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REPLACEMENT COPY OF TUESDAY, AUGUST 19, 2025

Name Category Published
People v. Wiley
Overruling *People v. Towne*, California Supreme Court determined that trial court, in imposing the upper term based on aggravating facts not decided by a jury, engaged in impermissible fact finding. 		Criminal Law and Procedure CASC Jun. 27, 2025
People v. Trent
Vacatur of defendant's murder conviction under Penal Code section 1172.6 rendered his gang offense "nonfinal" for purposes of the retroactive application of Assembly Bill No. 333. 		Criminal Law and Procedure 3DCA Jun. 26, 2025
People v. Dixon
Criminal defendant was not eligible to have his death sentence reduced under Penal Code Section 1172.75 because habeas corpus remained the exclusive method for collaterally attacking such a sentence. 		Criminal Law and Procedure 2DCA/7 Jun. 26, 2025
People v. Munoz
Despite not requiring unanimity amongst jurors as to which specific overt act was required for conspiracy to commit murder, jury instructions did not violate Sixth Amendment. 		Criminal Law and Procedure 1DCA/5 Jun. 26, 2025
In re Brissette
Penal code sections 1172.2 and 1170.1(c) are not irreconcilable--the latest court to impose a sentence in a multiple-case situation is the sentencing court, which then becomes the court to rule on compassionate release. 		Habeas Corpus, Criminal Law and Procedure 5DCA Jun. 25, 2025
People v. Ramos
No evidentiary error when trial court admitted transcripts from co-participant's jury trial to determine that defendant was ineligible for Penal Code section 1172.6 resentencing. 		Criminal Law and Procedure, Evidence 4DCA/3 Jun. 25, 2025
People v. Walts
Protective order forbidding convicted sex offender from contacting his ex-wife and two of his children was inappropriate where they were not named as victims of his underlying offense of conviction. 		Criminal Law and Procedure 5DCA Jun. 25, 2025
People v. Barrett
Trial court did not abuse its discretion in allowing evidence of defendant's violent character after defense counsel sought to introduce evidence of victim's violent character. 		Criminal Law and Procedure CASC Jun. 24, 2025
Esteras v. U.S.
District court considering revoking supervised release may not consider whether the punishment reflects the seriousness of the offense, promotes respect for the law, or provides just punishment for the offense. 		Criminal Law and Procedure USSC Jun. 23, 2025
People v. Sinay
Trial court retained jurisdiction to award over $900,000 restitution to victim's family 30 years after defendant's initial sentencing. 		Criminal Law and Procedure 2DCA/6 Jun. 19, 2025
U.S. v. Barry
Probable cause existed to search non-residence apartment under the parolee-search condition exception where parolee had a key to the apartment and showed intimate familiarity with it. 		Criminal Law and Procedure, Constitutional Law 9th Jun. 18, 2025
People v. American Surety Co.
Because criminal court failed to forfeit bond after defendant's initial disappearance, it lost jurisdiction and civil court erred in not vacating forfeiture and exonerating bail. 		Criminal Law and Procedure 2DCA/6 Jun. 18, 2025
People v. Lewis
Issuance of involuntary antipsychotic medication order without a full evidentiary hearing did not violate defendant's procedural due process rights. 		Criminal Law and Procedure, Constitutional Law 1DCA/2 Jun. 13, 2025
Rivers v. Guerrero
Petition filed after district court has entered judgment on an initial habeas petition but before appeal is resolved qualifies as a successive petition and must satisfy AEDPA's requirements. 		Criminal Law and Procedure USSC Jun. 13, 2025
Brown v. Attorney General for the State of Nevada
Unplanned ex parte contact between witness for prosecution, her friend, and several jurors was trial error but did not warrant relief because it did not prejudice the defendant. 		Criminal Law and Procedure 9th Jun. 13, 2025
Modification: People v. Jasso
Admission of detective's testimony regarding accomplice's friend's statements made during interview was not error where accomplice's statements were against his interest and defense counsel did not object to detective's testimony. 		Criminal Law and Procedure CASC Jun. 13, 2025
People v. Ortega
Trial court properly denied youthful offender's Penal Code section 1170(d)(1)(A)'s resentencing request when defendant did not meet statutory requirements and equal protection argument was moot. 		Criminal Law and Procedure 4DCA/3 Jun. 16, 2025
People v. Wagstaff
By failing to raise the issue to the trial court, Black defendant forfeited his argument that trial court's statement "you're a strong young buck" violated the Racial Justice Act. 		Criminal Law and Procedure 6DCA Jun. 16, 2025
People v. Wilson
Defense counsel was not ineffective as a matter of law for failing to object to prosecutor's referral to the Black defendant as a "gorilla pimp" during closing arguments to the jury. 		Criminal Law and Procedure 2DCA/6 Jun. 11, 2025
People v. Nixon
Where defendant used social media to make death threats, complete ban from social media as a condition of release was not unconstitutionally overbroad. 		Criminal Law and Procedure 3DCA Jun. 9, 2025
People v. Nino
Trial court improperly denied Penal Code section 1172.6 resentencing request when, despite being the actual killer, defendant could have been convicted under the now invalid second-degree felony murder statute. 		Criminal Law and Procedure 2DCA/7 Jun. 6, 2025
People v. Grajeda
Resentencing court's decision denying defendant's request to postpone Penal Code section 1172.75 hearing (invalid prison priors) to allow him to speak with his attorney violated his right to counsel. 		Criminal Law and Procedure 2DCA/7 Jun. 5, 2025
In re: Joshua Davis
Mandatory Victims Restitution Act permitted victims to seek amended restitution order where they discovered the original order did not include losses that were unclaimed due to government error. 		Criminal Law and Procedure 9th Jun. 4, 2025
Johnson v. U.S.
A conviction of Hobbs Act robbery under a Pinkerton theory of liability functions as a valid predicate "crime of violence" under 18 U.S.C. section 942(c) (firearm enhancement). 		Criminal Law and Procedure 9th Jun. 4, 2025
People v. Cabrera
Because a 50-year-to-life sentence is the functional equivalent of a life without parole sentence, defendant was eligible for youthful offender relief. 		Criminal Law and Procedure, Juveniles 2DCA/5 Jun. 3, 2025
People v. Emanuel
Trial court improperly dismissed petition for resentencing because the evidence was insufficient to support a finding that unarmed defendant acted with reckless indifference to human life. 		Criminal Law and Procedure CASC Jun. 3, 2025
Schneider v. Superior Court (Los Angeles County Sheriff's Dept.)
Although Brady motions seeking discovery of exculpatory information in confidential personnel files must use procedures in the Pitchess statutes, the Pitchess limitations on disclosures do not apply to Brady motions. 		Criminal Law and Procedure 2DCA/7 Jun. 2, 2025
People v. The North River Insurance Company
Trial court erroneously denied surety's request to exonerate bail and set aside forfeiture, where defendant failed to appear in court but subsequently landed in custody in another county. 		Criminal Law and Procedure 5DCA May 30, 2025
U.S. v. Puig Valdes
Defendant's plea agreement withdrawal before the agreement was entered and accepted by the court rendered the factual basis of the plea agreement inadmissible. 		Criminal Law and Procedure, Evidence 9th May 30, 2025
People v. Duenas
Granting defendant's habeas petition vacated the sentence, rendered the judgment nonfinal, and entitled defendant to full resentencing, including application of subsequent ameliorative legislation. 		Criminal Law and Procedure 2DCA/8 May 29, 2025
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