Justia California Court of Appeals Opinion Summaries

James Mason Heaps, a gynecological oncologist at UCLA, was prosecuted for multiple charges arising from medical examinations involving seven former patients. The allegations included sexual battery by fraud, sexual exploitation, and sexual penetration of an unconscious person during gynecological exams. The jury ultimately convicted Heaps on several counts involving two victims, acquitted him on others, and was unable to reach verdicts on some charges. Sentencing followed with an aggregate prison term of 11 years.The Superior Court of Los Angeles County presided over the trial and subsequent jury deliberations. During deliberations, a note was sent by the jury foreperson expressing concerns that Juror No. 15 lacked sufficient English proficiency to participate and had prematurely decided the case. The judicial assistant, rather than the judge, addressed the note directly with the jurors—speaking in both English and Spanish—without notifying counsel or making a record of the exchanges. Defense counsel was not informed of the note or these communications, and the trial proceeded to verdict. On appeal, the settled statement process included testimony and declarations clarifying the sequence of events, but key details remained unclear.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the case. It held that the trial court’s failure to notify counsel about the jury’s note and the judicial assistant’s ex parte communications with the jury during deliberations deprived the defendant of his Sixth Amendment right to counsel at a critical stage. The appellate court found that the prosecution had not met its burden to demonstrate, beyond a reasonable doubt, that this constitutional error was harmless. As a result, the judgment was reversed and the case remanded for a new trial. View "P. v. Heaps" on Justia Law

Law enforcement authorities investigating a graduate student at a university for rape served a search warrant on a major electronic service provider seeking data linked to the student’s university email account. Along with the warrant, the authorities obtained a nondisclosure order (NDO) that prohibited the provider from disclosing the existence of the warrant or the investigation to the target, the university, or others for 90 days. The provider did not contest the restriction as it applied to the target, but sought to modify the NDO so it could inform a trusted contact at the university about the warrant, arguing that doing so would not compromise the investigation and was required under state law and the First Amendment.In the Superior Court of Los Angeles County, the provider’s motion to modify the NDO was denied. The court based its decision on a sealed affidavit supporting the warrant and NDO, finding that several statutory criteria justifying nondisclosure were satisfied. The court also rejected the provider’s proposal to notify a university contact, expressing concern about its lack of jurisdiction over the university and the possibility of unauthorized disclosure. The NDO was later extended, but ultimately lifted after the student was arrested.The California Court of Appeal, Second Appellate District, Division Four, reviewed the provider’s petition for a writ of mandate. The court held that the trial court complied with the California Electronic Communications Privacy Act by making the required findings before issuing the NDO, and that the NDO satisfied strict scrutiny under the First Amendment. The court reasoned that the NDO served a compelling governmental interest in protecting an ongoing criminal investigation and was narrowly tailored, as allowing disclosure to a university contact posed unacceptable risks. The petition for writ of mandate was denied, and each party was ordered to bear its own costs on appeal. View "Microsoft Corp. v. Superior Ct." on Justia Law

The case centers on a defendant who was convicted by a jury of multiple offenses resulting from his involvement in a shootout with police officers in San Diego. During jury selection, the prosecution exercised a peremptory challenge to remove a prospective juror (Juror 1), who was believed to be a Latina, based on the prosecutor’s belief that she was confused about the concept of intent. The defendant objected, arguing that the peremptory challenge was being used to exclude Hispanic or Latina jurors. The trial court adopted the prosecution’s rationale, found that Juror 1 was confused about intent, and overruled the objection.The Superior Court of San Diego County presided over the trial and issued the challenged judgment, sentencing the defendant to a lengthy prison term. The defendant appealed, asserting that the trial court’s finding about Juror 1’s confusion was unsupported by the record. On appeal, the prosecution argued that the trial court’s factual finding was supported by substantial evidence and that the defendant had forfeited certain arguments for not making more specific objections during trial.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. Applying de novo review as mandated by statute, the appellate court concluded that the record did not support the trial court’s finding that Juror 1 was confused about intent. The court further held that the prosecutor’s justification—juror confusion—was a presumptively invalid reason for a peremptory challenge under section 231.7 of the Code of Civil Procedure, and that the trial court failed to properly confirm the asserted behavior occurred. Because there was no substantial evidence to support the prosecutor’s stated reason, the appellate court held that the judgment must be reversed and remanded for a new trial. View "People v. Aguilar" on Justia Law

In this case, the defendant was indicted along with several co-defendants for the murder of Kisasi Baltrip and related offenses following a grand jury proceeding in 2007. The charges included first-degree murder, conspiracy, discharge of a firearm, and gang participation, with various enhancements. The defendant later pleaded no contest to second-degree murder and other charges as part of a plea agreement, admitting to a firearm enhancement. The factual basis for the plea was stipulated to be found in police reports and grand jury testimony. He was sentenced to 15 years to life plus additional terms for the enhancements and related offenses, and the judgment was affirmed on appeal after a modification to custody credits.Subsequently, the defendant filed a petition for resentencing under Penal Code section 1172.6, which provides relief to certain individuals convicted of murder under theories that have since been restricted by legislative reform. The Superior Court of Kern County initially denied the petition at the prima facie stage, but the California Court of Appeal, Fifth Appellate District, reversed and remanded for a further hearing. Upon remand, the trial court conducted an evidentiary hearing and admitted the grand jury transcript, police reports, witness statements, and other law enforcement documents over defense objection, relying on these materials to deny the petition on the basis that the defendant was a major participant who acted with reckless indifference to human life.On appeal, the California Court of Appeal, Fifth Appellate District, held that neither the grand jury transcript nor the law enforcement-generated documents were admissible at the section 1172.6 evidentiary hearing under the governing statutory exception for evidence “previously admitted at any prior hearing or trial.” The court vacated the denial of the petition and remanded for a new evidentiary hearing, permitting the prosecution the opportunity to present admissible evidence. The holding was not that the petition should be granted outright, but rather that a new hearing must be held applying proper evidentiary standards. View "P. v. Dixon" on Justia Law

A man faced criminal charges stemming from two separate incidents: one in San Diego in August 2020, where he struck a taxi driver with a skateboard during what appeared to be a psychotic episode, and another in Newport Beach in March 2022, where he damaged property at a car dealership and stole a yacht, causing injury and property damage. After the first incident, he was diagnosed with paranoid schizophrenia and granted pretrial mental health diversion, but this was revoked following the second incident. After the Newport Beach offense, he was diagnosed by another expert with bipolar disorder and related conditions, with evidence suggesting he had been misdiagnosed and improperly medicated prior to the second incident.The Superior Court of Orange County considered his motion for pretrial mental health diversion under Penal Code section 1001.36, supported by expert reports stating his mental health conditions contributed to the offenses and that he would likely respond to treatment without posing an unreasonable risk to public safety if treated in the community. The prosecution opposed, arguing prior diversion had failed and that he posed a danger. The trial court denied the motion, finding him eligible but not suitable for diversion due to doubts about his responsiveness to treatment and concerns about danger to public safety, relying in part on his history of declining treatment and the circumstances of the offenses.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the lower court had abused its discretion. The appellate court held that the trial court applied the wrong legal standard regarding responsiveness to treatment by disregarding the uncontradicted opinion of a qualified mental health expert. It also found the trial court’s determination that the defendant posed an unreasonable risk of danger was not supported by substantial evidence. The appellate court granted a writ of mandate directing the trial court to vacate its order denying diversion and to reconsider the motion consistent with the proper legal standards. View "Siam v. Superior Court" on Justia Law

The defendant, who had previously been convicted of first degree burglary and attempted first degree burglary, was found by a jury to have committed these offenses while a person was present. In a separate proceeding, the trial court determined that he had three prior felony convictions qualifying under California’s Three Strikes law, three prior serious felony convictions, and a prior prison term enhancement. He was initially sentenced to 66 years to life, which was later reduced to 41 years to life. Following referral from the Department of Corrections and Rehabilitation, the defendant sought resentencing under Penal Code section 1172.75, requesting the trial court exercise its discretion to dismiss certain prior convictions and enhancements based on changes to Penal Code section 1385 and arguments under People v. Superior Court (Romero).The Superior Court of Los Angeles County held a hearing at which the defendant requested dismissal of two prior strike convictions and one five-year prior serious felony enhancement, citing age and conduct in prison. The People opposed, arguing the Three Strikes sentence was appropriate. The trial court dismissed the one-year prior prison term enhancement and struck the three five-year prior serious felony conviction enhancements but declined to dismiss any prior strike convictions under the Three Strikes law. The defendant was resentenced to 25 years to life.The California Court of Appeal, Second Appellate District, Division Six, reviewed whether the amended section 1385, subdivision (c), applied to the Three Strikes law and whether the rule of lenity could extend its application. The court held that section 1385, subdivision (c), as amended by Senate Bill No. 81, does not apply to the Three Strikes law, since the law constitutes an alternative sentencing scheme, not an enhancement. The court also found no statutory ambiguity warranting application of the rule of lenity. The judgment of the trial court was affirmed. View "P. v. Grandberry" on Justia Law

The case centers on Taiwan Orran Reed, who was convicted by a jury in August 2020 of multiple offenses, including pimping, pandering, human trafficking, and rape involving two victims. The jury also found special circumstances under California’s one strike law, resulting in Reed’s sentence of 21 years four months in prison, plus 30 years to life. Reed, who is African American, later filed a petition for writ of habeas corpus in the Riverside County Superior Court, seeking relief under the California Racial Justice Act of 2020. He alleged that racially discriminatory language—specifically being referred to as a “gorilla pimp”—was used by the prosecutor and expert law enforcement witnesses during his trial.After Reed’s retained counsel withdrew due to personal reasons and lack of payment, the superior court appointed the Riverside County Public Defender to represent Reed at an evidentiary hearing on his habeas petition. The Public Defender objected to the appointment, arguing that under Government Code section 27706, subdivision (g), his office has discretionary authority to decline representation in postconviction habeas matters, unlike mandatory representation required in trial proceedings under subdivision (a). The trial court disagreed and compelled the Public Defender to accept the appointment, finding that the Public Defender had not demonstrated unavailability.The California Court of Appeal, Fourth Appellate District, Division Two, granted the Public Defender’s petition for writ of mandate. The appellate court held that section 27706(g) governs public defenders’ representation of habeas petitioners, granting them discretion to decline such appointments without a showing of unavailability. The trial court’s order compelling the Public Defender to represent Reed was vacated, and the superior court was directed to appoint alternate counsel for Reed’s habeas petition. View "Harmon v. Superior Ct." on Justia Law

The defendant was arrested on October 2, 2021, for misdemeanor driving under the influence and was released after signing a citation promising to appear in court on December 14, 2021. The Riverside County District Attorney filed a misdemeanor complaint on November 17, 2021. The defendant failed to appear on the scheduled date, resulting in a bench warrant for her arrest. After a subsequent stop and another citation, she failed to appear again, leading to another bench warrant. In March 2024, the defendant voluntarily contacted the court, had her matters calendared, and pled not guilty. She later filed a motion to dismiss, arguing her Sixth Amendment right to a speedy trial had been violated due to delays.The Riverside County Superior Court denied the motion, finding the defendant’s own failures to appear contributed to the delay. The defendant then sought review by petitioning the Appellate Division of the Riverside County Superior Court. The Appellate Division, in a divided opinion, held that the prosecution’s failure to file a formal complaint within 25 days as required by Penal Code section 853.6 deprived the trial court of personal jurisdiction and automatically relieved the defendant of any obligation to appear. Based on this, it ordered the trial court to vacate its order and reconsider the motion to dismiss.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the Appellate Division’s decision. It held the lower court had abused its discretion by misinterpreting Penal Code section 853.6. The Court of Appeal clarified that the failure to file charges within 25 days did not relieve a defendant of the obligation to appear or deprive the court of personal jurisdiction. The appellate court issued a writ directing the Appellate Division to vacate its opinion and reconsider the defendant’s writ petition consistent with this interpretation. View "People v. Superior Ct." on Justia Law

In this case, Raul Rodriguez was charged in 1994 with several crimes, including the murder of Jose Alvaro Salavia. During the preliminary hearing, three police officers testified, primarily relaying hearsay statements from Rodriguez’s mother and uncle, indicating Rodriguez admitted to the shooting. No other evidence implicated Rodriguez, and the defense presented none. The court found probable cause, and Rodriguez subsequently pleaded guilty to second degree murder. The plea hearing did not include admissions to specific facts or a stipulation to the preliminary hearing transcript; the court found a factual basis based on counsel’s stipulation.Years later, in 2022, Rodriguez petitioned for resentencing under Penal Code section 1172.6, arguing that recent changes to California homicide law made him ineligible for a murder conviction under the prior theory. The Superior Court of Los Angeles County appointed counsel, ordered briefing, and reviewed the preliminary hearing transcript, which contained the police officers’ hearsay testimony. The People argued Rodriguez was the sole perpetrator, making him ineligible for relief. Rodriguez did not provide specific factual allegations in response and submitted on the papers. The court denied the petition, finding Rodriguez had not established a prima facie case for resentencing.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the order. It held that, at the prima facie stage of a section 1172.6 resentencing petition, courts may rely on hearsay statements admitted at the preliminary hearing, even if they would be inadmissible at a later evidentiary hearing, because the transcript serves to frame the issues rather than resolve factual disputes. The court affirmed the denial of Rodriguez’s petition but remanded the case to allow him thirty days to file an amended petition with nonconclusory factual allegations. View "People v. Rodriguez" on Justia Law

John Ross Craig, along with two accomplices, entered a clothing store in 2012 and robbed employees at gunpoint, ordering them to lie on the floor and taking their wallets and phones. After being surrounded by police, the group negotiated for two hours before surrendering. Craig was charged with multiple counts, including kidnapping to commit robbery and second degree robbery, with firearm and gang enhancements, as well as allegations of prior serious felony convictions. In 2015, he pleaded no contest to two counts of second degree robbery, admitted to the firearm enhancement and prior felony allegations, and was sentenced to 23 years in prison.In 2024, Craig petitioned the Superior Court of Los Angeles County to recall and resentence him under Penal Code section 1172.1, citing several legislative changes giving courts discretion to strike certain enhancements and asking for consideration of his post-conviction rehabilitation, youth at the time of the offense, and parole plans. The prosecution opposed, highlighting Craig’s prison rule violations. The superior court denied the petition, reasoning that Craig should be held to the plea agreement he entered and expressing skepticism about his rehabilitation and employment plans.On appeal, the California Court of Appeal, Second Appellate District, Division Seven, reviewed whether the superior court’s order denying Craig’s petition was appealable and whether the court erred in its decision. The appellate court held that the denial affected Craig’s substantial rights and was therefore appealable. Importantly, it found the superior court abused its discretion by applying an incorrect legal standard—relying on Craig’s plea agreement rather than the statutory criteria for resentencing under section 1172.1. The appellate court reversed the denial and directed the superior court to conduct a new resentencing hearing in accordance with the proper legal standard. View "People v. Craig" on Justia Law