The case involved Keith Sanford Hitchings, who was convicted in Humboldt County Superior Court of two murders with a multiple-murder special circumstance and sentenced to death. Hitchings filed a habeas corpus petition alleging juror misconduct by Cathy Nordstrom, including concealing prior knowledge of the case during voir dire, prejudging his guilt, and improperly discussing the case with coworkers at a local bank while serving as a juror. The court issued an order to show cause, appointed a referee to hold an evidentiary hearing on three specific questions about the juror's knowledge, bias, and discussions, and ultimately granted the writ after reviewing the referee's findings and evidence of Nordstrom's bias and improper communications. The decision rested on the conclusion that the juror's actions violated the duty to remain impartial and not discuss the case, requiring vacation of the convictions under the totality of circumstances showing actual bias. The opinion addressed related legal standards from U.S. Supreme Court precedents on juror dishonesty and prejudice but focused on the facts of this petition.
This case involved defendant Paul Douglas Fields, who was charged with multiple counts including gross vehicular manslaughter while intoxicated after causing a fatal car accident while driving under the influence. In the first trial, the jury convicted Fields on the lesser included offense of vehicular manslaughter while intoxicated but deadlocked on the greater offense, leading to a mistrial on that count; he was later retried and convicted on the greater offense. The California Supreme Court held that Penal Code section 1023, as interpreted in People v. Greer, barred the retrial on the greater offense once the defendant stood convicted of the lesser included offense, even though the jury had been deadlocked. The court reasoned that the implied acquittal doctrine did not apply due to the explicit deadlock, but the statutory prohibition on subsequent prosecution for the greater offense after conviction on the lesser still controlled, resulting in affirmation of the Court of Appeal's reversal of the greater offense conviction.
This case concerned whether a school district could use collective bargaining to grant probationary teachers more procedural protections—such as advance notice of reasons and an appeal opportunity—before deciding not to reelect them, than those specified in Education Code section 44929.21(b). The Round Valley Teachers Association grieved a district's nonrenewal of a probationary teacher that bypassed the bargained procedures, leading an arbitrator to order compliance and reconsideration. The district petitioned to vacate the award, arguing the statute preempted the agreement. The court held that section 44929.21(b) exclusively governs reelection procedures and permits nonrenewal without cause or hearing, while Government Code section 3540 et seq. bars bargaining on matters the Education Code reserves to districts; thus the arbitrator exceeded his powers by enforcing conflicting contract terms, and the award was vacated.
In this case, a defendant was charged in municipal court with misdemeanor contempt for violating a preliminary injunction issued by the superior court that restricted gang members' activities in a Los Angeles area. The municipal court overruled the defendant's demurrer challenging the injunction's facial constitutionality, and the appellate department of the superior court affirmed on jurisdictional grounds. The Court of Appeal upheld these rulings, but the California Supreme Court reversed, concluding that while a direct attack to dissolve the injunction could not be brought in municipal court, the defendant was entitled to defend against the contempt charges by asserting the injunction's unconstitutionality and to obtain appellate review of any contempt judgment on those grounds. The court's reasoning rested on settled California law that there can be no contempt of a void injunctive order and that constitutional challenges to such orders may be raised in contempt proceedings.
In re Avena was a habeas corpus proceeding brought by Carlos Jaime Avena, who had been convicted in 1980 of two first-degree murders and other offenses and sentenced to death. After the California Supreme Court issued an order to show cause on his petition and appointed a referee to resolve disputed factual issues, primarily concerning claims of ineffective assistance of trial counsel, the referee submitted findings adverse to Avena on those issues. The court concluded that the referee's findings were supported by the evidence, rejected the petitioner's exceptions, discharged the order to show cause, and denied the writ of habeas corpus. The decision turned on the absence of any factual or legal basis for relief from the convictions or death sentence.
This case involved defendant Larry Douglas Lucas's conviction for two counts of first-degree murder and burglary of an elderly couple who lived next door, along with special circumstance findings of multiple murder and burglary-murder that resulted in a death sentence. The California Supreme Court considered the automatic appeal from the judgment imposing the death penalty. The court affirmed the convictions and sentence, concluding that physical evidence including bloodstains consistent with the defendant's and victims' blood, fingerprints on items from the victims' home, and the defendant's own testimony about events on the night of the crimes sufficiently supported the jury's findings, and that the prosecutor's penalty phase arguments did not improperly undermine the reliability of the verdict.