Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the superior convicting Defendant, following a jury trial, of first degree murder and sentencing him to death, holding that Defendant failed to demonstrate that alleged errors occurring at the guilt phase of trial cumulated in his not having received a "fair trial on the issue of his mental state at the time of the shooting."Specifically, the Supreme Court held (1) the trial court committed error under state law by ordering that Defendant submit to an examination by the prosecution expert and allowing the jury to learn of Defendant's refusal to be examined, but these errors were not prejudicial; (2) the prosecutor's comments regarding the ethics of forensic psychiatry did not infect the trial with unfairness that rose to the level of prejudicial error; (3) the trial court erred in admitting a law enforcement officer's statement under People v. Sanchez, 63 Cal.4th 665 (2016), but the error did not contribute to the jury's verdict; (4) the guilt phase errors were not cumulatively prejudicial; (5) the trial court did not err in excusing a prospective juror for cause because of her views on the death penalty; and (6) no other prejudicial error occurred during the penalty phase of the trial. View "People v. Camacho" on Justia Law

The Supreme Court reversed the judgment of the court of appeal holding that a sidewalk picket purporting to protest a real estate company's business practices after the company evicted two long-term residents from their home did not constitute speech in connection with a public issue under the anti-SLAPP statute's catchall provision, holding that the sidewalk protest constituted protected activity within the meaning of Cal. Code Civ. Proc. 425.16(e)(4).The court of appeal held that the sidewalk picket at issue was beyond the scope of anti-SLAPP protection because the picket did not implicate a public issue. Rather, the court of appeal concluded that the picket concerned only a private dispute between the real estate company and the two residents. The Supreme Court reversed after applying both steps of the analysis set forth in FilmOn.com Inc v. DoubleVerify Inc., 7 Cal.5th 133 (2019), holding that the sidewalk protest furthered public discussion of the public issues it implicated. View "Geiser v. Kuhns" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death but struck the enhancement that Defendant committed the murder for the benefit of, at the direction of, or in association with a criminal street gang, holding that there was no basis for reversing Defendant's convictions or sentence.After a jury trial, Defendant was convicted of first-degree murder. The jury found true the gang enhancement and the special circumstances of robbery murder and torture murder. The jury returned a verdict of death, and the trial court denied Defendant's motions for a new trial, for reduced punishment, and to modify the verdict. The Supreme Court struck the gang enhancement and otherwise affirmed, holding (1) there was assumed or either found error regarding certain jury instructions, the failure to bifurcate, and the admission of hearsay and certain evidence, but each assumed or found error was harmless; (2) Defendant's gang enhancement was incorrectly imposed, but this error did not require reversal of the guilty verdicts or death judgment; and (3) there was no other basis for reversing Defendant's convictions or sentence. View "People v. Tran" on Justia Law

The Supreme Court affirmed Defendant's convictions and life sentences for first-degree murder, robbery, kidnapping, carjacking, and drug-related offenses, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant was not entitled to relief on his claims of error during jury selection; (2) the trial judge was neither biased nor prejudiced against Defendant nor his counsel during voir dire; (3) as to Defendant's claims of error during the guilt phase of his trial, he failed to establish that the trial court committed prejudicial error in its evidentiary rulings; (4) the prosecutor did not commit misconduct rendering Defendant's trial fundamentally unfair; and (5) as to the penalty phase issues raised by Defendant, there was no prejudicial error. View "People v. Ramirez" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, attempted murder, and conspiracy to commit murder and sentencing Defendant to death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the trial court properly excluded two prospective jurors for cause; (2) the "substantial impairment" standard used for determining jury bias in capital cases did not violate Defendant's Sixth Amendment right to an impartial jury; (3) there was no constitutional violation in the denial of Defendant's motion to dismiss the charges against him; (4) there was no error in the court's evidentiary rulings; (5) the trial court erred by failing to provide the jury with a cautionary instructions defining confessions, but the error was harmless; (6) Defendant did not demonstrate any basis for the Court to find error in California's death penalty laws; and (7) a limited remand was appropriate for the sole purpose of allowing the trial court to consider whether to exercise its discretion to strike the prior serious felony enhancement and the firearm enhancements. View "People v. Mataele" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two murders and finding true the special circumstances that one murder occurred during the commission of a robbery, that the other murder involved the killing of a witness and that Defendant had been convicted of multiple murders, and sentencing Defendant to death, holding that no errors required reversal of the judgment.Specifically, the Supreme Court held (1) substantial evidence supported the excusal of juror J.W. for cause; (2) assuming that the trial court erred when it allowed the prosecution to introduce "other acts" evidence at the guilt phase of trial, any error was harmless; (3) assuming that the trial court erred in introducing evidence at the penalty phase regarding Defendant's participation in mutual combat was harmless; and (4) there was no cumulative error requiring reversal of the judgment below. View "People v. Pineda" on Justia Law

The Supreme Court affirmed the order of the trial court entering judgment upon the jury's verdict that Defendant committed first degree murder, robbery, burglary, and firearm possession by a felon and sentencing him to death, holding that while the court committed statutory error, there were no additional errors or rulings that caused Defendant undue prejudice.On appeal, Defendant asserted that several errors in the guilt and penalty phases occurred, resulting in cumulative prejudice warranting reversal of his convictions. The Supreme Court disagreed and affirmed, holding (1) the trial court erred by allowing Defendant to be absent from trial without a written waiver, but the error was not prejudicial; and (2) Defendant failed to identify any other reversible error on appeal. View "People v. Poore" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of first degree murder and the jury's findings of the lying-in-wait special circumstance and the special circumstance allegations that Defendant intentionally killed the victim for financial gain while engaged in the commission or attempted commission of rape, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion by failing to initiate competency proceedings; (2) there was no error in the trial court's evidentiary rulings; (3) sufficient evidence supported the jury's true findings of the special circumstances, and the special circumstances, as applied, are not unconstitutional; (4) there was no instructional error; (5) Defendant's claims of prosecutorial misconduct were without merit; and (6) Defendant's remaining claims of error were unavailing. View "People v. Parker" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of the first-degree murder of his father and the second-degree murders of his stepmother and stepsister and sentencing him to death, holding that Defendant's second-degree murder convictions must be reversed.A federal court vacated Defendant's initial conviction and sentence. After a retrial, Defendant was convicted of first- and second-degree murder, and the jury found true a multiple-murder special-circumstance finding and various firearm- and weapon-use findings. Defendant was sentenced to death. At trial, Defendant's counsel conceded his responsibility for the deaths of all three victims, but Defendant was willing to accept responsibility only for the killing of his father and objected to admitting responsibility for the other two deaths. The Supreme Court held (1) defense counsel violated Defendant's Sixth Amendment rights to choose the fundamental objectives of his defense; and (2) while the error did not affect Defendant's first-degree murder conviction or the associated firearm-use finding, the error requires reversal of the remainder of the judgment and the judgment of death. View "People v. Bloom" on Justia Law

The Supreme Court affirmed the judgment of the the trial court convicting defendants Karl Holmes, Herbert McClain, and Lorenzo Newborn of three counts of murder, five counts of attempted murder, and one count of conspiracy to commit murder and sentencing each defendant to death, holding that no prejudicial error occurred at either stage of the proceedings.After the jury failed to reach a penalty verdict, a new penalty phase was held, and death verdicts were returned against all defendants. On appeal, Defendants asserted several allegations of error argued that the cumulative prejudicial errors in both the guilt and penalty phases of the trials required the reversal of their convictions and sentences. The Supreme Court affirmed, holding (1) in the few instances in which this Court found or assumed error, no prejudice resulted; and (2) whether the claims are considered separately or cumulatively, no prejudicial error occurred. View "People v. Holmes" on Justia Law