Justia Civil Rights Opinion Summaries

Petitioner was convicted in 1997 for the murder of his wife. Petitioner subsequently sought habeas corpus relief, stating that his murder conviction was based on false evidence given at trial by the prosecution's dental expert. The dental expert stated that he had testified inaccurately at trial. Other dental experts agreed that the expert had testified inaccurately based on newly available computer technology. After an evidentiary hearing, the superior court granted habeas corpus relief. The court of appeals disagreed. At issue on appeal was whether a conviction is based on "false evidence" when it depends in part on the opinion of an expert witness, and posttrial advances in technology have raised doubts about the expert's trial testimony without conclusively proving that testimony to be untrue. The Supreme Court affirmed, holding (1) in such circumstances the expert's trial testimony was not shown to be "false evidence," but the information garnered from technological advances could be presented as newly discovered evidence in support of habeas corpus relief; and (2) habeas corpus relief should be granted only if the new evidence points unerringly to innocence or reduced culpability, a showing that Petitioner did not make. View "In re Richards" on Justia Law

Defendant was convicted on two counts of possessing a firearm after conviction of a felony in violation of Cal. Penal Code 12021(a)(1) and two counts of possession a firearm after conviction of a specified violent offense in violation of Cal. Penal Code 12021.1(a). All four counts were based on Defendant's simultaneous possession of two firearms. The court of appeal reversed Defendant's section 12021.1(a) convictions, finding that violent offender in possession under section 12021.1(a) was a necessarily included offense of offender in possession under section 12021(a)(1). The Supreme Court reversed, holding (1) Defendant was properly convicted of both offenses because neither section 12021.1(a) nor section 12021(a)(1) is a necessarily included offense of the other; and (2) Defendant may be separately punished for two violations of section 12021(a)(1) and of section 12021.1(a) based on his simultaneous possession of two firearms, but he may not also be separately punished for violations of section 12021(a)(1) and section 12021.1(a) based on possession of the same firearm. Remanded. View "People v. Sanders" on Justia Law

While in Defendant's care, Defendant's young son died of shock and hemorrhage due to blunt force trauma. A jury convicted Defendant of involuntary manslaughter and assault on a child causing death. As relevant here, the court of appeal reversed the conviction upon finding the trial court erroneously failed to instruct the jury, sua sponte, on simple assault as a lesser included offense. The Supreme Court reversed and remanded with directions to reinstate the conviction, holding that the trial court had no sua sponte duty to instruct on that lesser offense, as (1) such instructions are required only when there is substantial evidence that, if the defendant is guilty at all, he is guilty of the lesser offense, but not the greater; and (2) here, it would be speculative at best to construe the trial evidence in this case as supporting a verdict of only simple assault. View "People v. Wyatt" on Justia Law

Prison regulations promulgated by the California Department of Corrections and Rehabilitation (CDCR) provide that validation of an inmate as a gang member or associate can result in the inmate's placement in a security housing unit. The current dispute arose when the CDCR validated Petitioner as a gang associate. Petitioner filed a petition for writ of habeas corpus, which the superior court denied. The court of appeal granted relief based on a disagreement with the CDCR over the interpretation of the CDCR's regulation. The Supreme Court reversed, holding that the court of appeal failed to accord due deference to the CDCR's interpretation of its own regulations. View "In re Cabrera" on Justia Law

Defendant was charged with murder, pled not guilty, and also raised an insanity defense. At the guilt phase trial, the prosecutor requested a jury instruction that Defendant was conclusively presumed to have been sane at the time of the offense. Defendant objected that the instruction might lead the jury to disregard the evidence of his mental illness and its effect on the intent required for murder. The court overruled the objection, gave the instruction on the presumption of sanity, and refused Defendant's request for an instruction on the legal definition of sanity. The jury convicted Defendant of first degree murder. The court of appeal affirmed. The Supreme Court affirmed, holding (1) although Defendant established no due process violation, the instruction was erroneous under state law, as the question of a defendant's sanity is entirely irrelevant at the guilt phase of a bifurcated trial under Cal. Pen. Code 1026; but (2) the error was harmless in this case. View "People v. Mills" on Justia Law

Defendant and Codefendant were charged with murdering two men by running over each of them with a car. The prosecution's theory was that one of the two victims had been drugged before he was killed. To prove this point, the prosecution presented the testimony of a laboratory director who, relying on reports not prepared by him, testified that testing of the victim's blood samples by analysts at his laboratory had determined the presence of drugs that could have caused drowsiness. According to Defendant, that testimony violated her Sixth Amendment right to confront and cross-examine the analysts who had tested the blood samples. The jury found both Defendant and Codefendant guilty of two counts of first degree murder and two counts of conspiracy to commit murder. The court of appeal affirmed, holding that even if there was a confrontation right violation, the error was not prejudicial. The Supreme Court affirmed, holding that in light of the overwhelming evidence against Defendant, exclusion of the laboratory director's trial testimony would, beyond a reasonable doubt, not have affected the outcome of Defendant's trial. View "People v. Rutterschmidt" on Justia Law

Defendant was charged with vehicular manslaughter while intoxicated after her vehicle collided with another, killing its driver. To prove intoxication, the prosecution at trial introduced into evidence a laboratory analyst's report on the percentage of alcohol in a blood sample taken from Defendant two hours after the accident. The analyst did not testify, but a colleague did. A jury found Defendant guilty as charged. The court of appeal reversed, holding that the admission of the nontestifying analyst's laboratory report and the colleague's testimony relating some of the report's contents violated Defendant's right to confront and cross-examine the report's author. The Supreme Court reversed, holding that the nontestifying analyst's laboratory report was not testimonial in nature, and the trial court did not err in permitting the prosecution to introduce that portion of the report into evidence, and in permitting the colleague to testify regarding it. View "People v. Lopez" on Justia Law

At Defendant's murder trial, a forensic pathologist testifying for the prosecution described to the jury objective facts about the condition of the victim's body as recorded in the autopsy report and accompanying photographs. Based on those facts, the expert gave his independent opinion that the victim had died of strangulation. Neither the autopsy report, which was prepared by another pathologist who did not testify, nor the photographs were introduced into evidence. The court of appeal reversed Defendant's conviction for second degree murder, holding that the expert's testimony violated Defendant's Sixth Amendment right to confront and cross-examine the preparer of the autopsy report, and that the error was prejudicial. The Supreme Court reversed, holding that the trial court did not err in admitting the expert's testimony over a Confrontation Clause objection, as the statements of the preparer of the autopsy report were not testimonial, and the Confrontation Clause did not bar their use. View "People v. Dungo" on Justia Law

This case involved the second habeas corpus petition filed by Petitioner, who was sentenced to death. The petition was an "exhaustion petition," which sought to exhaust state claims in order to raise them in federal court. Nearly all of Petitioner's claims raised legal issues that were not cognizable or were procedurally barred. The Supreme Court denied the writ after taking the opportunity to establish new ground rules for exhaustion petitions in capital cases, holding (1) this petition exemplifies abusive writ practices; and (2) following finality of this opinion, exhaustion petitions in capital cases will be subject to the page limits and other rules described in this opinion.

In People v. Carmony (Carmony II), a decision of the California court of appeal concluded that a twenty-five-year-to-life sentence under the Three Strikes law constituted cruel and/or unusual punishment as applied to a defendant whose triggering offense was the failure to annually update his sex offender registration within five working days of his birthday. In the present habeas corpus proceeding, the court of appeal, considering the constitutionality of a twenty-five-year-to-life sentence imposed upon Defendant, who also was convicted of failing to update his sex offender registration within five working days of his birthday, expressly disagreed with the conclusion of the appellate court in Carmony II and held that the punishment was constitutionally permissible. The Supreme Court affirmed on other grounds, holding that Defendant's sentence here did not constitute cruel and unusual punishment under the circumstances of this case, but this holding did not rest upon a determination that Carmony II was wrongly decided.