Carol Ann Corrigan

This consolidated case addresses whether a regulation validly defined "good cause" under Welfare and Institutions Code section 6601.3 to allow the Board of Parole Hearings to extend an inmate's custody up to 45 days past the scheduled release date for completing a sexually violent predator (SVP) evaluation. The court determined that the regulation was invalid because it required only some evidence of a qualifying conviction and likely SVP status, without linking the showing to circumstances necessitating the delay. It further ruled that the Board's reliance on the regulation was excusable as a good faith mistake of law under section 6601, subdivision (a)(2), so the SVP petitions filed during the extended custody period were not subject to dismissal for lack of timely lawful custody.

criminal lawprocedure

The case involved defendant Sonny Enraca, who was convicted in 1999 of the first-degree murders of two men and assault with a deadly weapon on a woman during a gang-related fight at an illegal street race in 1994. He was also found to have used a firearm and committed the crimes for the benefit of a criminal street gang, leading to a death sentence. On automatic appeal to the California Supreme Court, the court affirmed the convictions and sentence, upholding the trial court's proceedings and rejecting challenges to the evidence and legal rulings.

criminal lawguns

This case concerned whether manufacturers of valves and pumps used in Navy warships could be held strictly liable or negligent for asbestos exposure from insulation, gaskets, and packing made by third parties that were used with their products. The California Supreme Court held that manufacturers are not liable for harm caused by another manufacturer's products unless their own product substantially contributed to the harm or they substantially participated in creating a harmful combined use. The court reasoned that existing strict products liability law applies only to defects in a defendant's own products and does not extend to foreseeable risks from replacement parts or adjacent products made by others, as this would not serve the purposes of strict liability or public policy.

torts & liability

This case concerns whether claims adjusters employed by Liberty Mutual and Golden Eagle are exempt from California overtime requirements as administrative employees under IWC Wage Order 4. Plaintiffs filed class actions alleging misclassification and seeking unpaid overtime; the trial court partially decertified the class based on the pre- and post-2000 versions of the wage order, citing Bell cases for earlier claims. The Court of Appeal ruled for plaintiffs, holding the adjusters nonexempt as a matter of law under both versions of the order. The California Supreme Court reversed, concluding the Court of Appeal misapplied the law by interpreting the wage order categorically without properly analyzing the exemption criteria under the applicable regulations and statutes.

labor & employmentbusiness & regulatory

This case concerns a habeas corpus petition by Richard Shaputis, an inmate serving 15 years to life for a 1987 second-degree murder conviction arising from domestic violence, challenging the Board of Parole Hearings' denial of parole suitability. The California Supreme Court reaffirmed that judicial review of parole decisions is limited to the deferential 'some evidence' standard, which requires only that the record contain some support for the executive branch's finding that release would pose an unreasonable risk to public safety. The court held that the Court of Appeal had improperly reweighed the evidence and substituted its judgment for the Board's, noting that Shaputis's refusal to participate in a psychological evaluation or testify limited the available information and that the Board's reliance on the offense's gravity and his lack of insight was reasonable. The decision also provided guidance that lack of insight must be rationally tied to current dangerousness in each case rather than applied as a rote factor.

criminal lawprocedure

This case involved the first-degree murder convictions and death sentences of codefendants Michael Allen and Cleamon Johnson for the 1991 killings of two individuals in Los Angeles. During guilt-phase deliberations, the trial court discharged one juror after other jurors reported that he had prejudged the case and relied on evidence not presented at trial; the court then seated an alternate and the reconstituted jury convicted the defendants. The California Supreme Court reversed both the guilt and penalty verdicts, ruling that the trial court abused its discretion under Penal Code section 1089 because the record failed to show to a demonstrable reality that the discharged juror was unable to perform his duty, and neither prejudgment nor reliance on faulty logic or analysis constitutes good cause for removal.

criminal lawprocedure

In this case, plaintiffs challenged an extra expedited delivery fee charged by a deposition reporting service for a transcript in an underlying personal injury lawsuit and sought to have trial courts review the reasonableness of such fees charged to non-noticing parties. After prevailing on appeal in establishing that authority, plaintiffs moved for attorney fees under Code of Civil Procedure section 1021.5 as private attorneys general, but the trial court and Court of Appeal denied the motion based on prior precedent limiting such awards against parties who merely pursue their own interests. The California Supreme Court reversed, holding that section 1021.5 fees could be available because deposition reporters act as regulated officers of the court performing an important public service, rather than solely vindicating private rights, and the appeal addressed an important public interest in judicial oversight of their fee practices.

procedurebusiness & regulatory

The case involved defendant Erven R. Blacksher, who was charged with the first-degree murder of his nephew Torey, the second-degree murder of his sister Versenia, and being a felon in possession of a firearm, along with related firearm-use allegations and a multiple-murder special circumstance. A jury convicted him on all counts, found the allegations true, determined he was sane, and returned a verdict of death. On automatic appeal to the California Supreme Court, the defendant raised numerous claims of error concerning the guilt phase, sanity phase, penalty phase, and sentencing reliability, including issues related to jury instructions, evidence admission, competency proceedings, and cumulative prejudice. The court reviewed the trial record and concluded that any errors or assumed errors were not prejudicial and did not undermine the verdicts or death sentence. It therefore affirmed the judgment in full.

criminal lawguns

The case involved defendant David Lynn Scott III, who was convicted by a jury of first-degree murder of Brenda Gail Kenny with special circumstances of burglary and rape, along with numerous other felonies including multiple burglaries, rapes, a robbery, false imprisonment, and attempted murders, supported by weapon use and great bodily injury findings. Following a penalty phase trial, the jury imposed the death penalty. The Supreme Court of California affirmed the judgment in full, reviewing and rejecting challenges to the sufficiency of the evidence, admissibility of statements and physical evidence, jury instructions, and various constitutional claims regarding the trial and sentencing procedures.

criminal lawprocedure

This case concerns criminal charges and an accusation for removal from office against Robert Stark, the elected auditor-controller of Sutter County, arising from disputes with the Board of Supervisors over public finance decisions and alleged violations of statutes and rules governing expenditures between 2003 and 2005. A grand jury indicted Stark on 13 counts under Penal Code section 424 and returned a 15-count accusation under Government Code section 3060. The California Supreme Court held that the section 424 offenses are general-intent crimes but require that the defendant knew or was criminally negligent in failing to know the applicable legal requirements; that a claim of misinstruction on mens rea may be raised in a motion to set aside an indictment under section 995; that the district attorney's closing argument and slides did not invalidate the mental-state instructions given to the grand jury; and that a conflict-of-interest challenge to the district attorney's participation requires a showing of a due-process violation rather than the standards of section 1424. The court resolved the questions presented through statutory interpretation and application of existing precedent without addressing the full mental-state requirement for section 3060.

criminal lawprocedure

In People v. Thomas, the defendant was convicted of first-degree murder with special circumstances including lying in wait and multiple murders, attempted murder, and second-degree murder, along with firearm enhancements and prior serious felony convictions under the Three Strikes law, resulting in a death sentence. The California Supreme Court reviewed the automatic appeal from the San Diego County Superior Court judgment. The court affirmed the convictions and sentence after examining the evidence presented at trial, including witness testimony about the incidents, and addressing numerous claims regarding evidentiary rulings, jury instructions, and sentencing procedures. The core reasoning upheld the trial court's decisions as consistent with established precedents and found no prejudicial error warranting reversal.

criminal law

The case involved defendant Lester Wayne Virgil, who was convicted by a jury of murdering Soy Sung Lao during a robbery at a doughnut shop in Los Angeles County, along with two prior knife robberies and an assault; the jury also found true a robbery/murder special circumstance, resulting in a death sentence. On automatic appeal to the California Supreme Court, the defendant raised multiple claims of error concerning the guilt phase, penalty phase, and sentencing. The court reviewed the trial record, rejected all asserted errors as either meritless or non-prejudicial, and affirmed the convictions and death judgment in full.

criminal law

The case involved defendant Jomo Zambia, who was convicted of pandering under Penal Code section 266i, subdivision (a)(2), for encouraging an undercover police officer posing as a prostitute to work for him by offering housing, clothing, and other support in exchange for her earnings. The defendant argued that the statute does not apply when the target is already a prostitute or an undercover officer. The California Supreme Court affirmed the conviction, holding that the plain language of the statute criminalizes encouraging another person to become a prostitute regardless of whether the target is already engaged in prostitution.

criminal law

The case involved defendant Bernard Albert Nelson, who was convicted by a jury of first-degree murder, robbery, and attempted carjacking of Richard Dunbar, with a special circumstance finding that the murder occurred during the commission of the other felonies; he was also convicted of additional counts of robbery, attempted murder, and related offenses involving multiple victims, including peace officers, with firearm enhancements. Nelson received a death sentence, triggering an automatic appeal to the California Supreme Court. The court affirmed the judgment in full, concluding that the evidence—including eyewitness identification, ballistics linking the crimes, and the defendant's admissions—was sufficient to support the convictions and special circumstance, and that no reversible error occurred in the guilt or penalty phases.

criminal lawprocedure

The case involved defendant Jaime Vargas Soto, who was charged with committing lewd or lascivious acts on two girls under age 14 by use of force, violence, duress, menace, or fear under Penal Code section 288(b)(1). The trial court had allowed jury instructions or arguments treating the victims' consent as a potential defense, leading to an acquittal or reversal on appeal. The California Supreme Court held that consent is not a defense to aggravated lewd acts on a child under 14 under any circumstances, reversing the lower court's judgment. The core reasoning was that the Legislature deliberately removed the "against the will of the victim" requirement from the statute in 1981, and long-standing precedent establishes that children under 14 lack legal capacity to consent to sexual acts, distinguishing this from rape and making consent logically irrelevant to the force or duress element.

criminal law

The case involved a defendant convicted of leaving the scene of an accident resulting in death who was placed on felony probation. As a probation condition, the trial court ordered him to pay restitution directly to the hospital for the victim's final medical expenses after the prosecutor noted the deceased had no ability to pay. Defendant argued the order was unauthorized because section 1203.1 incorporates the narrower victim definitions from section 1202.4, under which the hospital would not qualify. The court held that section 1202.4's definitions are not incorporated into section 1203.1 and that the trial court did not abuse its discretion, as the restitution condition was reasonably related to the offense of leaving the scene and served the purposes of rehabilitation and deterrence.

criminal lawprocedure

The case involved defendant Morris Solomon, Jr., who was convicted by a jury of four counts of first degree murder, two counts of second degree murder, and sexual assaults on two victims, with a multiple-murder special circumstance found true. Following a retrial on the penalty phase after the first jury deadlocked, a second jury imposed the death penalty, and the California Supreme Court reviewed the automatic appeal. The court affirmed the convictions and death sentence, reasoning that the trial proceedings, including jury qualification on the death penalty and admission of evidence, complied with legal standards without reversible error.

criminal lawprocedure

The case involved defendant Cisco James Hartsch, who was convicted of three counts of first-degree murder and one count of shooting at an inhabited dwelling after he fatally shot two people in a parked truck during a robbery attempt and later killed a teenage girl, with the jury finding personal firearm use and the multiple-murder special circumstance. The trial court imposed a death sentence, which was subject to automatic appeal. The California Supreme Court affirmed the convictions and sentence in full, holding that the evidence supported the verdicts and that the defendant's various claims regarding jury instructions on lingering doubt, voir dire, and other procedural matters lacked merit under state law.

criminal law

The case addressed a conflict among appellate districts regarding the timing of motions for relief from bail forfeiture under Penal Code section 1305 when an absconding defendant is arrested or surrendered in a county other than where the case is pending. The trial court had entered summary judgment against the surety after the 180-day period expired without a motion to vacate the forfeiture, and the Court of Appeal had reversed based on one line of precedent. The Supreme Court reversed, holding that such a motion must be filed within the statutory 180-day period (or any permitted extension) even for out-of-county returns to custody. The core reasoning was that section 1305(c)(3) requires the surety to make an affirmative motion rather than providing for automatic exoneration, and section 1305(i) limits the filing window to the 180-day period to ensure timely resolution.

criminal lawprocedure

The case involved defendant Collins, who was convicted by a jury of first-degree murder, robbery, and kidnapping for robbery, with true findings on kidnapping-murder and robbery-murder special circumstances and firearm use allegations, resulting in a death sentence. The trial court granted a new penalty trial, but the Court of Appeal reversed that order and reinstated the death penalty; after reassignment of judges and denial of a penalty modification motion, the case reached automatic appeal. The California Supreme Court affirmed the judgment in full after reviewing the guilt-phase evidence, including witness identifications, ATM and credit card use, shoe print analysis, and ballistics, as well as penalty-phase issues such as alleged jury misconduct. The core reasoning centered on the sufficiency of the evidence supporting the convictions and special circumstances, the lack of prejudicial error in evidentiary and procedural rulings, and the propriety of reinstating the original penalty verdict.

criminal lawprocedure