Justia Civil Rights Opinion Summaries

Articles Posted in California Supreme Court
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After a jury trial, Defendant was found guilty of first degree murder, kidnapping during the commission of a carjacking, carjacking, and being a felon in possession of a firearm. After the penalty phase, the trial court sentenced Defendant to death. The Supreme Court reversed the carjacking conviction and stayed the sentence of kidnapping during the commission of a carjacking but affirmed the judgment in all other respects, including the death sentence, holding (1) because carjacking is a necessarily lesser included offense of kidnapping during a carjacking, Defendant’s conviction and sentence for carjacking could not stand; and (2) Cal. Penal Code 654 required staying of the kidnapping during a carjacking conviction. View "People v. Montes" on Justia Law

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After a jury trial, Defendant was convicted of the first degree murder of Monique Cleveland, the willful, deliberate, and premeditated attempted murder of Robert Cleveland, and being a felon in possession of a firearm. After a penalty retrial, the jury returned a verdict of death on the murder conviction. The Supreme Court affirmed, holding that (1) any error on the trial court’s part in ordering Defendant to wear a stun belt during his trial was harmless because there was no reasonable possibility that Defendant would have received a more favorable verdict had the trial court not required him to wear a stun belt; (2) the evidence was sufficient to support Defendant’s convictions; and (3) the trial court did not commit reversible error in its rulings during the penalty retrial. View "People v. Jackson" on Justia Law

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After a jury trial, Defendant was convicted of the first degree murder of her husband under the special circumstances of murder by administering poison and murder for financial gain. At the penalty trial, the prosecution presented evidence that Defendant had murdered her infant daughter several years previously. The jury returned a verdict of death, and the trial court imposed that sentence. On appeal, Defendant raised allegations of error regarding primarily pretrial events, guilt trial issues, and penalty issues. The Supreme Court affirmed the judgment, holding that the circuit court did not reversibly err in its rulings and that Defendant was not deprived of a fair trial in this case. View "People v. Rodriguez" on Justia Law

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After a jury trial, Defendant was convicted of two counts of first degree murder with robbery and multiple-murder special circumstances and sentenced to death. On appeal, the Supreme Court affirmed the judgment in its entirety, holding (1) no error occurred during the selection of the jury; (2) the trial court did not err in its evidentiary rulings; (3) changes in the composition of the jury did not violate Defendants rights to trial by an impartial jury; (4) the trial court did not err in instructing the jury; (5) no error occurred during the penalty phase of the trial; and (6) the aspects of California’s death penalty Defendant challenged did not render it unconstitutional. View "People v. Duff" on Justia Law

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Plaintiffs requested that the State Bar of California provide them access to certain information contained in the State Bar's admissions database, including applicants' grade point averages, race or ethnicity, and bar exam scores. Plaintiffs sought the information to conduct research on racial and ethnic disparities in bar passage rates and law school grades. The State Bar rejected the request. Plaintiffs then filed a petition for writ of mandate in the superior court, seeking to compel the State Bar to provide the records. The trial court concluded that there was no legal basis for requiring disclosure of the admissions database and denied the petition without reaching any issues regarding the privacy of the applicants. The court of appeal reversed. The Supreme Court affirmed and remanded, holding that under the common law right of public access, the State Bar was required to provide access to the information contained in the admissions database if the information could be provided in a form that protected the privacy of applicants and if no countervailing interest outweighed the public's interest in disclosure. View "Sander v. State Bar of Cal." on Justia Law

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After a jury trial, Defendant was convicted of two counts of first degree murder and related crimes. Following a penalty phase trial, the jury returned a verdict of death. The Supreme Court affirmed the judgment, holding, among other things, that (1) Defendant's rights to a speedy trial were not violated; (2) Defendant's Sixth Amendment rights of self-representation and to the assistance conflict-free counsel were not violated during trial; (3) the prosecution did not violate Defendant's due process rights under Brady v. Maryland; (4) the trial court did not improperly admit "inflammatory and damning evidence" that compromised Defendant's ability to receive a fair trial; (5) the prosecutor did not engage in improper misconduct; and (6) the trial court did not prejudicially err in its penalty phase rulings. View "People v. Williams" on Justia Law

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Plaintiffs were five independent retail pharmacies licensed in California, and Defendants were prescription drug claims processors. In 2002, Plaintiffs filed a federal class action suit alleging that Defendants failed to comply with Cal. Civil Code 2527, which requires prescription drug claims processors to compile and summarize information on pharmacy fees and transmit that information to their clients. The district court dismissed the cases for lack of standing without reaching the merits. On appeal, the Ninth Circuit Court of Appeals concluded that Plaintiffs had standing, reversed the district court, and remanded. On remand, Defendants moved for judgment on the pleadings, contending that section 2527 unconstitutionally compels speech in violation of the California and U.S. Constitutions. The district court denied the motions. On appeal, the Ninth Circuit asked the California Supreme Court to answer a question of state law. The Supreme Court answered by holding (1) section 2527 implicates the right to free speech guaranteed by the California Constitution and is subject to rational basis review; and (2) the statute satisfies that standard because the compelled factual disclosures are reasonably related to the Legislature's legitimate objective of promoting informed decisionmaking about prescription drug reimbursement rates. View "Beeman v. Anthem Prescription Mgmt." on Justia Law

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After a jury trial, Defendant was convicted of first degree felony murder and robbery. The jury also sustained a special circumstance allegation of murder in the commission of a robbery. After a penalty trial, the court pronounced a death judgment for the special circumstance murder. Defendant appealed, alleging several trial errors. The Supreme Court affirmed, holding that the trial court did not commit prejudicial error in, among other things, selecting the jury, making its evidentiary rulings, and instructing the jury during both the guilt phase and the penalty phase. The Court also rejected Defendant's attack on California's death penalty law, finding it to be constitutional. View "People v. Contreras" on Justia Law

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After a jury trial, Defendant was convicted of two counts of first degree murder and one count each of attempted murder, aggravated mayhem, and second degree attempted robbery. The trial court sentenced Defendant to death for the two murder convictions. The Supreme Court affirmed, holding (1) the trial court did not err in allowing a certain juror to remain on the jury despite her alleged fear for her safety; (2) Defendant's arguments that the trial court should have granted a new trial and a new penalty phase trial in light of alleged juror misconduct failed; (3) the trial court did not err in excusing for cause three prospective jurors and in failing to remove five prospective jurors for cause; (4) the prosecution did not impermissibly use peremptory challenges to excuse prospective jurors for discriminatory reasons; (5) the trial court did not violate Defendant's constitutional rights by ordering him to wear an electric shock belt during trial; (6) the evidence was sufficient to sustain Defendant's aggravated mayhem conviction; and (7) the trial court did not prejudicially err in instructing the jury. View "People v. Manibusan" on Justia Law

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Defendant was arrested and charged for unlawful transportation of marijuana and unlawful possession of marijuana for purposes of sale. In his defense, Defendant claimed he possessed the marijuana lawfully for purposes of medical treatment. After a jury trial, Defendant was convicted as charged. Defendant appealed, arguing that the evidence at trial was insufficient to establish his intent to sell because the expert who gave his opinion at trial lacked experience distinguishing between lawful possession for medical use and unlawful possession for purposes of sale. The Supreme Court affirmed, holding (1) Defendant forfeited his argument that the expert's opinion was inadmissible because the witness was unqualified by failing to object at trial to the witness's qualifications; and (2) the evidence was sufficient to sustain Defendant's convictions. View "People v. Dowl" on Justia Law