Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant was not entitled to relief on his allegations of error.Defendant was convicted of first degree murder with special circumstances of murder in the commission of forcible sodomy, murder in the commission of a lewd act on a child, and murder by torture. The trial court sentenced Defendant to death. On appeal, Defendant asserted multiple claims of error. The Supreme Court affirmed, holding (1) there was no prejudicial error during the guilt phase of trial; and (2) the only errors committed during the penalty phase were two instances of prosecutorial misconduct in argument to the jury, and these errors were not prejudicial either individually or cumulatively. View "People v. Rhoades" on Justia Law

The Supreme Court reversed the opinion of the court of appeal reversing the judgment of the trial court ruling that the search of Defendant's car was invalid on the basis that the search was authorized under In re Arturo D., 27 Cal.4th 60 (Cal. 2002), holding that the desire to obtain a driver's identification following a traffic stop does not constitute an independent, categorical exception to the Fourth Amendment's warrant requirement, and to the extent Arturo D. held otherwise it should no longer be followed.Acting on a tip about Defendant's erratic driving, a police officer approached Defendant after she parked and exited her car. The police detained Defendant for unlicensed driving and, without asking her name, searched the car for Defendant's personal identification. The trial court held that the search was invalid under Arizona v. Gant, 556 U.S. 332 (2009). The Court of Appeals reversed, holding that the search was authorized under the Supreme Court's pre-Gant decision in Arturo D. The Supreme Court reversed, holding that the warrantless search of Defendant's vehicle in this case violated the Fourth Amendment. View "People v. Lopez" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of two counts of first-degree murder and related crimes and sentencing Defendant to death for each of the murder convictions, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) there was substantial evidence to support the trial court's denial of Defendant's Batson/Wheeler challenge; (2) as to the admission of Defendant's confession, the investigator should have stopped the interrogation on April 21, 1999 sooner than he did, but the error did not compel the exclusion of the confession obtained on April 22, 1999 or thereafter; (3) Defendant's arguments involving testimony of Defendant's volitional impairment did not require reversal of the death sentence; (4) the trial court did not err in admitting testimony by Defendant's former girlfriend, a photograph of Defendant, and evidence that Defendant lied about shooting a person; and (5) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Krebs" on Justia Law

The Supreme Court disapproved the lead opinion in People v. Ray, 21 Cal.4th 464 (1999), in which the Court articulated a "community caretaking" exception to the warrant requirement for government entry into a private residence, holding that such an entry for reasons short of a perceived emergency, or similar exigency, fails to satisfy the relevant constitutional standard.Defendant was charged with manufacturing a controlled substance and firearm-related charges. Defendant filed a motion to suppress the evidence found in his home. The trial court denied the motion. Defendant later pleaded guilty. The court of appeal affirmed, concluding that, even in the absence of exigency, the warrantless entry of Defendant's home was justified under the "community caretaking" exception. The Supreme Court reversed, holding that the community caretaking exception asserted in the absence of exigency is not one of the carefully delineated exceptions to the residential warrant requirement recognized by the United States Supreme Court. View "People v. Ovieda" on Justia Law

The Supreme Court answered a question regarding California's Unruh Civil Rights Act, Cal. Civ. Code 51 et seq., by holding that a plaintiff has standing to bring a claim under the Act when the plaintiff visits a business's website with the intent of using its services and encounters terms and conditions that allegedly deny the plaintiff full and equal access to the website's services and then leaves the website without entering into an agreement with the service provider.Plaintiff sued Defendant, alleging that Defendant's seller agreement discriminated against him in violation of the Act. The district court dismissed the complaint on the ground that Plaintiff lacked standing under the Act to sue Defendant because Plaintiff had not attempted to use Defendant's services. On appeal, the United States Court of Appeals for the Ninth Circuit issued the certification order at issue in this case. The Supreme Court held that, under the rule announced today, Plaintiff sufficiently alleged injury for Unruh Civil Rights Act standing because entering into an agreement with the business is not required for standing under the Act. View "White v. Square, Inc." on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and sentence of death, holding that there was no error in the proceedings below that entitled Defendant to reversal of his convictions.Specifically, the Court held (1) both prongs of Cal. Const. art. I, 28(d)'s requirement were met in this case, and allowing the jury to judge the relevant evidence did not violate Defendant's due process rights; (2) a witness's decision not to testify, upheld by the court, did not deny Defendant the right to present a defense; (3) the state and federal constitutions supported the trial court's decision to grant the witness her Fifth Amendment privilege; (4) Defendant's challenges to California's death penalty law were unavailing; and (5) Defendant failed to establish cumulative error because there were no errors to aggregate. View "People v. Capers" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeal concluding that the anti-SLAPP statute, Cal. Code Civ. Proc. 425.16, cannot be used to judicially screen claims alleging discriminatory or retaliatory employment actions, holding that the statute contains no exception for discrimination or retaliation claims.Plaintiff alleged that Defendant, his employer, ultimately fired him for unlawful discriminatory and retaliatory reasons. Defendant, a news organization, filed an anti-SLAPP motion. The trial court granted the motion, concluding that Plaintiff had not shown any of his claims had minimal merit. The court of appeal reversed, concluding that discrimination and retaliation do not qualify as protected activity, and therefore, the anti-SLAPP statute did not apply. The Supreme Court reversed in part, holding (1) in cases alleging discrimination or retaliation claims in the employment context, the plaintiff's allegations about the defendant's invidious motives will not shield the claim from the same preliminary screening for minimal merit that would apply to any other claim arising from protected activity; and (2) Defendant showed that Plaintiff's claims arose in limited part from protected activity, and therefore, Defendant was entitled to a determination of whether those limited portions of Plaintiff's claims had sufficient potential merit to proceed. View "Wilson v. Cable News Network, Inc." on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and his sentence of death, holding that none of Defendant's challenges to his convictions and death sentence warranted reversal.Defendant was one of three members of a gang who were charged with the murders of Michael Faria and Jessica Salazar. This automatic appeal concerned only Defendant. The Supreme Court affirmed Defendant's conviction of two counts of first degree murder and death sentence, holding (1) any error in allowing a gang expert to testify was harmless; (2) the trial court did not err in declining to exclude two portions of a jailhouse conversation Defendant had with a friend; (3) there was sufficient evidence to support a finding that Defendant shot Faria; (4) the trial court did not abuse its discretion in limiting the cross-examination of a certain witness; (5) the trial court did not abuse its discretion in admitting a photograph depicting Faria's body; (6) the victim impact evidence admitting in this case was within the bounds of what precedents permit; and (7) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Mendez" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder, with the special circumstance that the murder was committed during a rape, and Defendant's sentence of death holding that there was no prejudicial error in the proceedings below.Specifically, the Court held (1) the victim's brother testified at the penalty phase in contravention of a court order, but any prejudice was cured by the trial court's admonition and by other evidence undermining the significance of Defendant's assertions; (2) any assumed error in failing to instruct at the guilt phase on a good faith but unreasonable belief in consent to intercourse was not prejudicial; and (3) Defendant offered no compelling reasons for the Court to reconsider its precedent rejecting Defendant's constitutional challenges to California's death penalty scheme. View "People v. Molano" on Justia Law

The Supreme Court affirmed Defendant's convictions for three counts of first degree murder and three counts of first degree attempted murder arising from two shootings committed by Defendant on the same day and Defendant's sentence of death, holding that only one error occurred during the proceeding, and the error was harmless beyond a reasonable doubt.Specifically, the Court held (1) none of Defendant's claims of error at the guilt phase had merit, and therefore, there was no cumulative error requiring reversal of his convictions; and (2) during the penalty phase, the trial court erred in failing to instruct the jury that a witness's prior conviction of a felony bore on his credibility, but the error was harmless, and therefore, there was no cumulative error requiring reversal of Defendant's penalty of death. View "People v. Mitchell" on Justia Law