California Supreme Court — appointed by Edmund Gerald Brown
California Supreme Court — appointed by Edmund Gerald Brown
California Supreme Court — appointed by Edmund Gerald Brown
In Re Horton
California Supreme Court · 1991-08-12 · cited 125×
The case concerned whether a court commissioner could preside over a capital murder trial in superior court without an express oral or written stipulation from the defendant, where defense counsel had proceeded to trial without objection despite knowing the presiding officer was a commissioner. The California Supreme Court denied habeas relief, holding that the constitutional requirement for a stipulation to authorize a commissioner to act as a temporary judge can be satisfied by implied consent inferred from counsel's conduct. The court reasoned that the right to a regularly elected or appointed judge is not a fundamental personal right that must be personally waived by the defendant after admonition, but rather one that counsel may effectively stipulate to on the client's behalf. It distinguished this from rights requiring explicit personal waiver and noted that the commissioner had followed standard practice of confirming stipulations with counsel.
criminal lawprocedure
Schwab v. Rondel Homes, Inc.
California Supreme Court · 1991-04-15 · cited 53×
This case concerned whether plaintiffs could obtain a default judgment against defendants in a housing discrimination lawsuit alleging refusal to rent an apartment due to a signal dog for a deaf tenant, without first serving a statement of damages under Code of Civil Procedure sections 425.10 and 425.11. The trial court set aside the default and judgment for lack of such notice, but the Court of Appeal partially reinstated it; the Supreme Court reversed, holding that notice is required. The court reasoned that the action sought damages for emotional distress and thus qualified as a personal injury case under the statutes, which prohibit stating damage amounts in the complaint but mandate separate notice before default to allow defendants to respond. Plaintiffs' complaint and proof focused on mental and emotional distress, triggering the notice obligation, so the default was invalid without it.
civil rightsprocedure
People v. Pensinger
California Supreme Court · 1991-02-28 · cited 348×
The case involved the conviction of Brett Patrick Pensinger for the first-degree murder of infant Michelle Melander and the kidnappings of Michelle and her five-year-old brother, along with special circumstance allegations that the murder occurred during a kidnapping and involved torture. The Supreme Court of California affirmed the convictions for murder and kidnapping as well as the kidnapping-murder special circumstance based on evidence that the defendant abducted the children after a confrontation over a stolen rifle and drove off with them. The court reversed the torture-murder special circumstance for lack of sufficient proof but upheld the death penalty, determining that the remaining valid special circumstance supported the sentence and that claims regarding hypnosis of witnesses, evidence handling, and counsel performance did not require reversal.
criminal law
People v. Daniels
California Supreme Court · 1991-01-07 · cited 354×
The case involved defendant Jackson Chambers Daniels, Jr., who was convicted of first-degree murder of two Riverside police officers sent to arrest him after his prior bank robbery conviction was affirmed, along with related drug and firearm possession charges. The jury found multiple special circumstances, including multiple murders, murder to avoid arrest, and murder of peace officers, and imposed the death penalty, triggering an automatic appeal. The court reviewed numerous claims regarding evidentiary rulings, jury instructions, prosecutorial arguments, and penalty phase procedures during both guilt and penalty trials, ultimately addressing issues such as the admissibility of prior crimes evidence, expert testimony, and notice requirements under California law.
criminal lawprocedure
Poster v. Southern California Rapid Transit District
California Supreme Court · 1990-12-24 · cited 64×
The case concerned whether a counteroffer by defendants automatically revoked a plaintiff's statutory settlement offer under Code of Civil Procedure section 998 in a personal injury lawsuit, and whether section 1013 extended the 30-day acceptance period by five days when the offer was served by mail. The court held that a counteroffer does not revoke or terminate a section 998 offer, which remains available for acceptance until expressly withdrawn by the offeror or deemed withdrawn under the statute's terms. It further concluded that section 1013 does not apply to section 998 offers, so the acceptance period runs from the date of service by mail without extension. The reasoning centered on the legislative purpose of section 998 to promote settlements while preserving the offer's viability during negotiations, and on the plain language distinguishing statutory deadlines from general response extensions.
proceduretorts & liability
In Re Fields
California Supreme Court · 1990-12-03 · cited 220×
In this habeas corpus petition, the defendant, previously convicted of murder with a special circumstance and sentenced to death, claimed he was denied effective assistance of counsel because his trial attorney failed to adequately investigate psychiatric defenses for the guilt and sanity phases or mitigating evidence for the penalty phase. After an evidentiary hearing before a referee, the court adopted the finding that counsel's investigation of mental defenses at the guilt and sanity phases met minimum professional standards. The court declined to decide whether the penalty-phase investigation was deficient, concluding instead that the defendant had not shown prejudice under the Strickland standard, as there was no reasonable probability that additional investigation would have produced a different outcome at the penalty phase. The petition was therefore denied.
criminal law