California Case Summaries

Criminal Law

Primary practice area

4th District Court of Appeal, Civil Procedure, Criminal Law

Sua v. Superior Court — Prosecution Cannot Compel Mental Exam for Defendants Seeking Mental Health Diversion

The Fourth District Court of Appeal held that California's criminal discovery statute (Penal Code § 1054.3(b)(1)) does not authorize a trial court to compel a defendant seeking pretrial mental health diversion to undergo a prosecution mental examination, because the diversion hearing is not a trial at which the defendant has placed mental state in issue through expert testimony.

Ninth Circuit Court of Appeals, Constitutional Law, Criminal Law

Knife Rights, Inc. v. Bonta — Ninth Circuit Denies En Banc Review, Upholding California Switchblade Regulations

The Ninth Circuit denied panel rehearing and rehearing en banc in a Second Amendment challenge to California's switchblade knife regulations, leaving intact a panel ruling that California's ban on the concealed carry of switchblade knives survives a facial constitutional challenge under the Bruen framework.

2nd District Court of Appeal, Constitutional Law, Criminal Law

Muradyan v. Bonta — Lifetime Sex Offender Registration for Child Luring Offense Survives Equal Protection Challenge

California's Second District Court of Appeal affirmed that placing child-luring offenders in the lifetime sex offender registration tier does not violate equal protection, because the Legislature could rationally find that the predatory, premeditated nature of luring crimes signals a higher risk of recidivism than other sex offenses.

4th District Court of Appeal, Civil Procedure, Criminal Law

In re King — Trial Court Must Expressly Find No Less Restrictive Alternative Before Ordering Pretrial Detention

The Fourth District Court of Appeal, on remand from the California Supreme Court, holds that a trial court ordering pretrial detention must make an express finding by clear and convincing evidence that no less restrictive condition than incarceration will adequately protect public safety — “balancing” alternatives against danger is not enough.

3rd District Court of Appeal, Constitutional Law, Criminal Law

People v. Garner — A 50-Year Juvenile Sentence Is Not a De Facto Life Term When Parole Is Available Under Section 3051

The Third District held that a juvenile offender's 50-year determinate sentence is not the functional equivalent of life without parole — and therefore does not qualify for resentencing under Penal Code section 1170(d)(1) — because section 3051 gave him a meaningful parole opportunity during his 15th year of incarceration.

1st District Court of Appeal, Criminal Law, Litigation

People v. Tyler — Court Warns That ‘Could Be Convicted’ Is the Wrong Standard at a Penal Code Section 1172.6 Resentencing Hearing

The First District publishes this opinion specifically to flag a recurring error: at a section 1172.6 evidentiary hearing, the trial court is an independent fact-finder who must decide whether the petitioner IS guilty beyond a reasonable doubt under current law — not whether a jury 'could' convict them.

2nd District Court of Appeal, Constitutional Law, Criminal Law

In re Melson — Murder Conviction Vacated After Prosecution Failed to Correct False Eyewitness Testimony and Defense Counsel Did Not Review Police Interview Transcripts

The Second District Court of Appeal grants habeas corpus and vacates a second-degree murder conviction after finding the prosecution allowed false eyewitness testimony to stand uncorrected — and defense counsel failed to cross-examine the witnesses with their own prior contradictory police statements — in a gang-related retrial.

Ninth Circuit Court of Appeals, Criminal Law

United States v. Shi — Ninth Circuit Rejects ‘Sophisticated Laundering’ Sentencing Stack Where Required Predicate Enhancement Was Never Applied

The Ninth Circuit affirms money laundering convictions and most sentencing enhancements in a $2.5 million Target gift-card laundering scheme, but vacates and remands because the district court improperly applied the sophisticated-laundering enhancement under USSG § 2S1.1(b)(3) without first applying the required predicate enhancement under § 2S1.1(b)(2)(B).

Ninth Circuit Court of Appeals, Criminal Law, Litigation

United States v. Shi — Ninth Circuit Vacates Sophisticated-Laundering Enhancement Where Required Guideline Step Was Skipped

The Ninth Circuit vacated a sophisticated-laundering sentencing enhancement because the district court applied the enhancement without first working through the required preceding step in U.S.S.G. § 2S1.1(b)(2), remanding for limited resentencing of three defendants convicted in a large-scale gift-card laundering scheme.

1st District Court of Appeal, Criminal Law, Litigation

People v. Powell — Trial Court Can Correct Presentence Credit Math Errors Without Triggering Full Resentencing

The First District holds that a trial court's mathematical error in calculating presentence custody credits is a clerical error the court can correct at any time — but that correction does not render the judgment nonfinal or entitle the defendant to full resentencing under ameliorative legislation, rejecting a contrary line of cases.

1st District Court of Appeal, Constitutional Law, Criminal Law

People v. DePape — California Double Jeopardy Bars Three State Charges After Federal Conviction in Paul Pelosi Attack

The First District affirms dismissal of three state charges against David DePape — including attempted murder — under California's statutory double jeopardy protection, holding that mental-state elements cannot save a state charge when the required physical act was already proved in a prior federal conviction.

Ninth Circuit Court of Appeals, Civil Procedure, Criminal Law

Cannon v. United States — Government Cannot Keep Cash Stolen by Its Own Agent After Recovering It in Restitution

The Ninth Circuit ruled that sovereign immunity does not block a person from recovering seized cash that a federal agent stole and the government later recouped in restitution proceedings, reversing summary judgment for the government in a case where an FBI agent pocketed $218,200 of money seized during a drug investigation.

4th District Court of Appeal, Constitutional Law, Criminal Law

In re I.H. — Mistaken Identity Arrest Upheld; Firearm Discovered Incident to Resisting-Arrest Charge Is Admissible

The Fourth District holds that officers who reasonably but mistakenly identified a juvenile as a murder-warrant fugitive had probable cause to arrest him, and that after realizing the mistake they lawfully searched him incident to a resisting-arrest charge, making the discovered firearm admissible.

Ninth Circuit Court of Appeals, Criminal Law, Immigration

Leon-Briviesca v. Blanche — Ninth Circuit Defines “Crime of Child Abuse” for Immigration Removal After Loper Bright, Covers California Penal Code § 273a

In its first post-Loper Bright interpretation of the federal immigration removal ground for crimes of child abuse, the Ninth Circuit holds that the statute covers child endangerment, requires criminal negligence mens rea, and applies regardless of whether the defendant is the child's parent — and that California Penal Code § 273a(a) falls within its scope.

2nd District Court of Appeal, Criminal Law

People v. Sacco — Mental Health Diversion Properly Denied When Crime’s Sophistication Contradicts Claimed Cognitive Impairments

The Second Appellate District affirmed denial of pretrial mental health diversion under Penal Code § 1001.36, holding that the trial court had substantial evidence to find the statutory presumption rebutted where the defendant's diagnosed depressive disorder — characterized by poor concentration and forgetfulness — was fundamentally inconsistent with years of coordinated, sophisticated financial crimes.

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