Justia Civil Rights Opinion Summaries

The Supreme Court held that Cal. Labor Code 1102.6 governs whistleblower retaliation claims brought pursuant to Cal. Labor Code 1102.5.Since 2003, section 1102.6 has prescribed a framework for presenting and evaluating retaliation claims brought under section 1102.5. Since 2003, some courts continued to apply the burden-shifting framework borrowed from the decision in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). The trial court granted summary judgment for Defendant on Plaintiff's whistleblower retaliation claim in this case, concluding that Plaintiff could not satisfy the third step of the McDonnell Douglas test. The Ninth Circuit Court of Appeal certified a question regarding the correct standard to the Supreme Court. The Supreme Court answered that section 1102.6 provides the governing framework for the presentation and evaluation of whistleblower retaliation claims brought under section 1102.5. View "Lawson v. PPG Architectural Finishes, Inc." on Justia Law

The Supreme Court affirmed Defendant's convictions for first degree murder and other crimes and Defendant's death sentence, holding that any found or assumed errors were individually harmless and that there was no cumulation of error that merited reversal.Specifically, the Supreme Court found or assumed errors in the admission of prior crimes evidence, a prosecutorial misconduct claim concerning a jury argument that Defendant signed a parole form advising him of a possible life sentence, a claim that the defense was prevented from responding to the prosecutor's argument, a claim that certain expert testimony usurped the trial court's role to instruct the jury about the law, and four additional prosecutorial misconduct claims. The Court held (1) any assumed or actual error in each of these claims was individually harmless; and (2) there was no cumulative error warranting reversal. View "People v. Johnson" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first-degree murder and sentencing him to death, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not commit reversible error when it denied Defendant's request for self-representation under Faretta v. California, 422 U.S. 806 (1975) because the motion was untimely; (2) it was not reasonably probable that the jury would have reached a result more favorable to Defendant but for one improper question posed by the prosecutor to a witness; (3) the trial court did not err when it denied Defendant's motion for a mistrial; (4) admission of certain evidence did not violate Defendant's right to due process or render his trial fundamentally unfair; (5) there was no merit to Defendant's allegations of instructional error; and (6) Defendant's challenges to the death penalty law were unavailing. View "People v. Wright" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and attempted second-degree robbery and sentence of death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) sufficient evidence supported the attempted robbery conviction; (2) the trial court did not err in admitting statements obtained during an undercover operation that law enforcement performed while Defendant was being transported and held in jail; (3) there was no error in the denial of defense counsel's request for a second continuance; (4) a wiretap application at issue in this case was not facially invalid; (5) any violation of Defendant's right to confrontation was harmless; (6) Defendant failed to establish either prosecutorial or judicial misconduct; (7) the trial court did not improperly restrict cross-examination or err in its remaining challenged evidentiary rulings; (8) Defendant failed to establish harmful error as to the admission of his statements at the penalty phase of his statements referencing other crimes; and (9) Defendant's challenges to the death penalty were unavailing. View "People v. Gonzalez" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting Defendant's motion for postconviction discovery under Cal. Penal Code 1054.9 giving Defendant access to the prosecutor's jury selection notes, holding that there was no error.In 1994, Defendant was convicted of capital murder and sentenced to death. Decades later, Defendant filed a habeas corpus petition claiming that the prosecution had used peremptory strikes to discriminate against prospective jurors, in violation of Batson v. Kentucky, 476 U.S. 79 (1986) and People v. Wheeler, 22 Cal.3d 258 (1978). Defendant also filed, in connection with the petition, a motion for postconviction discovery seeking access to the prosecutor's jury selection notes. The trial court granted the motion, and the court of appeal affirmed. The Supreme Court affirmed, holding that the district attorney may not invoke the attorney work product protection to withhold information necessary to the fair adjudication of Defendant's Batson/Wheeler claim. View "People v. Superior Court" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first degree murder, two counts of attempted murder, and possession of a firearm by a felon, holding that there was no reversible error.Specifically, the Supreme Court held (1) the prosecutor's use of a peremptory strike during jury selection prior to the guilt phase did not violate Batson v. Kentucky, 476 U.S. 79 (1986), or People v. Wheeler, 22 Cal. 3d 258 (1978); (2) the trial court did not err in denying Defendant's motion to suppress the gun discovered during a traffic stop; (3) the trial court did not err in admitting hearsay evidence that was the basis for the gang enhancement; (4) there was sufficient evidence to support Defendant's gang enhancement conviction; and (5) the court erred in admitting evidence of the victim's cancer diagnoses during the penalty phase, but there was no reasonable possibility that the victim impact testimony affected the verdict. View "People v. McDaniel" on Justia Law

The Supreme Court vacated the judgment of the court of appeal and its award of costs on appeal, holding that a claim for failure to promote brought under the harassment provision of the Fair Employment and Housing Act (FEHA), Cal. Gov. Code 12940, subd. (j), 12960, accrues, and thus the statute of limitations begins to run, at the point when an employee knows or reasonably should know of the employer's allegedly unlawful refusal to promote the employee.Plaintiff alleged that her employer passed her over for promotions because she refused to have sex with the company's executive vice-president, Michael Kelso. The trial court granted summary judgment for Kelso, finding no triable issue of fact as to Kelso's statute of limitations defense. The court of appeal affirmed the trial court's grant of summary judgment for Kelso and two other defendants and awarded costs on appeal to all three defendants. The Supreme Court reversed, holding (1) the court of appeals erred in concluding that the statute of limitations began to run when Plaintiff's employer offered a promotion to someone else and she accepted it; and (2) the court of appeal erred in awarding costs on appeal to Defendants without first finding that Plaintiff's underlying claim was objectively groundless. View "Pollock v. Tri-Modal Distribution Services, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of one count each of murder and rape and his sentence of death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err in excluding defense evidence relating to third party culpability and victim character; (2) the trial court did not by admitting three photographs of the victim proffered by the prosecutor while excluding a booking photograph of the victim offered by Defendant; (3) the trial court did not abuse its discretion in excluding certain newspaper articles or evidence of other crimes; (4) the trial court did not err in permitting the prosecutor to elicit testimony from Defendant's wife and from the victim's father; (5) assuming the trial court's instruction pursuant to CALJIC No. 2.50.01 was erroneous, there was no prejudice; (6) the trial court did not abuse its discretion in denying Defendant discovery of a witness's medical records; (7) any error in the admission of evidence and regiment regarding Defendant's lack of remorse was harmless; (8) assuming that the prosecutor erred in her penalty phase argument, the error was not prejudicial; and (9) Defendant's challenges to his sentence were unavailing. View "People v. Dworak" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal in this case involving allegations of active gang participation and gang enhancements attached to other offenses, holding that the commission of two or more predicate offenses must be proven by independent admissible evidence, and such proof may not be established solely by the testimony of an expert who has no personal knowledge of facts otherwise necessary to satisfy the prosecution's burden.The two defendants in this case were charged with two counts of attempted murder, assault with a firearm, and active street gang participation. Gang and firearm enhancements were attached to the charges. The first trial ended when the jury hung on almost all charges, but a second jury convicted Defendants of the remaining allegations. The court of appeal reversed the active gang participation and enhancement allegations, as well as Defendant's firearm enhancements attached to those allegations, and otherwise affirmed, holding that some of an expert's testimony constituted inadmissible hearsay. The Supreme Court affirmed, holding (1) the jury was permitted to improperly rely on hearsay to conclude that the predicate offenses had been proven and that Defendants acted with intent to benefit a gang when they committed the crimes with which they were charged; and (2) the error was not harmless. View "People v. Valencia" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of kidnapping and killing Shirley and Andrew Demko after burglarizing and robbing their home, holding that there was no error in the proceedings below.On appeal, Defendant raised numerous allegations of error both during the guilt phase and the penalty phase. The Supreme Court rejected the claims and affirmed the judgment in its entirety, holding (1) the trial court did not err in denying Defendant's Batson/Wheeler motion upon finding that the prosecutor did not make a prima facie showing that the prosecutor exercised a peremptory challenge in a discriminatory manner; (2) assuming, without deciding, that the trial court erred in admitting statements that Defendant identified as implicating prior burglaries, any error was harmless as a matter of law; and (3) there were no penalty phase errors and no cumulative prejudice to consider. View "People v. Battle" on Justia Law