Justia Civil Rights Opinion Summaries

After police seized a package from FedEx and discovered marijuana inside, Petitioner, who went to FedEx to claim the package, was arrested with possession of marijuana for sale and with the sale or transportation of marijuana. The superior court denied Petitioner's motion to suppress evidence, concluding that exigent circumstances justified the seizure, and the subsequent search was valid under the inevitable discovery doctrine. The court of appeal granted Petitioner's petition for writ of mandate and ordered the superior court to grant the motion to suppress, holding that the inevitable discovery doctrine did not apply to the facts in this case, that exigent circumstances did not justify the subsequent search of the container, and that the odor of contraband alone cannot justify a warrantless search. The Supreme Court affirmed in part, holding (1) a container's mobility may constitute exigent circumstances sufficient to justify a warrantless seizure, but it cannot alone justify a search of the container once it has been seized; and (2) the District Attorney forfeited his argument that the plain smell of marijuana constituted an exception to the warrant requirement. View "Robey v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, residential burglary, attempted rape, and a forcible lewd act on a child under the age of fourteen. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment of the trial court, holding, inter alia, (1) the trial court did not prejudicially err in its guilt phase evidentiary rulings; (2) the trial court did not unfairly frustrate defense efforts to present a defense establishing Defendant was coerced into making false admissions and a confession; (3) the trial court did not err in failing to excuse a certain juror for misconduct; (4) the trial court did not deprive Defendant of his ability to present a penalty phase defense and to establish lingering doubt as a mitigating factor by refusing to allow Defendant to call certain witnesses and restricting certain testimony; (5) the trial court did not err in allowing the admission of photographs of the victim and testimony as victim impact evidence; (6) Defendant's claims of prosecutorial misconduct were either not preserved for appeal or meritless; and (7) California's death penalty is not unconstitutional. View "People v. Linton" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, assault by means of force likely to produce great bodily injury and/or with a deadly weapon, and first-degree residential burglary. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not err in its rulings surrounding jury selection issues; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) the evidence was sufficient to support Defendant's conviction of first-degree murder; (4) the prosecutor did not commit misconduct during closing argument; (5) the trial court did not prejudicially err in instructing the jury during the guilt phase; (6) the trial court did not prejudicially err in its rulings during the penalty phase; (7) California's death penalty statute is not unconstitutional; and (8) Defendant was not cumulatively prejudiced. View "People v. Lopez" on Justia Law

After a second jury trial, Defendant was convicted of one count of attempted mayhem and two counts of assault with a firearm. Defendant appealed, contending that the trial court erred in instructing the jury that a gunshot wound may constitute a "serious bodily injury" for purposes of the offense of attempted mayhem. The court of appeal reversed the attempted mayhem conviction, holding that the trial court erred in giving the instruction because the instruction suggested to the jury that Defendant could be found guilty of attempted mayhem if it found Defendant merely intended to inflict a gunshot wound rather than intending to inflict a wound that would seriously impair the victim's physical condition. The Supreme Court reversed, holding (1) the pattern jury instruction on mayhem improperly requires proof of a "serious bodily injury"; but (2) assuming the trial court erred in giving the instruction in this case, the error was harmless. View "People v. Santana" on Justia Law

After a jury trial, Defendant was convicted of second degree murder. The court of appeal reversed the murder conviction, concluding that the trial court erred by failing to sua sponte instruct the jury on voluntary manslaughter as a lesser included offense of murder on the theory that Defendant killed without malice in the commission of an inherently dangerous assaultive felony. The Supreme Court reversed, holding that because a killing without malice in the commission of an inherently dangerous assaultive felony is not voluntary manslaughter, the trial court could not have erred in failing to instruct the jury that it was. View "People v. Bryant" on Justia Law

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 that although the jury instruction properly conveyed the standard for determining heat of passion, the argument of counsel may have introduced ambiguity. However, the jury asked a clarifying question, and the trial court's response dispelled any confusion. View "People v. Beltran" on Justia Law

After a jury trial, Petitioner was convicted of two counts of first degree murder and of being a felon in possession of a firearm. Following the penalty phase of trial, the jury sentenced Petitioner to death. The Supreme Court affirmed. While Petitioner's appeal was pending, Petitioner also filed a petition for writ of habeas corpus. Having found the petition stated a prima facie case for relief on several claims of alleged juror misconduct, the Supreme Court issued an order to show cause why relief should not be granted. After an evidentiary hearing, a referee filed his report. The Supreme Court accepted the referee's report and findings as supported by substantial evidence, discharged the order to show cause, and denied relief, holding (1) there was no substantial likelihood that one juror was biased against Petitioner for failing to disclose certain personal information; and (2) the record rebutted the presumption of prejudice that arose from two other jurors' misconduct. View "In re Boyette" on Justia Law

The Service Employees International Union, Local 721 (SEIU) was the exclusive bargaining representative of all Los Angeles County employees. SEIU proposed amending the memorandum of understanding it had with the County's bargaining units to enable SEIU to obtain the home addresses and phone numbers of all represented employees, including those who had not joined the union. The County rejected the amendment. The Los Angeles County Employee Relations Commission concluded that the County's refusal to provide the contact information was an unfair labor practice. The superior court denied the County's petition for relief. The appellate court affirmed but held that nonmember employees were entitled to notice and an opportunity to opt out before their contact information could be disclosed to SEIU. The Supreme Court affirmed but reversed the court of appeal's imposition of procedural requirements limiting disclosure, holding (1) although the County's employees have a cognizable privacy interest in their home addresses and telephone numbers, the balance of interests strongly favors disclosure of this information to the union that represents them; and (2) procedures may be developed for employees who object to this disclosure, but the court of appeal exceeded its authority by attempting to impose specific procedures on the parties. View "County of Los Angeles v. Los Angeles County Employee Relations Comm'n" on Justia Law

After a jury trial, Defendant was convicted of first degree murder under the special circumstances of kidnapping- and robbery-murder, of kidnapping, and of robbery. The jury also found Defendant personally used a firearm in committing each crime. The trial court imposed a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not prejudicially err in denying Defendant's motion to change venue; (2) the trial court did not err with regard to jury selection issues; (3) the trial court did not err with regard to guilt and special circumstance issues; (4) the trial court did not err with regard to certain penalty issues; and (5) not giving criminal defendants the right to take depositions does not violate equal protection. View "People v. Rountree" on Justia Law

After a jury trial, Defendant was found guilty of attempted voluntary manslaughter and assault with a firearm. Defendant waived a jury trial on the prior conviction allegations and admitted having suffered a prior serious felony conviction. Defendant informed the court, however, that the prior conviction had been reduced to a misdemeanor. The court sentenced Defendant to a total term of twenty-four years, which included a five-year sentence enhancement under Cal. Penal Code 667(a) based on Defendant's previously having been convicted of a serious felony. The court of appeal upheld imposition of the five-year enhancement, concluding that the prior assault remained a serious felony conviction for purposes of section 667(a), notwithstanding its having been reduced to a misdemeanor pursuant to Cal. Penal Code 17(b)(3) in 2006 and thereafter dismissed altogether. The Supreme Court reversed the judgment of the court of appeal insofar as it upheld imposition of a five-year sentence enhancement pursuant to section 667(a), holding that when the court in the prior proceeding reduced the assault conviction to a misdemeanor, that offense no longer qualified as a prior serious felony within the meaning of section 667(a), and could not be used to enhance Defendant's sentence. Remanded for resentencing. View "People v. Park" on Justia Law