Justia California Court of Appeals Opinion Summaries

A Black defendant was convicted of multiple felonies, including attempted premeditated murder, torture, and assault, after a series of violent incidents. The most serious event occurred at a hotel, where the defendant attacked a night manager with a boxcutter, stabbed him, and then continued to assault him with a pen and by biting and headbutting him. The defendant also assaulted correctional officers on two separate occasions while in jail. At trial, the defense did not dispute the violent conduct but argued that the defendant lacked the specific intent required for the most serious charges, emphasizing his impulsive behavior and likening his actions to those of an animal.The case was tried in the San Mateo County Superior Court, where the jury found the defendant guilty on all charges presented. The court imposed consecutive sentences for attempted murder and torture, finding that the crimes involved separate acts of violence and objectives. The court also described the defendant’s conduct as “animalistic” at sentencing. The defendant appealed, arguing that his counsel’s and the court’s animal comparisons violated the California Racial Justice Act of 2020 (RJA), that the court erred in evidentiary rulings and sentencing, and that cumulative error deprived him of a fair trial.The California Court of Appeal, First Appellate District, Division Two, held that the defendant was procedurally barred from raising RJA claims based on his counsel’s animal comparisons because those statements were part of a deliberate defense strategy, invoking the doctrine of invited error. The court also found that the RJA claim regarding the trial court’s comment was forfeited due to lack of objection. The court rejected the defendant’s other claims, finding no evidentiary or sentencing error, and affirmed the judgment. View "People v. Midell" on Justia Law

A prisoner incarcerated in a California state prison was found guilty of a serious institutional rule violation after a search of his shared cell uncovered a large quantity of inmate-manufactured alcohol. The reporting officer believed both cell occupants were aware of the alcohol due to its strong odor and issued a rules violation report (RVR) for each. The original RVR was classified as a serious offense by Captain Hopper, and after a disciplinary hearing, the senior hearing officer found the prisoner guilty. The chief disciplinary officer (CDO) at that time affirmed the result. The prisoner appealed administratively, and the California Department of Corrections and Rehabilitation (CDCR) office of grievances found merit in his due process claim, ordering the RVR to be reissued and reheard.After the RVR was reissued and classified by a different officer, a new hearing was held. The prisoner’s cellmate provided statements suggesting the prisoner had no knowledge of the alcohol, but the hearing officer again found the prisoner guilty. By this time, Hopper had become the acting CDO and conducted the final review, affirming the hearing results. The prisoner’s subsequent administrative appeal was unsuccessful, leading him to file a petition for writ of habeas corpus in the trial court, which was denied. He then sought relief in the California Court of Appeal, Fourth Appellate District, Division One.The appellate court held that under California Code of Regulations, title 15, section 3320(h), an officer who classified the original RVR is disqualified from conducting the final review of the same RVR as CDO. Because Hopper performed both roles, the court found this violated the regulation’s requirement for impartiality. The court granted the petition, vacated the disciplinary finding, and ordered a new review by a non-disqualified CDO or restoration of lost credits and pay if such review is not feasible. View "In re Dixon" on Justia Law

Christopher Skaggs was released on parole in 2019 after serving a prison sentence for felony violations of the Vehicle Code. In December 2020, the Mendocino County District Attorney filed a petition to revoke his parole, alleging new criminal conduct, and also filed a related criminal complaint. Skaggs failed to appear for hearings, resulting in bench warrants. He was later arrested in Lake County on these warrants and new charges, convicted, and sentenced to additional prison time. While incarcerated, Skaggs repeatedly requested to resolve the Mendocino County parole revocation and criminal matters. The criminal complaint was dismissed under Penal Code section 1381, but the court declined to dismiss the parole revocation petition, finding section 1381 inapplicable.Skaggs subsequently filed a nonstatutory motion to dismiss the parole revocation petition on constitutional due process grounds, arguing that delays prejudiced him by preventing concurrent sentencing and prolonging his custody. The Mendocino County Superior Court construed his motion as a Penal Code section 1385 motion and denied it, reasoning that section 1385 does not apply to parole revocation proceedings. The court then held a contested revocation hearing, found Skaggs violated parole, sentenced him to 90 days in jail, and ordered his parole terminated upon release. Skaggs appealed the denial of his motion and the parole revocation.The California Court of Appeal, First Appellate District, Division Three, determined that Skaggs’s appeal was moot because his parole had already been terminated and no effective relief could be granted. However, the court exercised its discretion to address the trial court’s error, holding that the trial court improperly construed Skaggs’s constitutional due process motion as a section 1385 motion and incorrectly concluded it lacked authority to consider the motion. The appellate court clarified that trial courts have jurisdiction to entertain nonstatutory motions to dismiss parole revocation petitions on constitutional due process grounds. The appeal was dismissed as moot. View "People v. Skaggs" on Justia Law

Justin J. (Father) appealed a jurisdiction finding and disposition order declaring his children, Hunter V. and B.V., dependents of the juvenile court. The court sustained a petition under Welfare and Institutions Code section 300, subdivisions (b)(1) and (j), alleging the children's mother had a history of substance abuse and left the children without proper care. The petition also alleged Father had an extensive criminal history and was incarcerated, which placed the children at risk.The Los Angeles County Superior Court held a detention hearing where neither parent was present. The court detained the children and ordered monitored visitation for both parents. At the jurisdiction hearing, the court amended the petition to allege Father was unable to parent due to his incarceration and inability to make an appropriate plan for the children. The court sustained the amended allegations and proceeded with the disposition hearing, declaring the children dependents of the court and ordering reunification services for both parents.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court found that the juvenile court violated Father's due process rights by failing to provide notice of the amended allegations, which were based on a different set of facts and legal theory from the initial petition. The court also violated Father's statutory right to be present at the jurisdiction hearing, as required by Penal Code section 2625, subdivision (d). The appellate court applied the Chapman standard for federal constitutional error and concluded the error was not harmless beyond a reasonable doubt. Consequently, the court reversed the jurisdiction finding and disposition order as to Father and remanded the case for further proceedings with Father present unless he waives his right to be present. View "In re Hunter V." on Justia Law

In 2024, Carlos Huerta filed a petition for a writ of habeas corpus in the superior court, seeking relief under the Racial Justice Act (RJA). The superior court denied the petition without appointing counsel, concluding that Huerta had failed to establish a prima facie claim for relief. Huerta then filed a petition in the Court of Appeal of the State of California, Fifth Appellate District, alleging racial discrimination in his charges and sentence, supported by statistical data.Previously, in 2010, Huerta was convicted of three counts of premeditated attempted murder and other felonies, with gang enhancements, and sentenced to 53 years to life plus 14 years. In 2022, he was resentenced to a determinate term of 26 years following changes in the law concerning attempted murder, retaining multiple gang enhancements. The RJA was not addressed during the resentencing.The Court of Appeal issued an order to show cause (OSC) in October 2024, appointing counsel for Huerta and directing the parties to address the legal showing required for the appointment of counsel in an RJA petition. The respondent initially argued that a prima facie showing was necessary for counsel appointment but later conceded that the McIntosh decision correctly interpreted section 1473, subdivision (e), which requires the appointment of counsel if the petition alleges facts that would establish an RJA violation.The Court of Appeal held that the superior court misapplied the statutory sequence by requiring a prima facie showing before assessing the lower pleading threshold for appointing counsel. However, the Court of Appeal concluded that Huerta's petition was facially defective as it failed to allege facts showing a qualifying offense under the RJA. The petition relied solely on gang enhancements, which do not fall within the scope of the relevant statutory provisions. Consequently, the Court of Appeal denied the petition for writ of habeas corpus. View "In re Huerta" on Justia Law

Mariano Albert Valdez was sentenced to life without the possibility of parole (LWOP) for a murder he committed at age 17. In 2018, Valdez petitioned for resentencing under Penal Code section 1170(d)(1), which allows juvenile offenders sentenced to LWOP to seek resentencing after 15 years of incarceration. The trial court granted the petition and resentenced Valdez to 50 years to life.In 2024, Valdez petitioned for resentencing again, arguing that his 50-year-to-life sentence was the functional equivalent of LWOP, citing People v. Heard, which held that denying resentencing relief to juvenile offenders sentenced to the functional equivalent of LWOP violates equal protection. The trial court construed Valdez's filing as a petition under section 1170(d)(10), which allows for resentencing after 20 years of imprisonment if the defendant was resentenced to LWOP or its functional equivalent. The trial court granted the petition, reasoning that Valdez's 50-year-to-life sentence was the functional equivalent of LWOP and that excluding him from resentencing relief would violate equal protection.The People petitioned for a writ of mandate to compel the trial court to deny Valdez's resentencing relief. The California Court of Appeal, Fourth Appellate District, Division Two, granted the petition. The court clarified that the reasoning in Heard does not apply to section 1170(d)(10) if the defendant was eligible for youth offender parole under the sentence imposed at resentencing under section 1170(d)(1). Valdez was eligible for youth offender parole under his 50-year-to-life sentence, making it not the functional equivalent of LWOP. Therefore, Valdez was not entitled to relief under section 1170(d)(10). The court directed the trial court to vacate its order granting resentencing relief and to deny Valdez's petition for resentencing. View "People v. Superior Court (Valdez)" on Justia Law

Kristopher Birtcher, experiencing a mental health crisis, was reported to law enforcement by a Hobby Lobby manager. Birtcher, unarmed and not threatening anyone, was detained by sheriff’s deputies. During the detention, Birtcher attempted to flee but was subdued by multiple deputies who restrained him in a prone position, applying bodyweight pressure to his back. Despite Birtcher’s pleas that he could not breathe, the deputies maintained the restraint, and Birtcher eventually stopped moving and died from asphyxiation and sudden cardiac arrest.In the Superior Court of San Diego County, the trial court granted summary judgment in favor of the defendants, finding no triable issues of material fact regarding the excessive force claim. The court concluded that the deputies’ actions were in accordance with their training and that Birtcher’s restraint was proper. The court also ruled that plaintiff failed to establish a legal basis for the negligent training claim against Sheriff William D. Gore.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court reversed the trial court’s decision, holding that there were indeed triable issues of material fact regarding the excessive force used by the deputies. The appellate court found that the evidence, including expert testimony, suggested that the deputies’ use of bodyweight pressure on Birtcher while he was restrained in a prone position could be considered excessive force. The court also held that the trial court erred in granting summary judgment on the negligent training claim against Sheriff Gore, as there was a statutory basis for the claim and evidence suggesting his involvement in the training policies.The appellate court reversed the judgment in favor of all defendants and remanded the matter for further proceedings. View "A.B. v. County of San Diego" on Justia Law

Perrie Thompson was sentenced to 50 years to life for a homicide he committed at age 17. Fifteen years later, he petitioned for relief under Penal Code section 1170(d), which allows juvenile offenders sentenced to life without parole to seek resentencing. Thompson argued that his sentence was effectively life without parole and cited cases like People v. Contreras and People v. Heard to support his claim. He presented evidence of his rehabilitation efforts while incarcerated. The trial court denied his petition, stating that his sentence was not equivalent to life without parole since he would be eligible for parole within his life expectancy.Thompson appealed the decision. The Attorney General initially opposed the appeal but later conceded that a 50-years-to-life sentence is functionally equivalent to life without parole and that denying relief to such offenders violates equal protection. However, the court independently reviewed the merits of Thompson's arguments.The California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court's order. The court held that Thompson's 50-years-to-life sentence is not the functional equivalent of life without parole for equal protection purposes. The court reasoned that the legislative intent behind section 1170(d) was to address the most severe punishments, specifically life without parole, and that the Legislature could rationally distinguish between life without parole and lengthy term-of-years sentences. The court concluded that Thompson failed to demonstrate that the exclusion of his sentence from section 1170(d) relief was irrational or unconstitutional. View "People v. Thompson" on Justia Law

In 2020, allegations emerged that certain officers in the Vallejo Police Department were bending the points of their badges after using potentially lethal force. The department hired an independent investigator to look into these claims but did not release the investigation's findings. The American Civil Liberties Union of Northern California (ACLU) requested records related to the investigation under the California Public Records Act (CPRA). The department released some records but withheld the investigative report, claiming it was a confidential personnel record.The ACLU filed a petition for a writ of mandate in the Solano County Superior Court, challenging the department's response. The court ordered the disclosure of parts of the investigative report and related materials, with redactions to protect the identities of officers, witnesses, and their families. Both parties sought writ review of this decision.The California Court of Appeal, First Appellate District, reviewed the case. The court concluded that the documents sought by the ACLU were not confidential personnel records but were subject to public disclosure under section 832.7, subdivision (b) of the Penal Code. This section pertains to records relating to the report, investigation, or findings of incidents involving the discharge of a firearm by a peace officer. The court also found that the redaction of officer names could not be sustained on the grounds relied upon by the superior court. However, due to the extensive volume of potentially disclosable materials and minimal briefing on redaction issues, the court remanded the case for further proceedings regarding redactions. View "City of Vallejo v. Superior Ct." on Justia Law

A Hobby Lobby manager called law enforcement because Kristopher Birtcher appeared to be suffering from a mental health crisis at the store. Birtcher, who was unarmed and had committed no crime, tried to flee when sheriff’s deputies arrived. The deputies subdued him by double-cuffing his hands behind his back, securing his ankles, tying his ankles to a cord around his waist, and applying bodyweight pressure to his back while he was lying face down. Birtcher gasped that he couldn’t breathe and called for help. He stopped moving after several minutes, and the deputies kept him in a prone position for another 50 seconds before turning him on his side, then later returned him to a prone position. Birtcher died from asphyxiation and sudden cardiac arrest within 25 minutes of the deputies’ arrival.Birtcher’s minor daughter, A.B., brought state claims in state court after unsuccessfully litigating federal claims. She asserted claims for wrongful death, battery, negligence, and negligent training, and a survival action for violation of the Bane Act. The Superior Court of San Diego County granted summary judgment to the defendants, finding no triable issues of material fact on the excessive force claim and ruling that the restraint was “by the book.” The court also ruled that A.B. failed to identify a legal basis for her negligent training theory against Sheriff Gore.The California Court of Appeal, Fourth Appellate District, Division One, reversed the trial court’s decision. The appellate court concluded that there were triable issues of material fact on the excessive force claim, noting that the deputies’ use of forceful prone restraint with bodyweight compression could be seen as excessive. The court also found that the trial court erred in granting summary judgment on the negligent training claim against Sheriff Gore, as A.B. had identified a statutory basis for the claim, and Sheriff Gore failed to demonstrate the absence of triable issues of material fact. The judgment was reversed and remanded for further proceedings. View "A.B. v. County of San Diego" on Justia Law