Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeal concluding that Petitioner was entitled to a new bail hearing, holding that the common practice of conditioning freedom solely on whether an arrestee can afford bail is unconstitutional.The trial court set Petitioner's bail at $350,000 without commenting on Petitioner's inability to afford bail. Petitioner filed a petition for writ of habeas corpus claiming that requiring money bail as a condition of release at an amount he could not pay was the functional equivalent of a pretrial detention order and requesting immediate release or a new bail hearing. The court of appeals reversed the bail order because the trial court failed to determine whether Petitioner could feasibly post bail. On remand, the superior court conducted a new bail hearing and ordered Petitioner released on various non-financial conditions. The Supreme Court affirmed, holding (1) where a financial condition is necessary, the court must consider the arrestee's ability to pay the stated amount of bail and may not detain the arrestee solely because the arrestee lacked the resources to post bail; and (2) Petitioner was entitled to a new bail hearing. View "In re Humphrey" on Justia Law

The Supreme Court upheld Senate Bill 1391 as a permissible amendment to Proposition 57 and reversed the judgment in the case, holding that the Legislature acted within its authority.Proposition 57, which was passed in the November 2016 general election, allowed prosecutors to move to transfer some minors as young as fourteen years old from juvenile court to adult criminal court. Senate Bill 1391, enacted in 2018, amended Proposition 57 to prohibit minors under the age of sixteen from being transferred to adult criminal court. The court of appeal held that Senate Bill 1391 was invalid because it was inconsistent with Proposition 57. The Supreme Court reversed, holding that the amendment was fully consistent with and furthered Proposition 57's purposes of promoting rehabilitation of youthful offenders and reducing the prison population, and therefore, Senate Bill 1391 was a constitutional amendment to Proposition 57. View "O.G. v. Superior Court" on Justia Law

The Supreme Court affirmed Defendant's conviction for five counts of murder, one count of residential burglary, and three counts of residential robbery with enhancements for personal use of a firearm and Defendant's death sentence, holding that there was no reasonable possibility that any assumed error could have affected the verdict.Specifically, the Supreme Court assumed potential errors in the trial court's failure to admonish support persons each time they accompanied a witness and in admitting hearsay during the penalty phase of trial. The Court, however, found no reasonable possibility that either assumed error could have affected the verdict. The Court further concluded that no cumulative prejudice rendered Defendant's trial unfair and therefore affirmed Defendant's convictions and his sentence of death. View "People v. Chhoun" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and sentence of death, holding that any errors, found or assumed, were not prejudicial.Specifically, the Supreme Court held (1) at the guilt phase, assuming that the trial court erred in admitting certain DNA evidence, the error was not prejudicial; (2) at the penalty phase, assuming the trial court erred in admitting evidence of potential animal abuse, the error was not prejudicial; (3) any error in imposing a parole revocation fine was harmless; (4) even when viewed in combination, the guilt phase and penalty phase errors were not prejudicial; and (5) the abstract of judgment reflected a clerical error, which will be corrected. View "People v. Baker" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder, attempted murder, and other offenses, and sentencing Defendant to death, holding that any errors that occurred during the trial proceedings were not prejudicial.Specifically, the Supreme Court held (1) during the guilt phase, there was error with respect to the prosecutor's misstatement of the reasonable doubt standard and with respect to defense counsel's agreement with the prosecutor on a certain point of law, but there was no reasonable probability that the prosecutor's or defense counsel's misstatements were prejudicial; (2) at the penalty phase, the prosecutor's comment about Defendant during penalty phase arguments bordered on "inflammatory" rhetoric, but any error was not prejudicial; and (3) the cumulative effect of these errors did not rise to the level of prejudice necessary to reverse Defendant's conviction or sentence. View "People v. Johnsen" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and sentence of death, holding that there was no prejudicial error in the trial proceedings.Defendant was convicted of the first degree murder of San Leandro Police Officer Nels Niemi. The jury returned a verdict of death, and the trial court sentenced Defendant accordingly. The court also ordered Defendant to pay a restitution fine of $10,000. The Supreme Court affirmed, holding (1) there was no error in the guilt phase of the proceedings; (2) there was no cumulative effect of any purported errors occurring at the penalty phase; and (3) the trial court did not violate any statutory or constitutional law by imposing restitution. View "People v. Ramirez" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that William Palmer was entitled to release from all forms of custody, including parole supervision, holding that to the extent Palmer's continued incarceration at some point became constitutionally excessive, that alone did not justify ending his parole under the current statutory scheme.Palmer first sought release on parole in 1995. The Board of Parole Hearings denied parole. Palmer continued to seek release. After the Board's tenth denial, Palmer filed a petition for writ of habeas corpus alleging that the thirty years he had served on a life sentence for an aggravated kidnapping committed when he was a juvenile was constitutionally excessive. The Board subsequently ordered Palmer released on parole. Ruling on Palmer's writ, the court of appeals concluded that Palmer's now-completed term of imprisonment had become unconstitutional and ended his parole. The Supreme Court reversed, holding that, in the absence of any persuasive argument from Palmer that his parole term had become constitutionally excessive, his parole remained valid. View "In re Palmer" on Justia Law

The Supreme Court held that Defendant could be convicted of an attempt to commit trafficking of a minor under Cal. Penal Code 236.1(c) for attempting to recruit as a prostitute "Bella," who was, in fact, an undercover detective.Bella had identified herself to Defendant as a seventeen-year-old girl but was actually an undercover detective. Defendant was convicted of human trafficking of a minor, attempted pimping of a minor, and pandering. The court of appeal reversed Defendant's human trafficking conviction, holding that Defendant could not be convicted under section 236.1(c) but only under the general law of attempt. The Supreme Court reversed and remanded the case, holding that, in light of the statutory language and the state's long-standing application of attempt law, Defendant could be convicted of an attempt under the trafficking statute. View "People v. Moses" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal granting Petitioner's petition for habeas corpus relief on the grounds that the Department of Corrections and Rehabilitation did not have the authority to exclude from nonviolent offender parole consideration inmates with prior sex offense convictions requiring registration, holding that this categorial exclusion violates Cal. Const. art. I, 32.After the electorate approved Proposition 57, the Public Safety and Rehabilitation Act of 2016, Petitioner filed a petition for a writ of habeas corpus challenging the Department's determination that he did not qualify for nonviolent offender parole consideration. The trial court denied the petition. The court of appeal granted habeas relief, holding that the amended regulations improperly excluded Petitioner from nonviolent offender parole consideration based on his two prior sex offense convictions. The Supreme Court affirmed, holding (1) nonviolent offender parole eligibility must be based on an inmate's current conviction; and (2) an inmate may not be excluded from nonviolent offender parole consideration based on a current conviction for a registrable felony offense that the Department's regulations have defined as nonviolent. The Court directed the Department to treat as void and repeal California Code of Regulations, 3491(b)(3) and 3496(b). View "In re Gadlin" on Justia Law

The Supreme Court held that Senate Bill 1437 bars a conviction for second degree murder under the natural and probable consequences theory and that the procedure set forth in Cal. Penal Code 1170.95 is the exclusive mechanism for retroactive relief and that, therefore, the ameliorative provisions of Senate Bill 1437 do not apply to nonfinal judgments on direct appeal.Among other things, Senate Bill 1437 amended Cal. Penal Code 188 to provide that in order to be convicted of murder, a principal in a crime shall act with malice aforethought. At issue in this appeal was the affect of this amendment on the natural and probable consequences doctrine as it applies to second degree murder. The Supreme Court remanded this matter to the court of appeal to affirm Defendant's second degree murder conviction without prejudice to any petition for relief that Defendant may file under section 1170.95, holding (1) section 188(a)(3) bars conviction for second degree murder under a natural and probable consequences theory; and (2) the ameliorative provisions of Senate Bill 1437 do not automatically apply to nonfinal judgments on direct appeal. View "People v. Gentile" on Justia Law