Justia Criminal Law Opinion Summaries

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 vacated the judgment of the court of appeal affirming in part and reversing in part the trial court's denial of Defendant's Proposition 47 petition, holding that the court of appeals did not properly apply this Court's decision in People v. Romanowski, 2 Cal.5th 903 (2017).At issue in this case was how to assess the value of stolen access card information. Defendant was convicted of five counts theft of access card information. Defendant petitioned for Proposition 47 relief seeking resentencing on her convictions on the basis that the value of the property she obtained was not more than $950. The trial court denied relief. The court of appeal reversed as to two convictions and affirmed as to the other three. The court did not engage in the Romanowski inquiry but instead assumed that the value of what Defendant obtained using the stolen information set a floor on the fair market value of the information she unlawfully used. The Supreme Court vacated the judgment and remanded with instructions to send the case back to the trial court for further fact-finding as to the reasonable and fair market value of the access card information at issue, holding that the court of appeal's reasoning fell short of what Romanowski required. View "People v. Liu" on Justia Law

The Supreme Court held that when a law enforcement agency creates a so-called internal Brady list, and a peace officer on that list is a potential witness in a pending criminal prosecution, the agency may disclose to the prosecution the name and identifying number of the officer and that the officer may have relevant exonerating or impeaching material in that officer's confidential personnel file.The "Pitchess statutes" restrict a prosecutor's ability to learn of and disclose certain information regarding law enforcement officers. Some law enforcement agencies created Brady lists enumerating officers that the agencies identified as having potential exculpatory or impeachment information in their personnel filed - i.e., evidence that may need to be disclosed to the defense under Brady and its progeny. Petitioner in this case obtained a preliminary injunction preventing the Los Angeles County Sheriff's Department from disclosing the identity of deputies on the Department's Brady list, but the injunction included and exception permitting disclosure to prosecutors when a deputy is a potential witness in a pending prosecution. The court of appeal concluded that the exception was impermissible under the Pitchess statutes. The Supreme Court reversed, holding that the Pitchess statutes merit such disclosure. View "Association for Los Angeles Deputy Sheriffs v. Superior Court" on Justia Law

The Supreme Court affirmed the decision of the court of appeal affirming Defendant's conviction of attempted kidnapping where Defendant was charged with completed kidnapping, holding that reversal was not warranted by the mere fact that Defendant was charged with completed kidnapping but convicted of attempted kidnapping.In affirming the conviction, the court of appeal cited the Supreme Court's decision in People v. Martinez, 20 Cal.4th 225 (1999), which treated attempted kidnapping as a lesser included offense of completed kidnapping. On appeal, Defendant asked the Court to overrule Martinez and rule that he could not constitutionally be convicted of attempted kidnapping because that offense includes an element that completed kidnapping lacks. The Supreme Court affirmed, holding (1) because attempted kidnapping requires an additional intent element, attempted kidnapping is not a lesser included offense of completed kidnapping; but (2) reversal was not warranted in this case because Cal. Penal Code 1159 states that a defendant may be convicted of an attempt despite being charged only with the completed crime. View "People v. Fontenot" on Justia Law

The Supreme Court reversed the judgment of the court of appeal finding that the trial court's error in permitting the jury to consider a box cutter an inherently deadly weapon was prejudicial, holding that the error was harmless beyond a reasonable doubt.A jury convicted Defendant of assault with a deadly weapon and found true that Defendant personally used a deadly and dangerous weapon. The court of appeal reversed the conviction of assault with a deadly weapon and the true finding on the weapon allegation, finding that the trial court erred in permitting the jury to find the box cutter to be an inherently deadly weapon, and the error required reversal of the conviction. The Supreme Court reversed, holding that the error was harmless beyond a reasonable doubt. View "People v. Aledamat" on Justia Law

The Supreme Court affirmed the decision of the court of appeal affirming the judgment of the trial court denying Defendant's motion to dismiss his recommitment as a mentally disordered offender (MDO) on the basis that the redesignation of his theft offense meant he no longer had a qualifying offense for his MDO recommitment, holding that the applicable statutes did not afford Defendant the relief he sought.Defendant pleaded guilty to one count of felony grand theft. After Defendant had completed his sentence he was admitted to a state hospital as an MDO as a parole condition. Since his initial commitment, Defendant was recommitted as an MDO annually. In 2016, after voters approved Proposition 47, Defendant successfully petitioned to have his felony conviction redesignated as a misdemeanor. Thereafter, Defendant moved to dismiss his recommitment as an MDO, arguing that the redesignation of his theft offense meant he no longer had a qualifying offense for his MDO recommitment. The trial court denied the motion, and the court of appeal affirmed. The Supreme Court affirmed, holding that the redesignation of Defendant's theft offense as a misdemeanor did not undermine the continued validity of his initial commitment or preclude Defendant's continued recommitment as an MDO. View "People v. Foster" on Justia Law

In this appeal concerning a condition of probation requiring Ricardo P. to submit to warrantless searches of his electronics devices the Supreme Court held that the electronics search condition was not reasonably related to future criminality and was therefore invalid under People v. Lent, 15 Cal.3d 481 (1975).In Lent, the Supreme Court held that "a condition of probation which requires or forbids conduct which is not itself criminal is valid if that conduct is reasonably related to the crime of which the defendant was convicted or to future criminality." Ricardo, a juvenile, was placed on probation after admitting two counts of felony burglary. As a condition of his probation, the juvenile court imposed the electronics search. Although there was no indication Defendant used an electronic device in connection with the burglaries, the court imposed the condition in order to monitor Ricardo's compliance with separate conditions. The court of appeals concluded that the condition was unconstitutionally overbroad and should be narrowed but held that the condition was permissible under Lent because it served to prevent future criminality. The Supreme Court disagreed, holding that the electronics search condition was not reasonably related to future criminality. View "In re Ricardo P." on Justia Law

The Supreme Court discharged an order to show cause filed by Petitioner in connection with his petition seeking a writ of habeas corpus, holding that Petitioner failed to meet the applicable standard for relief under any claim raised in his habeas petition and referenced in the Court's order to show cause.Petitioner was convicted of first degree murder and conspiracy to commit murder and to commit assault on correctional staff. The Supreme Court affirmed. While Petitioner's appeal was pending, Petitioner filed a petition seeking a writ of habeas corpus. The Supreme Court found the petition stated a prima facie cause for relief on several claims and issued an order to show cause why relief should not be granted on a subset of the claims raised. The Court then appointed a referee to take evidence and making certain findings of fact. After the referee filed a report, the Court accepted most of the referee's report and findings as supported by substantial evidence and discharged the order show cause, holding that Petitioner failed to meet the standards for habeas relief. View "In re Masters" 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