Justia California Court of Appeals Opinion Summaries

In California, a lawsuit was brought against the state by the AIDS Healthcare Foundation and the City of Redondo Beach. The plaintiffs argued that Senate Bill 10, which allowed local governments to bypass housing density restrictions, violated the initiative power of the California Constitution. The trial court ruled against the plaintiffs, leading them to appeal.Senate Bill 10 was enacted to address the severe shortage of housing in California. It provided local legislative bodies the authority to supersede local housing density caps, including those enacted by voter initiatives, in order to allow for more housing units per parcel of land. This power was not absolute; it could only be exercised in certain areas and required a supermajority vote to supersede caps adopted by local voter initiatives.The Court of Appeal upheld the lower court's decision, concluding that Senate Bill 10 did not violate the initiative power of the California Constitution. The appellate court reasoned that the housing shortage was a matter of statewide concern and that the bill conflicted with, and hence preempted, local initiatives that mandated housing density caps. Furthermore, the court determined that the bill's mechanism of granting local legislative bodies the discretion to supersede such caps was not constitutionally problematic.The court also rejected the plaintiffs' argument that existing voter initiatives constituted a preemptive exercise of the local legislative body’s discretion under Senate Bill 10, such that the body lacked the power to supersede such initiatives. The court found no textual support for this argument in the bill and concluded that such an interpretation would frustrate the purpose of Senate Bill 10. View "AIDS Healthcare Foundation v. Bonta" on Justia Law

In this case, Albert Jackson was alone in a parked car when two officers approached him. The officers boxed him in, shined flashlights on him, and questioned him, while observing that he was wearing a bulky jacket on a hot night and seemed nervous. The officers did not have any reason to suspect criminal activity, but they stopped and detained Jackson due to his behavior. The officers found a gun in Jackson's possession, leading to his arrest. Jackson challenged his arrest, arguing that his detention violated his Fourth Amendment rights. The trial court disagreed and denied his motion to suppress the evidence.The Court of Appeal of the State of California Second Appellate District Division Eight held that the officers' actions amounted to an unjustified detention. The court found that a reasonable person in Jackson's position would not feel free to leave due to the officers' display of authority. The court noted that the officers did not have any specific and articulable facts suggesting that criminal activity was afoot. Wearing a bulky jacket on a hot night, appearing surprised and nervous, and sitting awkwardly in a car do not amount to reasonable suspicion of criminal activity. The court also rejected the prosecution's argument that the area was a high-crime area, stating that the officer's words did not suggest this.The court reversed the judgment, vacated the conviction, and remanded the matter for the trial court to vacate its order denying Jackson’s motion to suppress the evidence and to enter a new order granting that motion. The court concluded that Jackson's detention was invalid and violated the Fourth Amendment. View "People v. Jackson" on Justia Law

This case revolves around the appeal of Timothy Marvin Santos, who was originally sentenced in 2007 under California's Three Strikes law and other enhancement provisions. The appeal concerns a resentencing order issued in 2022, where the trial court struck Santos' prior prison term and drug conviction enhancements but maintained his sentence of 25 years to life under the original Three Strikes law.Santos argued that the court did not apply the Three Strikes Reform Act of 2012 to reduce his sentence and that the resentencing was held without his presence, violating his federal and state constitutional rights. The People initially supported the trial court's decision but later changed their stance, suggesting that the court should have resentenced Santos under the current penalty provisions specified by the Reform Act.However, the Court of Appeal of the State of California, Third Appellate District, disagreed with this assertion. The court held that the Reform Act's revised penalty provisions could not be retroactively applied to Santos' sentence outside of the specific mechanism provided for in the Act itself. The court further concluded that if the resentencing statute was interpreted to authorize retroactive application of the revised penalty provisions without adhering to the criteria in the Reform Act, it would unconstitutionally amend the initiative statute.Concerning Santos' absence during resentencing, the court concluded that any error in accepting his counsel's waiver of his presence was harmless beyond a reasonable doubt. Santos could not have offered any help since he was not eligible for a reduction of his term under the Three Strikes law based on the resentencing statute. Consequently, his absence could not have influenced the proceeding's outcome. The court affirmed the judgment. View "P. v. Santos" on Justia Law

The Court of Appeal of the State of California, First Appellate District, considered a habeas corpus request by Ropati Afatia Seumanu, a capital case convict. Seumanu sought a certificate of appealability (COA) after his habeas corpus petition was dismissed, as he sought to challenge the superior court's decision on nine points. The court agreed to issue a COA on one claim but declined to do so for the remaining claims. The court also addressed three unprecedented issues: whether the 10-day time limit for granting or denying COA requests was mandatory or directory; how strong a showing a COA applicant must make to meet the “substantial claim for relief” test; and whether an as-applied attack on the constitutionality of section 1509, subdivision (d) was appealable under section 1509.1(c). The court found that the 10-day time limit was not mandatory, a “substantial claim to relief” required a strong enough showing for reasonable jurists to debate whether the trial court erred, and as-applied attacks on the constitutionality of section 1509(d) were appealable under section 1509.1(c). The court also discussed the need for a COA applicant to provide an adequate record for review. View "In re Seumanu" on Justia Law

This case involved Jason Felix, who was arrested for a traffic violation in Utah where a consensual search of his car led to the discovery of a handgun, ammunition, and over five kilograms of methamphetamine. Felix became a suspect in two murders in Southern California while in custody in Utah on drug charges. Upon his return to California, Felix invoked his right to counsel during an interview about one of the murders. He was then placed in a cell with an undercover detective, to whom he made incriminating statements about both murders. The trial court denied Felix's motion to suppress the evidence from the Utah traffic stop and admitted his incriminating statements made to the undercover agent. He was found guilty of two counts of first-degree murder.On appeal, Felix contended that the trial court erred in denying his motion to suppress the evidence from the warrantless search of his car and in admitting his statements to the undercover agent as he had previously invoked his right to counsel. The Court of Appeal of the State of California Second Appellate District disagreed and affirmed the judgment of conviction in its entirety. The court held that the traffic stop was lawful and not unduly prolonged, and Felix's consent to the car search was voluntary and free from coercion. It also held that Felix's incriminating statements to the undercover detective were properly admitted, as they were made freely to someone he believed to be a fellow inmate. However, the court agreed that Felix should be awarded an additional day of presentence custody credits and remanded the case to the superior court for correction. View "People v. Felix" on Justia Law

In this case, the defendant, Kevin Eugene Cartwright, was convicted of first-degree murder with special circumstances, robbery, burglary, being a felon in possession of a firearm, and being a prohibited person owning or possessing ammunition. He was sentenced to life without the possibility of parole plus 50 years to life, and a determinate prison term of 20 years four months. On appeal, Cartwright contended that the trial court erred by denying his motion to suppress video footage from the City of San Diego’s “City IQ” streetlight camera program and evidence derived from that footage. The Fourth Appellate District Division One of the Court of Appeal for the State of California affirmed the trial court's decision. The court held that Cartwright did not have an objectively reasonable expectation of privacy when he traversed a public right of way in downtown San Diego in the middle of a business day. The court found that accessing the recordings from the City’s streetlight cameras did not amount to a search within the meaning of the Fourth Amendment and, consequently, did not require a warrant. The court distinguished the cameras in this case from the aerial surveillance images and integrated police department systems addressed in other precedents, stating that the City's camera program stands alone and does not reveal the transit patterns of people throughout the county. The court concluded that the police did not conduct a "search" when they accessed footage from the City's streetlight cameras and, accordingly, there was no violation of the Fourth Amendment. View "People v. Cartwright" on Justia Law

In the early hours of New Year's Day in 1987, O'Neal Underwood and an accomplice mugged a pedestrian in Richmond, California. During the mugging, Underwood's accomplice stabbed the victim, who subsequently died from his wounds. Underwood was convicted of first degree murder and robbery and sentenced to 25 years to life in prison. Years later, the Legislature amended the murder statutes to limit felony murder liability for persons who were not the actual killers. Underwood petitioned for resentencing under the new law. The trial court denied the petition, finding Underwood ineligible for relief because he aided and abetted murder with intent to kill and was a major participant in the underlying robbery, acting with reckless indifference to human life. Underwood appealed, arguing that the trial court applied the wrong standard of proof, the prosecution's evidence does not prove he is guilty of first degree murder under current law, and his attendance at the evidentiary hearing by speakerphone and without a means of confidentially communicating with his counsel violated his constitutional and statutory rights. The Court of Appeal of the State of California, First Appellate District, Division Two, agreed with Underwood that the prosecution failed to prove he is guilty of first degree murder under current law because no substantial evidence supports a finding that he intended to kill or acted with reckless indifference for human life. Consequently, the court reversed the trial court's decision and instructed it to vacate the murder conviction and resentence Underwood in accordance with the appropriate section of the Penal Code. View "People v. Underwood" on Justia Law

In San Diego, California, Kevin Eugene Cartwright was convicted of first-degree murder with special circumstances, robbery, burglary, being a felon in possession of a firearm, and owning or possessing ammunition as a prohibited person. Cartwright appealed the judgment, arguing that the trial court erred in denying his motion to suppress video footage from the City of San Diego's "City IQ" streetlight camera program and evidence derived from the footage. Cartwright contended that the police conducted a warrantless search when they accessed the streetlight camera footage and any evidence obtained as a result of the footage should be considered "fruit of the poisonous tree."The Court of Appeal, Fourth Appellate District, Division One, State of California, disagreed with Cartwright's argument. The court held that Cartwright did not have an objectively reasonable expectation of privacy when he traversed a public right of way in downtown San Diego in the middle of a business day. The court found that the streetlight cameras only captured short-term movements and did not create a retrospective database of everyone's movements across the city. The court concluded that the police did not conduct a "search" when they accessed footage from the City of San Diego's streetlight cameras, and there was no violation of the Fourth Amendment. Therefore, the court affirmed the judgment against Cartwright. View "People v. Cartwright" on Justia Law

In California, a man named Clifford James Smyth, who was categorized as a tier two sex offender, sought to be removed from the California sex offender registry. However, at the time of his petition, he was living and registered as a sex offender in Oregon, not California. The Superior Court of Glenn County denied his petition, stating that he was not currently registered as a sex offender in California. On appeal, Smyth argued that the denial of his petition violated equal protection and was contrary to the legislative intent of California's sex offender registration laws.The Court of Appeal of the State of California Third Appellate District affirmed the lower court's decision. The court found that the California law, which was restructured to establish three tiers of registration for sex offenders, only allowed people registered in California to petition for termination from the California sex offender registry. The court disagreed with Smyth's argument that excluding out-of-state registrants from obtaining relief was contrary to the legislative intent and was absurd. The court reasoned that as someone not registered in California, the legislative concerns did not apply to Smyth.Furthermore, the court rejected Smyth's equal protection claim, concluding that out-of-state registrants are not similarly situated to California registrants for purposes of the California law, as they do not contribute to the problems identified by the Legislature when it decided to adopt the statute. The court also noted that even if out-of-state registrants were similarly situated, the distinction between the two groups would survive the requisite degree of scrutiny as there was a rational relationship between the disparity of treatment and a legitimate governmental purpose. View "People v. Smyth" on Justia Law

In this case, the defendant, Alexander Alberto Frias, was convicted of stalking. Frias appealed the decision, arguing that the trial court violated his Sixth Amendment right to counsel of his choice by denying his four requests to substitute the Castaneda Law firm as his counsel. The trial court denied the first three requests on the grounds that the firm's attorneys were not ready for trial and the case had been pending for three years, with four different attorneys had handled Frias’s defense at his request. However, the Court of Appeal of the State of California Second Appellate District Division Seven held that the trial court abused its discretion in denying Frias's fourth request. At the time of the fourth request, the case had been pending for three-and-a-half years, the case was set for trial, and the prosecutor and deputy public defender had announced they were ready for trial. An attorney from the Castaneda firm announced he was ready for trial. The trial court's concerns that the Castaneda firm was not prepared for trial and that Frias would seek to substitute new counsel were not sufficient grounds to deny Frias's request to have retained counsel of his choice. The Court of Appeal reversed the judgment based on the trial court's denial of Frias's right to counsel of his choice. However, the court found that there was sufficient evidence to support Frias's conviction for stalking and remanded for a new trial. View "People v. Frias" on Justia Law