Justia Criminal Law Opinion Summaries

The Supreme Court reversed the decision of the court of appeal affirming the trial court's judgment convicting Defendant of loitering for purposes of prostitution, holding that the court of appeal erred in ruling that trial courts retain authority to deny a continuance unsupported by good cause even if the decision will foreseeably result in the case's dismissal for lack of evidence.Defendant filed a motion to suppress, but the prosecutor orally requested a continuance on the date of the suppression hearing due to the unavailability of a witness. The trial court denied the motion for a continuance for lack of good cause and then granted Defendant's motion to suppress. Upon reconsideration, however, the trial court vacated its prior orders and denied the suppression motion. Defendant ultimately agreed to a "slow plea." The court of appeals affirmed, holding that the trial court did not err in reconsidering its continuance and suppression rulings. The Supreme Court reversed the court of appeal's decision but affirmed Defendant's conviction, holding (1) the principles set forth in People v. Ferguson, 218 Cal.App.3d 1173 (1990), apply when the People are unable to proceed with a hearing on a suppression motion; and (2) the trial court's denial of Defendant's suppression motion "reposed within the court's sound discretion." View "People v. Brown" on Justia Law

The Supreme Court reversed the judgment of the court of appeal denying Petitioner's petition for writ of habeas corpus, holding that the Attorney General has both a constitutional and an ethical duty to disclose evidence in response to a petition for writ of habeas corpus alleging a Brady violation under certain circumstances.In her habeas petition, Petitioner asserted that the People had suppressed evidence at trial in violation of Brady v. Maryland, 373 U.S. 83 (1963), that would have supported her claim of self-defense. The court of appeal concluded that the evidence was not material under Brady and denied the habeas petition. In her petition for review, Petitioner argued that the Attorney General violated her due process rights by suppressing the same evidence that had formed the basis of her Brady claim. The Supreme Court reversed, holding (1) the respondent to a petition for a writ of habeas corpus alleging a Brady violation has a duty to disclose evidence forming the basis of the Brady claim under certain circumstances; and (2) remand for further proceedings was appropriate in this case. View "In re Jenkins" on Justia Law

The Supreme Court reversed Defendant's conviction of the first-degree murder of her newborn daughter by poison, holding that the jury instructions were erroneous and that the error was prejudicial.At issue was whether there is a mental state component of first degree poison murder when there is no question that the defendant acted with willfulness, deliberation, and premeditation. The Supreme Court held (1) to prove first degree murder by means of poison, the prosecution must show that the defendant deliberately gave the victim poison with the intent to kill the victim or inflict injury likely to cause death; and (2) the trial court's instructions erroneously did not include this element of first degree poison murder, and the error was prejudicial, requiring remand. View "People v. Brown" on Justia Law

The Supreme Court remanded this case to the circuit court after the court found that Defendant inflicted "great bodily injury," holding that the sentencing court's finding of great bodily injury violated Defendant's Sixth Amendment jury trial rights under Apprendi v. New Jersey, 530 U.S. 466 (2000).Defendant was charged with assault by means of force likely to produce great bodily injury and other related crimes. The jury found Defendant guilty of assault, battery, and participating in a street gang and deadlocked on the remaining counts. During sentencing, the court imposed a five-year enhancement, concluding that Defendant's charges were serious felonies because there was "great bodily injury." After he appealed, Defendant sought a writ of habeas corpus, arguing that appellate counsel provided ineffective assistance by failing to challenge the great bodily injury finding. The Supreme Court reversed, holding that the sentencing court's finding of great bodily injury did not violate Defendant's Sixth Amendment right to a jury trial under Apprendi in light of the jury's failure to reach a verdict on great bodily injury allegations. View "In re Cabrera" on Justia Law

The Supreme Court reversed the judgment of the court of appeal in this criminal case, holding that the evidence a law enforcement officer found after his illegal detention of Defendant was not admissible.The officer in this case was responding to a report of suspicious activity in the area when he unlawfully detained Defendant, who was "hanging out" in his car reclining in the passenger seat. The officer ran a records check and learned that Defendant was on active and searchable parole. The officer proceeded to search Defendant and his vehicle, finding firearm- and drug-related evidence. Defendant moved to suppress the ensuing charges against him, arguing that his detention violated the Fourth Amendment. The trial court denied the motion, and the court of appeal affirmed. The Supreme Court reversed, holding that the officer's discretionary decision to conduct the parole search of Defendant did not sufficiently attenuate the connection between the officer's initial unlawful decision to detain Defendant and the later discovery of contraband. View "People v. McWilliams" on Justia Law

The Supreme Court held that Proposition 36, the Three Strikes Reform Act of 2012, did not change the law and strip sentencing courts or their discretion to impose concurrent terms for felonies that were committed on the same occasion or arose from the same set of operative facts, even if the felonies qualified as serious or violent.At issue was whether the Reform Act abrogated the rule in People v. Hendrix, 16 Cal.4th 508, 512 (Hendrix), that a court may impose concurrent sentences in cases falling under the "Three Strike" sentencing scheme. The Supreme Court held (1) following Proposition 36, the court retained its Hendrix concurrent sentencing discretion; and (2) the total sentence imposed for multiple counts of serious or violent felonies "must be ordered to run consecutively to the term imposed for offenses that do not qualify as serious or violent felonies." The Court therefore reversed the judgment of the court of appeals concluding that it lacked discretion to impose concurrent terms on multiple serious or violent felonies after passage of the Reform Act. View "People v. Henderson" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the decision of the trial court denying Defendant's motion to vacate his conviction, holding that holding that the court of appeals erred in ruling that Defendant failed adequately to corroborate his claim that immigration consequences were a paramount concern and thus that Defendant could not demonstrate prejudice within the meaning of Cal. Penal Code 1473.7.In 2004, Defendant, a native of Mexico, accepted a plea bargain and served one year in jail. In 2015, Defendant was detained by federal immigration authorities after a return flight to the United States, and his permanent residence card was seized. In his his third motion to vacate his conviction, Defendant argued that he had not been aware of the immigration consequences of his plea and that, had he been aware, he would have sought a plea with lesser consequences or gone to trial. The trial court denied the motion without holding an evidentiary hearing. The Supreme Court reversed, holding that, under the totality of the circumstances, there was a reasonable probability that Defendant would have rejected the plea had he understood its immigration consequences. View "People v. Espinoza" on Justia Law

The Supreme Court affirmed Defendant's conviction for the first degree murder of Rafael Noriega and his sentence of death, holding that there was no reversible error in the proceedings below.A jury convicted Defendant of first degree murder and found true the special circumstance allegation that the murder was committed while Defendant was engaged in the commission of a robbery. The jury also found true the special circumstance allegation that Defendant was previously convicted of murder. The jury returned a verdict of death, and the trial court denied Defendant's ensuing motion for modification of his sentence. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant's right to self-representation in its rulings regarding Defendant's funding requests; (2) there was no error or abuse of discretion in the district court's evidentiary rulings; (3) Defendant's challenges to the special service allegations were unavailing; (4) there was no error in the jury instructions; (5) there was no error or abuse of discretion during the penalty phase; and (6) Defendant's challenges to the constitutionality of California's death penalty law failed. View "People v. Thomas" on Justia Law

The Supreme Court reversed Defendant's conviction for three counts of first degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request.Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless. View "People v. Waldon" on Justia Law

The Supreme Court held that a law enforcement officer's act of shining a spotlight for illumination does not ipso facto constitute a detention under the Fourth Amendment, but rather, the proper inquiry requires consideration of the totality of the circumstances, including the use of the spotlight.Defendant was charged with drug offenses after a law enforcement officer conducted a search of the car he was driving. At issue was whether the officer engaged in a consensual encounter when he pulled behind Defendant's car and turned on his spotlight. The court of appeal concluded that spotlight illumination and approach on foot did not "manifest a sufficient show of police authority to constitute a detention." The Supreme Court agreed, holding (1) under the totality of the circumstances, Defendant was not detained by the officer's use of a spotlight; and (2) remand was appropriate for a new factual finding as to whether the officer's detention of the vehicle's female passenger effectuated a detention of Defendant. View "People v. Tacardon" on Justia Law