Janice Rogers Brown

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.

criminal lawprocedure

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.

procedurefederal power

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.

criminal law

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.

criminal law

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.

criminal law

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.

procedurebusiness & regulatory

The case involved defendant Daryl Randle, who was convicted of murder after shooting Brian Robinson, who was beating Randle's cousin during a confrontation over stolen property. Randle claimed he fired to protect his cousin from what he believed was imminent deadly harm, though the belief may have been unreasonable. The California Supreme Court held that the doctrine of imperfect defense of others applies in California, meaning that a killing committed with an actual but unreasonable belief in the need to defend another from death or great bodily injury constitutes voluntary manslaughter rather than murder because it negates the malice required for murder. The court reasoned by analogy to the established imperfect self-defense doctrine, concluding that the same principles of reduced culpability should extend to defense of others. The matter was remanded for further proceedings consistent with this holding.

criminal law

The case involved defendant Donald Thomas Wright, who was convicted of murdering his neighbor Eddie Sanchez after shooting him in the Sanchez home without any preceding argument or threat. Wright sought to rely on the doctrine of imperfect self-defense, claiming an actual but unreasonable belief in the need for self-defense based on delusions or hallucinations stemming from mental illness or intoxication, without objective circumstances indicating a threat. The California Supreme Court granted review to determine whether to extend imperfect self-defense to such delusion-based claims but concluded it need not resolve that question. The court held that Wright had been permitted to assert imperfect self-defense at trial, the jury received evidence supporting the defense, and any exclusion of additional supporting evidence was not prejudicial, leading to reversal of the Court of Appeal's judgment.

criminal lawprocedure

The case involved defendant Colin Raker Dickey, who was convicted by a jury of the first-degree murders of Marie Catón and Louis Freiri, with special circumstances of felony murder robbery, felony murder burglary, and multiple murder, as well as first-degree robbery and burglary counts; the jury imposed a death sentence at the penalty phase. The California Supreme Court affirmed the judgment in full on automatic appeal. The core reasoning centered on the sufficiency of the prosecution's evidence from witnesses such as Gail Goldman and Gene Buchanan, which tied the defendant to the crimes through details like the use of a Venetian blind cord and knives, along with rejection of claims concerning trial counsel's performance and procedural motions like Marsden hearings.

criminal lawprocedure

The case involved a patient injured in a car accident who received treatment at a hospital that was part of his health plan's preferred provider network. The hospital accepted payment from the patient's insurer and the patient's copayments as full satisfaction under its provider agreement, which included a 'payment in full' clause, but later filed a lien under the Hospital Lien Act to recover the difference between its full charges and the negotiated amount. The trial court upheld the hospital's right to assert the lien, but the Court of Appeal reversed, and the California Supreme Court affirmed that the hospital could not enforce the lien. The court reasoned that the lien requires an underlying debt for reasonable and necessary charges, which was extinguished by the hospital's agreement to accept the discounted payments as full compensation. The decision did not address related issues such as the litigation privilege or the applicability of certain precedents outside the Medicaid context.

healthcaretorts & liabilityprocedure

The case involved former employees of Varian Associates who posted derogatory messages online about company executives and the companies, prompting a lawsuit alleging libel, invasion of privacy, breach of contract, and other claims. The defendants filed anti-SLAPP motions under Code of Civil Procedure section 425.16 to strike the complaint as a strategic lawsuit against public participation, but the trial court denied the motions as untimely and on other grounds, after which the defendants appealed. The California Supreme Court held that the filing of an appeal from the denial of an anti-SLAPP motion automatically stays all further trial court proceedings on the merits of the affected causes of action. The core reasoning was that under section 916, such an appeal stays enforcement of the order and any related proceedings because the defendants would be deprived of the protection from litigation if the trial proceeded before the appeal was resolved.

free speechprocedure

This case concerns the extended detention procedures in Welfare and Institutions Code section 1800 et seq., which allow civil commitment of individuals who would otherwise be discharged from Youth Authority commitments if they pose a danger due to mental issues. The court decided that to comply with due process, the scheme must be interpreted to require proof that the person's mental deficiency, disorder, or abnormality causes serious difficulty in controlling dangerous behavior. Because the jury in this case was not instructed on that element and evidence on it was limited, the defendant is entitled to a new commitment proceeding, leading the court to reverse the Court of Appeal's judgment without remand.

criminal lawcivil rightsprocedure

In People v. Benavides, defendant Vicente Figueroa Benavides was convicted by a jury of the first-degree murder of 21-month-old Consuelo Verdugo, along with rape, sodomy, and lewd conduct, with special circumstances of felony murder during those acts, and was sentenced to death. The prosecution's case showed that Benavides inflicted fatal blunt force penetrating injuries to the child's anus and internal organs while babysitting her, with medical evidence contradicting the claim that she had run into a door. On automatic appeal, the California Supreme Court affirmed the judgment in its entirety, upholding the convictions and penalty based on the sufficiency of the evidence and the trial proceedings.

criminal law

The case involved a habeas corpus petition by Anderson Hawthorne, Jr., a death row inmate, who claimed he was mentally retarded and thus could not be executed under the Eighth Amendment as interpreted in Atkins v. Virginia. The California Supreme Court addressed the lack of statutory procedures for postconviction mental retardation claims, since Penal Code section 1376 applied only to preconviction proceedings. The court decided that such claims should be resolved in substantial conformance with the standards and procedures in section 1376, including a threshold showing by expert declaration, an evidentiary hearing with a preponderance burden on the petitioner, and examination by qualified experts. Because Hawthorne met the initial threshold with evidence of significantly subaverage intellectual functioning and adaptive deficits before age 18, the matter was transferred to the superior court for a full hearing on the claim.

criminal lawprocedure

The case concerned whether a trial court could terminate a criminal defendant's right to self-representation based solely on out-of-court misconduct related to discovery matters, after the defendant had been granted Faretta status. The court held that termination is permissible for misconduct—whether in or out of court—that seriously threatens the core integrity of the trial, and it reconsidered prior precedent limiting revocation to disruptive in-court conduct. The decision was based on the language and logic of Faretta v. California, which does not restrict termination authority to courtroom behavior, and the need to preserve a fair trial process. Because the record lacked a specific assessment of the misconduct's nature and impact, the court remanded for a hearing to determine if revocation was justified, with instructions to reinstate the conviction or order a new trial accordingly.

criminal lawprocedurecivil rights

The case concerned whether a City of Oakland ordinance regulating predatory lending practices in the subprime home mortgage market was preempted by state legislation. Eight days before California enacted Division 1.6 of the Financial Code in 2001 to curb abusive lending practices such as excessive fees and loans made without regard to repayment ability, Oakland adopted its own ordinance on the same subject. The Supreme Court of California held that the ordinance was preempted by Division 1.6. It reasoned that the state statute established a comprehensive regulatory scheme for covered loans that evidenced the Legislature's intent to occupy the field, rendering the local measure invalid. The court reversed the Court of Appeal's judgment that had upheld the ordinance after severance of an exemption for federally chartered lenders.

business & regulatoryproperty

This case is an automatic appeal from a death judgment under California's 1978 death penalty law. Defendant Robert Young was convicted after a jury trial of three first-degree murders, multiple robberies, attempted murders, and other offenses, with true findings on robbery-murder and multiple-murder special circumstances as well as firearm and great bodily injury allegations. The jury returned a death verdict in the penalty phase, which the trial court imposed along with determinate terms for the remaining counts. The California Supreme Court reviewed the guilt-phase and penalty-phase proceedings, including evidentiary, instructional, and prosecutorial claims, and affirmed the judgment in full.

criminal law

The case involved Robinson Helicopter Company suing Dana Corporation, its supplier of critical sprag clutches used in helicopters, after Dana altered the grinding process for the clutches without notifying Robinson or the FAA and continued to provide false certificates stating that the clutches met required specifications. Robinson claimed this constituted intentional misrepresentation and fraud, leading to potential safety risks and economic damages. The California Supreme Court held that the economic loss rule, which generally bars tort recovery for purely economic losses in contract disputes absent personal injury or damage to other property, does not apply to bar Robinson's tort claims for intentional misrepresentation. The court's reasoning centered on the fact that Dana's provision of false certificates amounted to an independent tort separate from the breach of contract, particularly given the affirmative misrepresentations and the safety implications for aircraft components.

torts & liabilitybusiness & regulatory

This case arose from the death of a developmentally disabled adult due to negligence by staff at a residential care facility where he had been placed by a regional center under the Lanterman Developmental Disabilities Services Act. Plaintiffs argued the regional center should be held vicariously liable for the facility's negligence based on nondelegable statutory duties, but the trial court rejected this position, allowed apportionment of fault, and the jury found the regional center not negligent. The Court of Appeal held the regional center vicariously liable and applied the law of the case doctrine from a prior decision in the same case, but the Supreme Court reversed. The Court reasoned that the prior appellate decision had not resolved the vicarious liability issue and that the Lanterman Act's provisions for service coordination by regional centers do not create vicarious liability for negligence by independent residential facilities.

torts & liabilityhealthcare

This case involves defendant Richard Dean Turner’s appeal from a death sentence imposed after a retrial for the first-degree murders of Merle and Freda Claxton during a burglary. Following reversal of the original death judgment due to faulty jury instructions on intent to kill for the special circumstances, the defendant entered a plea for life without parole, but that was vacated on appeal; on retrial the prosecution pursued only the multiple-murder special circumstance with intent to kill, which the jury found true, resulting in a death verdict for one victim and life without parole for the other. The California Supreme Court affirmed the death sentence after reviewing the evidence and rejecting the defendant’s various challenges to the special-circumstance finding, penalty phase, and other procedural matters.

criminal lawprocedure