Applies and follows controlling authority without revisiting, as in Hawthorne (Atkins retroactive) and Wright (imperfect self-defense limits). In Re Hawthorne ↗ People v. Wright ↗
Deference to government powerSkepticism of government power
In this case, a jury convicted the defendant of two robberies and a murder committed during the second robbery, along with firearm enhancements and a robbery-murder special circumstance, leading to a death sentence on automatic appeal. The court reviewed the guilt-phase evidence, including victim and accomplice testimony detailing the crimes, as well as challenges to jury selection procedures under People v. Wheeler. The court affirmed the convictions and sentence, finding sufficient evidence supported the verdicts and no reversible error in the trial court's handling of peremptory challenges or other procedural matters.
Plaintiffs, a fisherman and two vessel companies from Rhode Island, sued federal defendants including the Secretary of Commerce and NOAA agencies in the District of New Jersey, challenging an administrative law judge's decision that imposed fines and revoked fishing permits for alleged violations including fishing without a permit. Defendants moved to dismiss for improper venue under 28 U.S.C. § 1391(e) or to transfer the case, arguing that no events occurred in New Jersey, defendants reside in Washington D.C., and plaintiffs reside in Rhode Island. The court determined that venue was improper in New Jersey because a substantial part of the events did not occur there and neither party resided in the state. It denied the motion to dismiss without prejudice but granted transfer to the District of Columbia under 28 U.S.C. § 1406(a), where venue was proper and the parties had agreed to litigate.
The case involved defendant Mary Ellen Samuels, who was convicted by a jury of first-degree murders of her ex-husband Robert Samuels and James Bernstein, as well as soliciting and conspiring to commit those murders. The jury found true special circumstances of financial gain and multiple murders, and it returned death verdicts for each count; the trial court imposed the death sentence after denying post-trial motions. On automatic appeal, the California Supreme Court affirmed the judgment in its entirety, upholding the convictions, special circumstances, and penalty based on the evidence of solicitation, financial benefits received by the defendant, and trial procedures.
The case involved defendant Carmen Lee Ward, who was charged with the first-degree murders of two individuals and the attempted murder of a third, along with related enhancements and a multiple-murder special circumstance. After severing the charges, separate juries convicted him of second-degree murder in one case and first-degree murder plus attempted murder in the other, and found true a prior murder conviction special circumstance, leading to a death sentence. The California Supreme Court reviewed the automatic appeal and found no reversible error in the guilt or penalty phases, affirming the judgment in full, including the death penalty.
The case involved a registered sex offender charged with willfully failing to update his registration within five working days of his birthday under Penal Code section 290, subdivision (a)(1)(D). The defendant claimed severe depression caused him to forget the deadline, seeking to introduce evidence that this condition negated the willfulness element of the felony offense. The California Supreme Court held that the willfulness requirement may be negated only by evidence of an involuntary condition that deprived the defendant of actual knowledge of the duty to register, but only the most disabling conditions, such as severe Alzheimer's disease or trauma-induced amnesia, would qualify. Defendant's depression did not meet this standard because he knew of his obligation and could have discharged it, so the evidence was properly excluded and the conviction affirmed.
The case involved a California resident filing a class action lawsuit against several Nevada hotels, alleging they violated consumer protection laws by imposing an undisclosed energy surcharge on guests after quoting a lower room rate during reservations made by phone from California. The hotels moved to quash the summons, arguing lack of personal jurisdiction because they had no physical presence, employees, or bank accounts in California. The trial court granted the motion, but the Court of Appeal reversed, holding that the hotels' extensive advertising in California media, interactive website accepting reservations, toll-free number, and significant business from California residents established sufficient minimum contacts for specific jurisdiction. The court reasoned that these activities showed purposeful direction toward California, that the surcharge claims arose directly from those contacts, and that exercising jurisdiction would be fair and reasonable.
