Justia Civil Rights Opinion Summaries

Defendant was charged with two separate crimes, murder and participation in a criminal street gang. The court failed to include the standard reasonable doubt instruction prior to the jury's deliberations. The court's instructions with regard to the murder charge did inform the jury that it must find every element of that charge must be proved beyond a reasonable doubt. The instruction relating to the gang offense did not include similar reasonable doubt language. The jury found Defendant guilty of the lesser offense of voluntary manslaughter and of the gang offense. The court of appeals reversed Defendant's conviction of the gang offense. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court's omission of the standard reasonable doubt instruction did not constitute federal constitutional error as to the voluntary manslaughter conviction, and although the omission amounted to state law error as to that conviction, the error was harmless; and (2) with respect to the gang offense, the failure to instruct the jury to prove the elements of the crime beyond a reasonable doubt constituted error under both state law and the federal constitution, but the error was harmless.

Petitioner was found guilty of the murders of two brothers. The trial court sentenced Petitioner to death. The Supreme Court affirmed. Petitioner subsequently filed a habeas corpus petition for relief from the judgment of death. The Supreme Court ordered an evidentiary hearing on Petitioner's claim that the prosecution had failed to disclose evidence that would have supported a case in mitigation at the penalty phase that Petitioner committed the two murders because of a Colombian drug cartel's death threats against him and his family. The referee found merit to Petitioner's claim. The Supreme Court upheld the determination by the referee and granted Petitioner's habeas corpus petition, holding (1) substantial evidence supported the referee's determination, and (2) it was reasonably probable that Petitioner's penalty phase jury would have returned a verdict of life imprisonment without parole had it heard the evidence withheld by the prosecution.

In 2007, sixteen-year-old Defendant opened fire on three teenage boys who were members of a rival gang. A jury convicted Defendant of three counts of attempted murder. The jury found true that Defendant personally and intentionally discharged a firearm and inflicted great bodily harm on one victim and that Defendant committed the crimes for the benefit of a criminal street gang. Defendant's total sentence was 110 years to life. The court of appeal affirmed. At issue before the Supreme Court was whether the sentence contravened the mandate in Graham v. Florida against cruel and unusual punishment of juveniles convicted of nonhomicide offenses and sentenced to life imprisonment without the possibility of parole. The Court reversed, holding that consistent with the U.S. Supreme Court's holding in Graham, sentencing a juvenile offender for a nonhomicide offense to a term of years with a parole eligibility date that falls outside the juvenile offender's natural life expectancy constitutes cruel and unusual punishment in violation of the Eighth Amendment.

A jury convicted Defendant Richard Valdez of five counts of first degree murder. As to each count, the jury found true special circumstance allegations of multiple murder and gang and weapon enhancement allegations. The evidence presented at trial established that Defendant was a member of the Sangra street gang. The jury returned a verdict of death as to each of the victims. The trial court denied the automatic application to modify the verdict and sentenced Defendant to death for the five murders. The Supreme Court affirmed, holding, among other things, that Defendant's claims alleging numerous errors in connection with protective orders the trial court issued delaying and limiting disclosure of the identities of certain prosecution witnesses failed, and that the trial judge did not prejudicially err in refusing to declare a mistrial after the jurors declared they were at an impasse and could not reach a unanimous verdict on any count.

Defendant, an ex-felon on probation, planted an object near a government building that resembled a bomb and that caused fear and disruption when discovered. Defendant was convicted of violating Cal. Penal Code 148.1(d), which allows misdemeanor or felony punishment for anyone who maliciously places a false bomb with the intent to cause another person to fear for his own safety or the safety of others. Defendant's sentence included a twenty-five-years-to-life three strikes term based on the section 148.1(d) felony count and his prior serious and violent felony convictions. The court of appeal reduced the section 148.1(d) conviction to a misdemeanor, finding that the felony provision under which Defendant was convicted and sentenced denied him equal protection of the law when compared to an entirely different statute, Cal. Penal Code 11418.1, which provides that anyone who places a WMD with the intent to cause fear in others can be convicted of a felony only if the perpetrator's conduct causes another person to be placed in sustained fear, an element not necessary under the false bomb statute. The Supreme Court reversed, holding that no equal protection violation occurred, as the challenged distinction was not irrational.

The Minor in this case was the subject of several delinquency petitions. Minor was eventually placed in foster care. Minor appealed, arguing the dispositional order placing him in foster care had to be reversed because the juvenile court had failed to comply with the notice requirements of the Indian Child Welfare Act (INCA). The court of appeals affirmed, holding notice was not required because federal law specifically excludes delinquency cases from ICWA, and any interpretation of California law that would expand ICWA's application to delinquencies would be invalid under federal preemption principles. The Supreme Court affirmed, holding (1) California law requires the court to inquire about a child's Indian status at the outset of all juvenile proceedings, but ICWA's additional procedures are not required in most delinquency cases; (2) a delinquency court must ensure that notice is given and other ICWA procedures are complied with only under certain circumstances; and (3) assuming Minor was an Indian child, the juvenile court did not err in failing to give notice under ICWA in this case.

A jury convicted Defendant of the first degree murder of a Los Angeles County sheriff's deputy. The jury found true the special circumstance allegations that Defendant committed the murder to avoid a lawful arrest and that he knew or should have known that the victim was a peace officer performing his duties. The jury also found that Defendant was armed with and personally used a firearm during the offense. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment after examining (1) pretrial and guilt phase issues, (2) penalty phase issues, and (3) challenges to the death penalty law, holding that the trial court correctly convicted and sentenced Defendant.

A jury convicted Defendant of first degree murder and found true the robbery-murder and burglary-murder special circumstance allegations. The jury also convicted Defendant of first degree robbery, first degree burglary, and kidnapping for robbery, finding as to these counts that the victim was sixty-five years or older. The jury additionally convicted Defendant of two counts of second degree burglary. The trial court imposed a sentence of death for the murder. With respect to the remaining counts, the trial court imposed, among other things, the upper term of nine years for carjacking plus one year for the elderly victim enhancement. The Supreme Court affirmed the death judgment as modified, concluding that the judgment should be modified to stay the sentence on the carjacking count, as Defendant could not be punished for both carjacking and kidnapping for robbery because the prosecutor argued to the jury that the victim's car was the object of the robbery.

A jury convicted Defendant of the first degree murders of four persons and found true a multiple-murder special-circumstance allegation. The jury also convicted Defendant of the attempted murders of ten other persons and found true allegations that the attempted murders were willful, deliberate, and premeditated; that Defendant personally used a firearm in committing the murders and attempted murders; and that, except as to one person, Defendant personally inflicted great bodily injury in committing the attempted murders. The jury further convicted Defendant of assault with a firearm on three individuals and false imprisonment for the purpose of protection from arrest. After a sanity trial, the jury found Defendant to be sane. After a penalty phase, the jury returned a verdict of death. The trial court sentenced Defendant to death on the murder counts, life imprisonment on the attempted murder counts, and a determinate sentence on the remaining counts and enhancements. The Supreme Court affirmed the judgment of the district court, holding that the court did not err in its judgment.

Defendant Ivan Joe Gonzales was convicted of murdering four-year-old Genny Rojas. The jury found as a special circumstances that the murder was intentional and involved the infliction of torture. However, it was unable to reach a penalty verdict. Another jury was impaneled, and the second penalty phase trial resulted in a death verdict. After analyzing several aspects of the conviction of and sentence, including (1) guilt phase issues, and (2) penalty phase issues, the Supreme Court affirmed the judgment of the trial court, holding that the court did not err in its judgment.