found the conditions were sufficiently precise and narrowly tailored to address the state's compelling interest in preventing Perrot from reoffending. The order revoking Perrot's parole was affirmed. View "P. v. Perrot" on Justia Law

A man named Johnathon Lerke, who was under a Murphy conservatorship, challenged his confinement in a county jail while awaiting transfer to a state hospital. Murphy conservatorships are for individuals found incompetent to stand trial and deemed a danger to others. Despite being ordered to a state hospital, Lerke was held in county jail for months due to a lack of space at the hospital. He argued that his confinement in jail was unauthorized and violated his rights.The Superior Court initially found Lerke incompetent to stand trial and ordered him to a state hospital for competency restoration. After nearly two years, the hospital reported that Lerke had not regained competence. Subsequently, a Murphy conservatorship was established, requiring his placement in a state hospital. However, due to the unavailability of space, he remained in county jail. Lerke's counsel requested his release or transfer to a local psychiatric hospital, but the court denied the request, stating that he would remain in jail until a state hospital bed became available.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court concluded that no legal authority permitted Lerke’s indefinite detention in county jail pending his transfer to the state hospital. The statutory framework requires conservatees to be placed in treatment facilities that promote their treatment and protect the public, and county jails do not meet these requirements. Although the court found Lerke’s confinement in jail unlawful, it denied habeas relief because he had already been transferred to an authorized treatment facility during the proceedings. The petition for writ of habeas corpus was denied as moot. View "In re Lerke" on Justia Law

Roderick Barnes III was convicted by a jury of three counts of attempted murder, three counts of attempted robbery, and three counts of assault with a firearm. The jury also found that Barnes personally discharged a firearm causing great bodily injury and that he participated in a criminal street gang, committing the crimes for the benefit of the gang. Barnes was sentenced to 70 years to life in prison.Barnes appealed, arguing that the trial court erred in overruling his objection to the prosecutor’s use of a peremptory challenge against a Black prospective juror, failing to instruct the jury with CALCRIM No. 332, and that there was insufficient evidence to support the gang participation conviction and enhancements. The People conceded the latter two points but argued that the gang-related offenses could be retried.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court found that the trial court erred in overruling Barnes’s objection to the peremptory challenge. The court determined that the prosecutor’s reasons for striking the juror were not valid and that the trial court improperly considered reasons not stated by the prosecutor. The court also found that substantial evidence did not support the gang participation conviction and enhancements, as the prosecution failed to provide a sufficient foundation for the expert’s opinion that the murder of P.M. commonly benefited the gang.The Court of Appeal reversed the judgment in its entirety and remanded the case for a new trial on counts 1 through 9. The court held that the prosecution could not retry Barnes for the gang participation offense or the gang enhancements due to insufficient evidence. View "People v. Barnes" on Justia Law

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. The jury also found true firearm allegations. 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. His minimum eligible parole date (MEPD) is set for February 2036, and his youth parole eligible date (YPED) is set for October 2026.Nguyen petitioned the trial court for a writ of habeas corpus in 2022, arguing that he should be allowed to use all earned 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 issue 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, as it aligns with the legislative intent to provide youth offenders with a meaningful opportunity for release while maintaining a relatively fixed YPED. Consequently, the court denied Nguyen's petition for writ of habeas corpus. View "In re Nguyen" on Justia Law

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