The case involved an appeal from a first-degree murder conviction in which the defendant argued that the jury foreman committed misconduct by telephoning an attorney during deliberations to ask about the classification of involuntary manslaughter and the meaning of diminished capacity. The California Supreme Court reversed the judgment, holding that the foreman's consultation created a presumption of prejudice that was not rebutted, requiring a new trial. The court also provided guidance that the defendant's extrajudicial confession should have been suppressed because it was obtained without proper Miranda warnings. The decision rested on settled precedent that private communications with jurors about pending matters are presumptively prejudicial unless shown otherwise. Topics selected focus on the criminal conviction, jury procedures, and confession issues central to the opinion.
In King v. Thierry S., a minor was declared a ward of the juvenile court under Welfare and Institutions Code section 602 after being arrested without a warrant for misdemeanor vandalism that was not committed in the officer's presence. The court held that the arrest was illegal under section 625.1, which by its terms and legislative history requires a warrant for misdemeanor arrests outside the officer's presence, and that evidence obtained from the illegal arrest was tainted and should have been suppressed. The judgment was reversed because the wardship finding relied solely on that tainted evidence of railroad vandalism. The decision rested on rules of statutory construction, including Government Code section 9605, and the history of sections 625 and 625.1.
The case involved a 14-year-old minor, Roger S., who petitioned for a writ of habeas corpus after his mother admitted him to Napa State Hospital under Welfare and Institutions Code section 6000(b), seeking release on grounds that the statute denied him procedural due process and equal protection compared to minors committed as wards under the Lanterman-Petris-Short Act. The California Supreme Court held that minors aged 14 or older possess a liberty interest entitling them to due process protections, including a hearing to determine if they are mentally ill or disordered, whether they are gravely disabled or dangerous to self or others, and whether admission would likely benefit them; these rights cannot be waived by a parent. The court reasoned that while parental authority to guide a child's development generally allows curtailment of a minor's liberty, admission to a state mental hospital implicates fundamental constitutional protections under the Fourteenth Amendment and the California Constitution that require procedural safeguards when the state is involved in the confinement. The decision outlined minimum procedures for such admissions and noted interim use of LPS Act commitments until new legislation is enacted.
The case involved Lee Roy Hannon's appeal from convictions for attempted robbery and assault with a deadly weapon stemming from an incident outside a restaurant. The court rejected his claim that prearrest delay violated his right to a speedy trial, holding that under relevant precedents such delay must be intentional to support relief. It reversed the judgment, however, because the trial court gave a prejudicial jury instruction allowing consideration of certain evidence as tending to show consciousness of guilt when the circumstances did not support it.
The case involved the estate of Inez G. Fasken, a California resident who died in 1968 leaving property in both California and Texas to her son. The State Controller appealed an order that reduced the inheritance tax by $463,858, challenging the trial court's rejection of a state regulation for calculating the portion of the federal estate tax credit allocable to California when multiple states are involved. The California Supreme Court affirmed the lower tax amount, holding that the regulation violated federal due process by exceeding California's jurisdictional limits over out-of-state property. The core reasoning centered on the need to apportion the federal "pick-up" tax credit among states based on the location of taxable property, consistent with prior precedents like the Treichler decisions, rather than using a method that could disproportionately favor one state.
The case involved a juvenile, Ronald E., who petitioned for a writ of habeas corpus claiming unlawful detention by the Youth Authority. He argued that juvenile court orders were defective because he was not advised of his Boykin-Tahl constitutional rights (against self-incrimination, to confrontation, and to a jury trial) before admitting allegations in multiple petitions under the Juvenile Court Law, and that no waiver could be implied; he also challenged procedural aspects of his parole revocation. The court denied relief, holding that the petitioner had waived any constitutional defects by failing to raise timely challenges to the commitments and by not alleging a lack of knowledge of his rights or prejudice from any omissions. The decision emphasized that habeas corpus cannot substitute for appeals absent special circumstances excusing the delay, and that Boykin-Tahl protections apply to juveniles but require a showing that admissions were involuntary for collateral relief.
