California Case Summaries

Criminal Law

Primary practice area

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, 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.

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.

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.

Ninth Circuit Court of Appeals, Criminal Law, Litigation

Detrich v. Thornell — Ninth Circuit En Banc Tightens Standard for Excusing Procedural Default in Federal Habeas Cases Under Martinez v. Ryan

In an en banc opinion, the Ninth Circuit affirmed denial of habeas relief to an Arizona death-row prisoner, clarifying that merely including an underlying petition as an exhibit does not 'fairly present' a claim to a state supreme court, and that Martinez v. Ryan requires a showing of reasonable probability of a different outcome in state postconviction proceedings — not just the potential merit of the underlying IAC claim.

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

People v. Hayes — SWAT Coercion to Exit Home Is an In-Home Arrest, but a Valid Warrant Saves the Search

When a SWAT team uses gas, drones, and robots to flush a suspect from his apartment, the resulting arrest is treated as an in-home arrest — but California's First District upheld the conviction anyway because the underlying warrant affidavit, even with false statements excised, still established probable cause.

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

People v. Russo — Prior Failure in the Same Treatment Program Justifies Denying Mental Health Diversion

A trial court may deny mental health diversion under Penal Code section 1001.36 when a defendant proposes returning to the same treatment program that previously failed to address his needs — even if the court frames its analysis in terms of treatment adequacy rather than the statutory suitability factors.

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

People v. Konther — DNA Abandoned at a Crime Scene Carries No Fourth Amendment Privacy Protection, Even for Genetic Genealogy Analysis

In the first California published decision on investigative genetic genealogy, the Fourth District held that a rapist has no reasonable expectation of privacy in semen left at a crime scene — and that law enforcement's use of that DNA for genealogical database searches to identify him did not constitute a Fourth Amendment search.

2nd District Court of Appeal, Criminal Law

People v. Bustillos — Defendant Who Fled Justice Still Gets SB 567’s Upper-Term Sentencing Protections

Applying the California Supreme Court's recent People v. Mitchell decision, the Second District held that Senate Bill 567's restrictions on imposing upper-term sentences apply retroactively to defendants resentenced after probation revocation — even defendants who absconded for years and whose cases remained non-final only because of their own misconduct.

6th District Court of Appeal, Criminal Law

People v. Scott — Three Strikes Prisoner Gets Full Resentencing After Prop 47 Win, But Must Still Clear Prop 36’s Public Safety Bar

A Three Strikes prisoner who successfully petitioned under Proposition 47 to redesignate a grand theft conviction as a misdemeanor is entitled to a full resentencing on all counts — but must still satisfy Proposition 36's public safety standard before the court can reduce his indeterminate Three Strikes sentence.

Ninth Circuit Court of Appeals, Constitutional Law, Criminal Law, Litigation

Ciria v. Gerrans — Ninth Circuit Denies Qualified Immunity to SFPD Inspectors Who Allegedly Fabricated Evidence Leading to 32-Year Wrongful Imprisonment

The Ninth Circuit denies qualified immunity to two former SFPD inspectors accused of fabricating evidence that led to Joaquin Ciria's 32-year wrongful imprisonment, holding that the right not to be charged based on deliberately fabricated evidence was clearly established by 1990.

Ninth Circuit Court of Appeals, Civil Procedure, Constitutional Law, Criminal Law

United States v. $1,106,775 in U.S. Currency — Ninth Circuit En Banc Limits Government’s Power to End Civil Forfeiture Cases Through Discovery Sanctions

The Ninth Circuit, sitting en banc, reverses a district court that ended a $1.1 million civil forfeiture case as a discovery sanction, holding that the claimant established standing and gave the government enough information to investigate his ownership claim.

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