Justia Criminal Law Opinion Summaries

These three consolidated cases presented similar issues concerning Proposition 47’s effect on felony-based enhancements in resentencing proceedings under Cal. Penal Code 1170.18.Proposition 47, or the Safe Neighborhoods and Schools Act, reclassified as misdemeanors offenses that were previously felonies or “wobblers” and added section 1170.18, which permits allows defendants previously convicted of felony offenses that Proposition 47 reduced to misdemeanors to petition to have those felony convictions resentenced or redesignated as misdemeanors.The Supreme Court held that Proposition 47’s directive that the resentenced or redesigned offense “be considered a misdemeanor for all purposes” permits defendants to challenge felony-based Cal. Penal Code 667.5 and Cal. Penal Code 12022.1 enhancements when the underlying felonies have subsequently been resentenced or redesignated as misdemeanors.The Court further held that such challenges may be brought in a resentencing procedure under section 1170.18 or may be brought on a petition for writ of habeas corpus, under which instance relief is limited to judgments that were not final at the time the initiative took effect. Finally, those convicted under Cal. Penal Code 1320.5 cannot obtain similar relief. View "People v. Buycks" on Justia Law

After issuing an order to show cause with respect to Petitioner habeas claim that prejudicial juror misconduct occurred when a juror did not timely disclose a history of childhood abuse, the Supreme Court discharged the order to show cause and held that Petitioner was not entitled to relief.Petitioner was convicted of four counts of first degree murder and was sentenced to death. Petitioner then filed this amended habeas corpus petition alleging that the jury foreperson had committed misconduct by concealing that he was abused as a child. The Supreme Court issued an order to show cause and ordered a reference hearing directing a referee to answer four questions. After an evidentiary hearing, the referee found that there was no prejudicial juror misconduct because the juror’s nondisclosure was neither intentional nor deliberate and that juror was not biased against Petitioner.The Supreme Court agreed generally with the referee’s findings and held that Petitioner failed to establish that he was entitled to habeas corpus relief on his claim of prejudicial juror misconduct. View "In re Manriquez" on Justia Law

The Supreme Court reversed the sentence of death imposed in connection with Defendant’s conviction for the first degree murder of a police officer and the attempted murder of a police officer, holding that the trial court, over defense objection, erroneously excused for cause a prospective juror based on his written response to questions about his view on capital punishment, requiring reversal of the penalty verdict.After finding that Defendant did not have an intellectual disability, and following a penalty trial, the jury returned a verdict of death. The trial court imposed a judgment of death after denying the automatic motion to modify the verdict. The court also imposed a prison sentence on the other counts for which Defendant was convicted and enhancement allegations. The Supreme Court held (1) the trial court erred in excusing a prospective juror based on his questionnaire responses, an error that automatically compelled reversal of the penalty phase; and (2) the trial court’s judgment is affirmed in all other respects. View "People v. Woodruff" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of murdering James Madden and sentencing Defendant to death.On appeal, Defendant raised a number of issues, most of which focused on purported errors made by the trial court. Defendant also took issue with the Supreme Court’s decision not to supplement the appellate record with the trial transcripts of his codefendants and also challenged the constitutionality of California’s death penalty scheme. The Supreme Court affirmed the judgment of the trial court in its entirety, holding that there was no reversible error in this case. View "People v. Spencer" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendants Joseph Adam Mora and Ruben Rangel of two counts of murder and two counts of attempted robbery and sentencing Defendants to death.On appeal, Defendants argued that several errors during the guilt and penalty phases of their trial warranted reversal of their convictions. The Supreme Court disagreed with the exception of a guilt phase instructional error. The Court held (1) the trial court erred by permitting the jury to find the multiple murder special circumstance try without finding that either defendant intended to kill or actually killed either victim, but the error was harmless; and (2) no error or assumed error, whether considered separately or collectively, merited reversal. View "People v. Mora" on Justia Law

The Supreme Court affirmed, as modified, the judgment of the trial court convicting Defendant of first degree murder, conspiracy to commit robbery and burglary, and two counts of residential burglary, including the judgment of death, and modified the judgment by striking a one-year enhancement the trial court imposed for the finding that Defendant had served one prior prison term.The Supreme Court held that no prejudicial error occurred during the guilt phase of trial or the penalty phase of trial, with the exception of the one-year enhancement for the prior prison term, holding that because the prison term was served for two of the convictions for which the Court also enhanced the sentence, the enhancement for the prior prison term must be stricken. View "People v. Anderson" 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.Defendant was convicted of first-degree murder for killing his girlfriend’s twenty-one-month-old granddaughter, assault resulting in the death of a child under eight years old, and committing lewd and lascivious conduct on a child under the age of fourteen. The Supreme Court affirmed, holding (1) the admission of testimony from child witnesses was not in error and did not violate Defendant’s due process rights; (2) the evidence was sufficient to support Defendant’s murder conviction; (3) the trial court did not err in admitting evidence of a witness’s broken leg; (4) the trial court did not improperly coerce a death verdict; (5) the trial court’s response to a jury question, coupled with the prosecutor’s argument, did not allow the jury to consider inadmissible evidence during its penalty determination; (6) the prosecutor did not commit error under Griffin v. California, 380 U.S. 609 (1965); and (7) the admission of rebuttal character evidence was not in error. View "People v. Lopez" on Justia Law

The Supreme Court reversed the decision of the court of appeal interpreting Cal. Civ. Code 3531 as authorizing a court to declare Cal. Penal Code 31910(b)(7)(A) unenforceable when a complainant alleges, and the court finds, that complying with the statute is impossible.Penal Code 31910(b)(7)(A) amended the definition of unsafe handguns under the Unsafe Handgun Act to include semiautomatic pistols that are not equipped with with dual placement microstamping. National Shooting Sports Foundation, Inc. (NSSF) filed a complaint seeking declaratory and injunctive relief, alleging that dual placement micro stamping technology was impossible to implement and, therefore, Penal Code 31910(b)(7)(A) was unenforceable on the basis of Civil Code 3531’s declaration that “[t]he law never requires impossibilities.” The court of appeals held that NSSF may present evidence of impossibility and that the judiciary may invalidate Penal Code 31910(b)(7)(A) if compliance is shown to be impossible. The Supreme Court reversed, holding that Civil Code 3531’s maxim that "[t]he law never requires impossibilities” is an interpretive aid that occasionally authorizes an exception to a statutory mandate in accordance with the Legislature’s intent behind the mandate and has never been recognized, nor will it be recognized in this case, as a ground for invalidating a statutory mandate altogether. View "National Shooting Sports Foundation, Inc. v. State" on Justia Law

A jailer’s authority “to set a time and place for the appearance of the arrested person” under Cal. Penal Code 1269b(a) makes that appearance “lawfully required” for purposes of forfeiting bail under Cal. Penal Code 1305, former subdivision (a)(4), under which a court may declare the bail forfeited if a defendant fails to appear on “[a]ny other occasion prior to the pronouncement of judgment if the defendant’s presence in court is lawfully required.”Based on a criminal defendant’s failure to personally appear for a pretrial conference, the trial court ordered her bail forfeited. The court then granted summary judgment on the forfeited bond and sent a demand for payment to Financial Casualty & Surety, Inc. Financial Casualty moved to set aside summary judgment on the ground that the defendant was not ordered to appear at the hearing. The trial court granted the motion. The Court of Appeal affirmed. The Supreme Court reversed, holding that the defendant’s obligation to appear to the hearing was “lawfully required” under section 1305 because, when she was released on bond, the jailer set the time and place for her next appearance, as authorized under section 1269b(a). View "County of Los Angeles v. Financial Casualty & Surety, Inc." on Justia Law

At issue was how to assess the validity of a stipulation entered into by Defendant, through counsel, that admitted all of the elements of a charged crime, making it tantamount to a guilty plea, when Defendant was neither advised of, nor expressly waived, his privilege against self-incrimination or his rights to a jury trial and confrontation.The Supreme Court reversed the court of appeal’s judgment affirming Defendant’s conviction of misdemeanor driving when his driver’s license was suspended or revoked. The Court held (1) the test set forth in People v. Howard, 1 Cal.4th 1132 (1992), that a plea is valid notwithstanding the lack of express advisements and waivers if the record affirmatively shows that it is voluntary and intelligent under the totality of the circumstances applies in cases where there is a total absence of advisements and waivers; and (2) applying that test, the record failed affirmatively to show that Defendant understood his counsel’s stipulation had the effect of waiving Defendant’s constitutional rights. View "People v. Farwell" on Justia Law