Justia Civil Rights Opinion Summaries

Defendant was charged with murder and use of a deadly weapon. The trial court gave instructions on first and second degree murder, as well as voluntary manslaughter based upon a sudden quarrel or heat of passion. The jury found Defendant guilty of second degree murder with a use enhancement. The court of appeal reversed Defendant's conviction, concluding that the voluntary manslaughter instruction was prejudicially erroneous. The Supreme Court reversed after clarifying what kind of provocation will suffice to constitute heat of passion and reduce a murder to manslaughter, holding (1) provocation is adequate only when it would render an ordinary person of average disposition "liable to act rashly or without due deliberation and reflection, and from this passion rather than judgment; and (2) although the jury instruction properly conveyed the standard for determining heat of passion, the argument of counsel may have introduced ambiguity, but the jury asked a clarifying question, and the trial court's response dispelled any confusion. Remanded. View "People v. Beltran" on Justia Law

After a jury trial, Defendant was convicted of several offenses, including robbery and theft. The convictions stemmed from Defendant's acquisition of gift cards through his false representation that he was using valid payment cards to purchase the gift cards. Defendant challenged his robbery convictions, contending that the type of theft that constitutes a "felonious taking," an element of robbery, was theft by larceny only and not theft by false pretenses, the type of theft that Defendant committed. The court of appeal affirmed Defendant's robbery convictions, holding that theft by false pretenses can satisfy the "felonious taking" requirement of robbery. The Supreme Court reversed, holding that theft by false pretenses cannot satisfy the "felonious taking" element of robbery. Remanded. View "People v. Williams" on Justia Law

After a jury-waived trial, Defendant was convicted of first degree murder. The court found true the special circumstance that the killing was intentional and that Defendant knew or should have known the victim was a peace officer engaged in the performance of duty. After a penalty jury returned a death verdict, Defendant was sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) Defendant's counsel did not labor under a conflict of interest or provide ineffective assistance; (2) the evidence supporting the special circumstance finding that Defendant intentionally killed a police officer engaged in the performance of duty was legally sufficient; (3) a certain juror was not biased on the issue of penalty; (4) substantial evidence supported the race-neutral reasons given by the prosecutor for his excusal of African-American prospective jurors; (5) the trial procedures did not deny Defendant reliable determinations of death eligibility and of the appropriate penalty; and (6) California's death penalty statute is not unconstitutional. View "People v. Mai" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, two counts of attempted murder, and of committing forcible rape, sodomy, and oral copulation. Following a penalty trial, Defendant was sentenced to death. The Supreme Court affirmed in all respects, holding (1) the trial court did not err in its pretrial rulings contested by Defendant; (2) the trial court did not err in its rulings made during the guilt phasel; (3) the trial court did not err when instructing the jury during the guilt phase; (4) the trial court did not err during the penalty phase of the trial; and (5) having found no legal error, Defendant's claim that the cumulative effect of all errors required reversal was rejected. View "People v. Jones" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, unlawful taking of a vehicle, and arson. The jury returned a verdict of death. The trial court sentenced Defendant to death on the murder count and imposed a determinate sentence on the remaining counts and enhancements. The Supreme Court affirmed, holding, (1) the trial court properly denied Defendant's motions for a change of venue; (2) the trial court did not err in its rulings regarding the selection of the jury; (3) the trial court did not prejudicially err in its decisions during the guilt phase of trial; (3) the trial court did not prejudicially err in its decisions during the penalty phase of trial; and (4) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Harris" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. The jury also found true the special circumstance allegations of burglary-murder and torture-murder. After the jury was unable to agree on a sentence, the trial court declared a mistrial. At the second penalty phase trial, the trial court entered a judgment of death. The Supreme Court affirmed, holding (1) the trial court did not commit prejudicial error in its rulings regarding pretrial issues; (2) the trial court did not prejudicially err in its rulings during the guilt phase of trial; and (3) the trial court did not prejudicially err in its rulings during the second penalty phase. View "People v. Edwards" on Justia Law

Kevin Reilly was originally committed as a sexually violent predator (SVP) in 2000. In 2008, the Secretary of the Department of Corrections and Rehabilitation sought a petition for recommitment. Two evaluators evaluated Reilly under the Sexually Violent Predator Act (SVPA) and concluded he was an SVP. The Office of Administrative Law subsequently determined that the initial evaluations supporting the petition were conducted under an assessment protocol that amounted to an invalid regulation. The evaluators subsequently re-evaluated Reilly based on In re Ronje, this time concluding that he no longer met the criteria for commitment as an SVP. The court of appeal subsequently dismissed the SVPA commitment petition based on Ronje, which ordered replacement evaluations in these circumstances without requiring a determination that the underlying mistake in the assessment protocol amounted to material error. The Supreme Court reversed, holding (1) the Ronje decision was error; (2) an alleged SVP must show that any fault that did occur under the assessment protocol contained a material error; and (3) the court of appeal erroneously dismissed the petition against Reilly without requiring a finding of material error. View "Reilly v. Superior Court of Orange County" on Justia Law

Sheriff's deputies came to the home of Shane Hayes in response to a call from a neighbor. When the deputies arrived, Hayes's girlfriend informe them that Hayes was suicidal. The deputies then entered the house, where Hayes came toward them with a large knife raised in his right hand. The deputies simultaneously drew their guns and fired at Hayes, who died from the gunshot wounds. Hayes's daughter filed a complaint in federal district court against the County of San Diego and the deputies, alleging three federal law claims and two state law claims. The district court granted summary judgment for Defendants on all claims, finding that the deputies owed Plaintiff no duty of care with respect to their preshooting conduct. The Ninth Circuit Court of Appeals asked the California Supreme Court to answer a question of state law. The Court answered by holding that, under California negligence law, liability can arise from tactical conduct and decisions employed by law enforcement preceding the use of deadly force if the conduct and decisions leading to the use of deadly force show, as part of the totality of the circumstances, that the use of deadly force was unreasonable. View "Hayes v. County of San Diego" on Justia Law

Pursuant to the terms of a plea bargain, Defendant, who was an eighteen-year-old citizen of Mexico at the time, pleaded guilty to the sale or transportation of marijuana. After completing his probation, Defendant sought an adjustment in status to lawful permanent residency. Defendant's application was denied because of his conviction, and removal proceedings were initiated against him. Defendant filed a motion to vacate his conviction pursuant to Cal. Penal Code 1016.5, asserting that had he known the immigration consequences of pleading guilty, he would have rejected the plea offer. The only issue adjudicated at the hearing on Defendant's motion was whether he would have received a more favorable outcome had he rejected the plea bargain. The trial court denied the motion without considering the possibility Defendant might have rejected the plea bargain even if it were not reasonably probable he would have received a more favorable outcome. The Supreme Court reversed, holding (1) relief is available under section 1016.5 if the defendant establishes he would have rejected the existing bargain to accept or attempt to negotiate another; and (2) the trial court applied the incorrect test for prejudice in this case. Remanded. View "People v. Martinez" on Justia Law

After a jury trial, Defendant, an alleged member of the Mexican Mafia, was convicted of the first degree murders of three adults and two children. The jury also found true multiple-murder special-circumstance and weapon use sentence enhancement allegations. Defendant was sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in its rulings and decisions prior to trial; (2) the evidence was sufficient to support Defendant's convictions and the multiple-murder special-circumstance true finding; (3) the trial court did not err in the remainder of its rulings during the guilt phase of Defendant's trial; (4) the trial court did not engage in judicial misconduct during either the guilt phase or the penalty phase; (5) the prosecutor did not commit prejudicial misconduct during closing argument; (6) the trial court did not err in the remainder of its rulings during the penalty phase; and (7) California's death penalty statute is not constitutionally invalid. View "People v. Maciel" on Justia Law