Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder and arson of property. The jury found true the special circumstance that Defendant was previously convicted of first degree murder. The trial court imposed the death sentence for the murder. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not err in granting the prosecution's challenge for cause against a prospective juror; (2) the trial court did not err in admitting evidence of two uncharged murders; (3) the jury was properly instructed regarding flight; (4) the prior-murder-conviction special circumstance was valid; (5) the trial court did not err in its penalty phase rulings; and (6) Defendant's challenges to California's death penalty failed. View "People v. Rogers" on Justia Law

Defendant was charged with sale and possession for sale of a controlled substance. At trial, evidence showed that the pills contained 3,4-methylenedioxymethamphetamine (MDMA). The court of appeal affirmed, holding that although there was not a stipulation or expert testimony showing that MDMA met the definition of a controlled substance or controlled substance analog within the Health and Safety Code, the name supported the inference that the pills contained some quantity of methamphetamine or amphetamine. The Supreme Court reversed, holding that evidence of MDMA's chemical name, standing alone, was insufficient to prove the material is a controlled substance where MDMA is not listed in the Code. View " People v. Davis" on Justia Law

Defendant was charged with committing four lewd acts upon his niece. Before trial, the prosecution offered evidence under Cal. R. Evid. 1108 that Defendant had sexually abused his sister when Defendant was nearly fourteen. Defendant opposed the prosecutor's motion, arguing that the evidence should be excluded because, as a minor under the age of fourteen, he was presumed incapable of committing a crime. The court allowed the evidence. During trial, the trial court did not give an instruction directing the jury to assess Defendant's capacity to commit the offense admitted under section 1108 under Cal. Penal Code 26(1). The jury convicted Defendant on all counts. The court of appeal reversed, holding that the trial court erred by not sua sponte instructing the jury that the prosecution must prove by clear and convincing evidence that Defendant appreciated the wrongfulness of his conduct admitted under section 1108. The Supreme Court reversed, holding (1) proof was required that Defendant knew the conduct at issue was wrongful and was thus capable of committing a crime; and (2) the trial court was not required to sua sponte instruct the jury to consider Defendant's age at the time of his act admitted under section 1108. Remanded. View "People v. Cottone" on Justia Law

After a jury trial, Defendant was convicted of resisting an executive officer in the performance of his duties pursuant to Cal. Penal Code 69. Defendant appealed, arguing that the trial court erred by denying his request to instruct the jury that it could instead convict him of the lesser offense of resisting a public officer under Cal. Penal Code 148(a)(1). The Supreme Court affirmed, holding (1) section 148(a)(1) was a necessarily included lesser offense of section 69 as alleged in the amended information; but (2) because substantial evidence did not reveal Defendant violated section 148(a)(1) without also violating section 69, the trial court did not err in refusing to instruct the jury on section 148(a)(1). View "People v. Smith" on Justia Law

Defendants were part of a Bakersfield gang and were involved in various retaliatory shootings against perceived rivals. After a jury trial, Defendants were convicted of, inter alia, first degree murder with multiple-murder and gang-murder special circumstances, active gang participation, and conspiracy. The conspiracy count alleged that each Defendant had engaged in conspiracy to commit felony assault, robbery, murder, and gang participation. The court of appeals affirmed the conspiracy convictions, holding that conspiracy to actively participate in a criminal street gang did not qualify as a crime, but each conspiracy count was also based on the valid theory of conspiracy to commit murder. The Supreme Court reversed, holding that that a defendant may conspire to actively participate in a criminal street gang and may be separately charged once a conspirator has committed an overt act. Remanded. View "People v. Johnson" on Justia Law

Plaintiff, a nonprofit public benefit corporation that was granted a charter in 2003 to serve Los Angeles County, had its charter revoked by the County Board of Education in 2007. Plaintiff appealed, contending that the revocation proceedings violated due process and revocation was not based on substantial evidence. The State Board of Education affirmed the revocation. The trial court issued a writ setting aside the revocation of the charter, finding that Plaintiff was not afforded a hearing before an impartial adjudicator because the County Board has an interest in ensuring that funds flowing to charter schools are reallocated to other public schools. The court of appeal reversed. The Supreme Court affirmed, holding that the school failed to establish that the Legislature's chosen procedures denied it the opportunity to be heard at a "meaningful time and in a meaningful manner" by a decision maker without financial or other bias. View "TodayÂ's Fresh Start, Inc. v. Los Angeles County Office of Educ. " on Justia Law

At issue in this case was the database of information about land parcels in a geographic information system (GIS) file format maintained by Orange County and whether it was subject to disclosure at the actual cost of duplication under the California Public Records Act (PRA) or whether it was covered by the PRA's exclusion of "computer software" from the definition of a public record. Sierra Club requested a copy of the OC Landbase pursuant to the PRA. The County agreed to produce the records but refused to provide the records in GIS format unless Sierra Club paid a licensing fee and agreed to the license's restrictions on disclosure and distribution. Sierra Club subsequently sought a writ of mandate to compel the County to provide the OC Landbase in a GIS file format as a public record with no requirement that Sierra Club comply with the licensing agreement. The superior court denied the petition for writ of mandate, concluding that the OC Landbase in GIS file format was excluded from the PRA's general rules of disclosure. The Supreme Court reversed, holding that GIS-formatted databases like the OC Landbase are public records that must be produced upon request at the actual cost of duplication. View "Sierra Club v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of possession of cocaine and resisting a peace officer. On appeal, Defendant argued that the trial court committed reversible error when, after finding the prosecution improperly used a peremptory challenge to discharge a prospective juror under People v. Wheeler, it reseated the juror instead of discharging the entire jury venire. The court of appeal agreed, finding that Defendant did not consent to the court's remedy of reseating the juror, therefore reversing Defendant's conviction. The Supreme Court reversed, holding (1) in the context of a trial court's order to reseat an improperly discharged prospective juror after the court granted the complaining party's Wheeler motion, the complaining party's assent to reseating the improperly discharged juror can be found on the basis of implied consent; and (2) in this case, Defendant did impliedly consent to the alternative remedy of reseating the juror. View "People v. Mata" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, kidnapping for child molestation, forcible rape, sodomy, and committing a lewd and lascivious act upon a child under fourteen. Prior to sentencing, the trial court ordered a new trial based on juror misconduct. On retrial, the second jury found Defendant guilty of the same charges. The trial court imposed a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not prejudicially err in its rulings during the guilt phase, sanity phase, and penalty phase of trial; (2) California's death penalty scheme and related jury instructions do not violate the United States Constitution; (3) the trial court did not prejudicially err in sentencing Defendant; and (4) the cumulative effect of the trial court's few errors did not warrant reversal. View "People v. DeHoyos" on Justia Law

After a jury trial, two defendants (Defendants) were convicted of the first degree murders of two people. The jury found true special circumstance allegations of multiple murder and sentence enhancement allegations that Defendants committed the murders to benefit a criminal street gang and used firearms to commit them. The trial court sentenced Defendants to death. The Supreme Court vacated one multiple-murder special-circumstance finding for each defendant and the true findings for the street gang and fire use enhancements, holding (1) the trial court erred in instructing the jury pertaining to the gang enhancement allegations, and the error was prejudicial; (2) the sentence enhancement allegations for personal firearm use must also be vacated because those findings depended on the jury first finding true the gang enhancement allegations; and (3) the trial court erred in allowing the jury to make multiple-murder special-circumstance findings as to each count of murder. View "People v. Nunez" on Justia Law