Justia Civil Rights Opinion Summaries

Victor Raul Tellez was charged with three counts of lewd or lascivious acts upon a child and faced a maximum prison term of 12 years. On the advice of his attorney, he accepted a plea deal, pleading guilty to one count and receiving a three-year prison sentence. Tellez was not informed that his conviction would make him eligible for civil commitment as a sexually violent predator (SVP) under the Sexually Violent Predator Act (SVPA). After completing his prison term, the District Attorney initiated SVPA proceedings for his involuntary commitment to a state hospital.Tellez filed a petition for writ of habeas corpus in the San Diego County Superior Court, claiming ineffective assistance of counsel for not being advised of the SVPA consequences. The superior court denied his petition, and the Court of Appeal also denied it, stating that prevailing norms did not require such advisement and that Tellez had not demonstrated prejudice. Tellez then petitioned the California Supreme Court for review.The California Supreme Court held that Tellez did not sufficiently demonstrate he was prejudiced by his counsel’s failure to advise him of the SVPA consequences. The court noted that Tellez provided insufficient evidence that he would not have accepted the plea deal had he been informed of the SVPA consequences. Therefore, the court did not address whether his counsel’s performance was constitutionally deficient. However, recognizing the significant liberty deprivation involved in SVPA commitments, the court exercised its supervisory powers to require trial courts to inform defendants of potential SVPA consequences when pleading guilty or no contest to a qualifying offense. The judgment of the Court of Appeal was affirmed on the ground that Tellez had not demonstrated prejudice. View "In re Tellez" on Justia Law

The case involves Nicholas Needham, who was referred for evaluation as a possible Sexually Violent Predator (SVP) under the Sexually Violent Predator Act (SVPA) after serving his prison term for certain sex offenses. Two evaluators initially determined that Needham had a mental disorder making him likely to engage in sexual violence unless civilly committed. However, before the probable cause hearing, one evaluator changed his opinion, leading to the appointment of two other evaluators. One of these evaluators concluded that Needham qualified as an SVP, while the other did not. The trial court found probable cause to believe Needham was an SVP and ordered a trial.The People retained Dr. Craig King as an expert and sought discovery of Needham's evaluations and records. The trial court granted the request and ruled that Dr. King could interview and test Needham. Needham filed motions to preclude Dr. King from testifying at trial, which were denied. Needham sought a writ of mandate/prohibition to prevent Dr. King from conducting any further interviewing or testing and from testifying at trial. The Court of Appeal granted Needham's writ petition and directed the trial court to exclude Dr. King's testimony. The People petitioned for review from that ruling.The Supreme Court of California held that, under the SVPA, the People may call their retained expert to testify at trial, both to contest the testimony of other witnesses and to offer an independent opinion as to whether the defendant qualifies as an SVP. However, the People's retained expert may not compel a defendant to be interviewed or participate in testing before trial. The court reversed the Court of Appeal's contrary judgment and remanded the case for trial. View "Needham v. Superior Court" on Justia Law

In May 2019, police officers detained Marlon Flores in a Los Angeles neighborhood known for narcotics and gang activity. The officers observed Flores standing alone near a parked car, ducking behind it as they approached. The officers suspected Flores was involved in narcotics activity due to his behavior and the area's reputation. During a pat-down search, the officers found a drug pipe in Flores's car and methamphetamine in his wallet. Flores was subsequently charged with carrying a loaded firearm and armed possession of methamphetamine.The trial court denied Flores's motion to suppress the evidence, reasoning that his behavior was suspicious enough to warrant detention and subsequent questioning. Flores pleaded no contest to the firearm charge, and the methamphetamine charge was dismissed. He was sentenced to three years' probation. The Court of Appeal affirmed the judgment, concluding that Flores was not detained until he was ordered to stand and put his hands behind his head, and that reasonable suspicion justified the detention.The Supreme Court of California reversed the lower courts' decisions. The court held that the officers' observations of Flores's behavior, combined with his presence in a high crime area at night, did not provide a particularized and objective basis for suspecting that Flores was engaged in illegal activity. The court emphasized that a person's mere presence in a high crime area cannot transform them into a suspect. The court concluded that the officers lacked reasonable suspicion to detain Flores, and thus, the evidence obtained during the pat-down search should have been suppressed. The case was remanded to the trial court to allow Flores to withdraw his no contest plea and for the court to grant Flores's suppression motion. View "P. v. Flores" on Justia Law

In 2019, the California Supreme Court ruled that the defendant, Oscar Manuel Vaquera, did not receive fair notice of the sentence that the prosecution was seeking in his case, which violated his right to due process. Vaquera was charged with two counts of a sex offense covered by California's "One Strike" law and was convicted on both counts. In the habeas corpus proceeding, Vaquera challenged the 25-year-to-life sentence the trial court imposed for the second count.The prosecution had initially requested a sentence of 15 years to life for the second count, but later argued for a 25-year-to-life sentence under a different provision of the One Strike law. Vaquera contended that the imposition of the 25-year-to-life sentence violated due process because he did not receive fair notice that the prosecution intended to seek that sentence. The California Supreme Court agreed with Vaquera and ordered the trial court to resentence him to 15 years to life for the second count.The Court ruled that the One Strike allegation in Vaquera's case did not provide him with fair notice that the prosecution was seeking a 25-year-to-life sentence under the specific provision of the law based on the victim's age. The Court held that due process requires an accusatory pleading to inform the defendant of the particular One Strike sentence the prosecution is seeking and of the factual basis it intends to prove to support that sentence. In this case, the prosecution did not provide fair notice of its intent to seek the longer One Strike sentence, which violated Vaquera's due process rights. View "In re Vaquera" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Petitioner's petition for relief and resentencing under the new procedure set forth in Senate Bill No. 1437 (former Cal. Penal Code 1170.95, subd. (a); now Cal. Penal Code 1172.6, subd. (a)), holding that the trial court erred.Petitioner was convicted of first degree murder and sentenced to life imprisonment without the possibility of parole. Twelve years later, the Legislature enacted Senate Bill 1437 narrowing or eliminating certain forms of accomplice liability for murder. Petitioner petitioned for relief and resentencing under the new procedure, but the trial court denied the petition for failure to state a prima facie case. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court erred in rejecting Petitioner's prima facie showing and should have proceeded to an evidence hearing on Petitioner's resentencing petition. View "People v. Curiel" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court determining that because of racially polarized voting, the at-large method of election had impaired Latino voters' ability to elect candidates of their choice or to influence the outcome of an election, holding that the court of appeal misconstrued the California Voting Rights Act of 2001 (CVRA), Cal. Elec. Code 14025 et seq.The trial court in this case concluded that the at-large method of electing city council members in the City of Santa Monica diluted Latinos' ability to elect their preferred candidates and their ability to influence the outcome of council elections and, as a remedy, ordered the City to conduct a special election using a map drafted by an expert who testified at trial. The court of appeal reversed. The Supreme Court reversed and remanded the case, holding (1) a court presented with a dilution claim should undertake a searching evaluation of the totality of the facts and circumstances; and (2) remand was required for the court of appeal to evaluate the dilution standard of the CVRA under this standard. View "Pico Neighborhood Ass'n v. City of Santa Monica" on Justia Law

The Supreme Court reversed the judgment of the court of appeal that a Department of Insurance regulation prohibiting bail bond agents from entering into agreements with jail inmates to be notified when individuals have recently been arrested and thus may be in need of bail bond services was facially invalid under the First Amendment, holding that the court of appeal erred in holding that the regulation was unconstitutional on its face.In declaring the regulation constitutionally invalid the court of appeal concluded that the regulation imposed burdens on the free speech rights of bail bond agents that were not adequately justified by the State's interests in deterring abusive bail solicitation practices. The Supreme Court reversed, holding that the regulation burdened a protected speech right, that intermediate scrutiny applied, and that the regulation passed constitutional muster. View "People v. Martinez" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the trial court's judgment concluding that the at-large method of electing city council members in the City of Santa Monica diluted Latino voters' ability to elect their preferred candidates and their ability to influence the outcome of council elections, holding that the court of appeals misconstrued the California Voting Rights Act of 2001, Cal. Elec. Code 14025 et seq. (CVRA).The superior court ruled in favor of Plaintiffs on their claims that the racially polarized voting in the City violated the CVRA. The superior court ruled in favor of Plaintiffs and ordered the City to conduct a special election using a seven-district map drafted by an expert who testified at trial. The court of appeal reversed, concluding that there had been no dilution of Latino voters' ability to elect their preferred candidates or their ability to influence the outcome of the election. The Supreme Court reversed, holding (1) a court presented with a dilution claim should undertake a searching evaluation of the totality of the facts and circumstances; and (2) because the court of appeal did not evaluate the dilution element of the CVRA under the proper standard, remand was required. View "Pico Neighborhood Ass'n v. City of Santa Monica" on Justia Law

The Supreme Court held that an employer's business entity agents can be held directly liable under the California Fair Employment and Housing Act (FEHA), Cal. Gov. Code 12900 et seq., for employment discrimination in appropriate circumstances when the business entity agent has at least five employees and carries out activities regulated by FEHA on behalf of an employer.Plaintiffs, on behalf of themselves and an alleged class, brought this action alleging claims under the FEHA, the Unruh Civil Rights Act, unfair competition law, and the common law right of privacy. Plaintiffs named as a defendant U.S. Healthworks Medical Group (USHW), who was acting as an agent of Plaintiffs' prospective employers. The district court dismissed all claims, concluding, as relevant to this appeal, that the FEHA does not impose liability on the agents of a plaintiff's employer. The federal district court of appeals certified a question of law to the Supreme Court, which answered that FEHA permits a business entity acting as an agent of an employer to be held directly liable as an employer for employment discrimination, in violation of FEHA, when the business entity has at least five employees and carries out FEHA-regulated activities on behalf of an employer. View "Raines v. U.S. Healthworks Medical Group" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming Defendant's conviction of first-degree murder, holding that when the record contains substantial evidence of imperfect self defense, the trial court's failure to instruct on that theory amounts to constitutional error and is subject to review under the federal Chapman standard. See Chapman v. California, 386 U.S. 18 (1967).On appeal, Defendant argued that the trial court committed harmful error in denying his request for an instruction on imperfect self-defense. The court of appeals affirmed, concluding that the trial court erred but that the error was subject to the "reasonable probability" standard for evaluating prejudice set forth in People v. Watson, 46 Cal.2d 818 (1956) and that Defendant suffered no prejudice. The Supreme Court reversed, holding (1) the form of misconstruction in this case precluded the jury from making a finding on a factual issue necessary to establish the element of malice, thus qualifying as a federal error; and (2) the court of appeal's harmless error analysis did not comport with the standards for evaluating prejudice under Chapman. View "People v. Schuller" on Justia Law