The Impact of Supreme Court Decisions on California Case Law 

The Impact of Supreme Court Decisions on California Case Law 

Estimated reading time: 9 minutes

The decisions of the U.S. Supreme Court significantly influence California case law, guiding how state courts interpret key legal issues, particularly those related to constitutional rights, federal laws, and nationwide legal standards. When the Supreme Court issues rulings on matters like civil liberties, criminal justice, or regulatory authority, California courts are obligated to apply these precedents within their rulings. However, the state’s unique legal culture and progressive policies sometimes lead to distinct interpretations and adaptations of these rulings. California courts often integrate federal mandates while addressing state-specific statutes and concerns, creating a dynamic legal landscape where national and state interests intersect. For California attorneys, staying informed about Supreme Court decisions is critical to understanding how federal rulings may reshape state law, influence judicial opinions, and impact litigation strategies across various practice areas. We’ll explore some of these decisions below. 

Price v. Civil Service Commission (1980)

In Price v. Civil Service Commission, the California Supreme Court addressed the constitutionality of a race-conscious hiring program implemented by Sacramento County to remedy past discriminatory practices. The Court relied heavily on U.S. Supreme Court precedents, particularly Steelworkers v. Weber (1979) and Regents of the University of California v. Bakke (1978), to inform its decision.

In Weber, the U.S. Supreme Court upheld an affirmative action plan implemented by a private employer to address the underrepresentation of Black employees in skilled craft positions. The Court ruled that Title VII of the Civil Rights Act did not prohibit voluntary affirmative action plans aimed at eliminating historical racial imbalances. Similarly, the majority in Price concluded that the Sacramento County Civil Service Commission’s race-conscious hiring program was constitutional, as it was designed to remedy the effects of past discrimination and did not unduly harm the interests of non-minority applicants.

The majority also drew on the reasoning in Bakke, where the U.S. Supreme Court upheld the principle that race-conscious measures could be used by governmental entities under certain circumstances, particularly when addressing specific instances of past discrimination. The Bakke decision distinguished between permissible affirmative action programs designed to rectify identified discrimination and impermissible programs aimed solely at achieving racial balance.

In Price, the California Supreme Court used these U.S. Supreme Court rulings to justify its decision, emphasizing that the Commission’s affirmative action plan was temporary, targeted, and designed to correct documented discriminatory hiring practices. Thus, the Court concluded that such race-conscious hiring measures, when carefully tailored and limited in scope, are consistent with both state and federal equal protection principles.

Johnson v. California (2005)

Johnson arose from the California Supreme Court’s use of a “more likely than not” standard to assess whether a defendant had established a prima facie case of racial discrimination under Batson v. Kentucky (1986), a landmark U.S. Supreme Court decision. In Batson, the Court outlined a three-step process to evaluate whether peremptory challenges during jury selection were racially motivated.

The issue in Johnson was whether California’s requirement that a defendant prove it was “more likely than not” that the prosecutor’s peremptory challenges were based on race aligned with Batson’s framework. The U.S. Supreme Court held that California’s standard was too restrictive and inconsistent with Batson. Under Batson, a defendant need only provide evidence sufficient to raise an “inference” of discrimination, not meet the higher burden of proving it was “more likely than not.”

Justice Stevens, writing for the majority, emphasized that the Batson process was designed to protect both the defendant’s right to a fair trial and the integrity of the jury system by preventing racial discrimination in jury selection. The Court concluded that California’s standard placed an undue burden on defendants, making it more difficult to challenge racially discriminatory jury strikes. The Court reversed the California Supreme Court’s decision and remanded the case, reinforcing the less onerous “inference of discrimination” standard from Batson as the appropriate threshold for establishing a prima facie case of racial bias.

This decision underscored the U.S. Supreme Court’s role in ensuring that lower courts adhere to constitutional standards regarding jury selection and equal protection.

People v. Franklin (2016)

In Franklin, the California Supreme Court addressed the constitutionality of sentencing juveniles to long prison terms, particularly in light of recent U.S. Supreme Court decisions that protect juvenile offenders from overly harsh sentences. The majority opinion was heavily shaped by U.S. Supreme Court precedents, particularly Miller v. Alabama (2012) and Graham v. Florida (2010).

Miller established that mandatory life without parole (LWOP) sentences for juveniles convicted of homicide violated the Eighth Amendment, as juveniles possess unique characteristics like immaturity, impulsiveness, and a greater capacity for change, which must be considered when sentencing. Graham similarly held that juveniles cannot be sentenced to LWOP for non-homicide offenses. Both cases emphasized that children are “constitutionally different” from adults for sentencing purposes.

The Franklin court relied on these rulings to evaluate whether a 50-year-to-life sentence for a juvenile offender, with the possibility of parole after 25 years (due to California’s newly enacted Senate Bill No. 260), was the “functional equivalent” of an unconstitutional LWOP sentence. The court ruled that the legislative changes, which provide juveniles with parole eligibility after 25 years, complied with Miller and Graham by ensuring that juvenile offenders have a “meaningful opportunity for release.” Therefore, Franklin’s 50-year sentence did not violate the Eighth Amendment, as he was eligible for parole within his lifetime, respecting the principles set forth by the U.S. Supreme Court regarding the distinct treatment of juvenile offenders.

People v. Buza (2018)

Buza upheld the constitutionality of California’s DNA Act, which mandates DNA collection from felony arrestees. The California Supreme Court’s reasoning was heavily influenced by the U.S. Supreme Court’s decision in Maryland v. King (2013). In King, the U.S. Supreme Court ruled that collecting DNA samples from individuals arrested for serious offenses, as part of routine booking procedures, was constitutional under the Fourth Amendment.

The majority in Buza applied the rationale from King, which likened DNA collection to fingerprinting and photographing during the booking process. The U.S. Supreme Court in King had emphasized that such identification procedures serve important governmental interests, including identifying suspects, solving past crimes, and ensuring that suspects appear for trial. The King decision also concluded that the minimal intrusion of a cheek swab was outweighed by these significant state interests, rendering the practice reasonable under the Fourth Amendment.

Similarly, the Buza court reasoned that California’s DNA collection requirement was reasonable, as it furthered the state’s interest in accurately identifying felony arrestees and linking them to other crimes. Despite minor differences between California’s law and Maryland’s, such as the broader scope of offenses triggering DNA collection in California, the majority found that these distinctions did not meaningfully alter the Fourth Amendment analysis established in King. The court concluded that the state’s interest in solving and preventing crime justified the collection of DNA from arrestees without requiring a warrant or independent suspicion. Thus, Maryland v. King played a pivotal role in guiding the Buza majority’s decision.

Sheetz v. County of El Dorado (2024)

George Sheetz challenged a $23,420 traffic impact fee imposed by El Dorado County, California, as a condition for issuing a residential building permit, arguing that it constituted an unlawful taking because it was not based on the specific traffic impact of his development but was applied broadly under a legislative scheme. Sheetz contended that the fee failed to meet the requirements set out in the U.S. Supreme Court’s decisions in Nollan v. California Coastal Commission and Dolan v. City of Tigard.

The lower courts, including the California Court of Appeal, upheld the fee, ruling that the Nollan/Dolan test applied only to administrative conditions imposed on a discretionary basis, not to fees imposed legislatively on a broad class of property owners. The courts reasoned that legislatively imposed fees were categorically exempt from the heightened scrutiny required by Nollan/Dolan, which ensures that permit conditions have an “essential nexus” to the government’s land-use interests and are “roughly proportional” to the development’s specific impact.

However, the U.S. Supreme Court disagreed with the lower courts, holding that the Takings Clause applies equally to legislative and administrative land-use conditions. The Court emphasized that nothing in the Constitution supports exempting legislative actions from ordinary takings analysis. The Court ruled that the Nollan/Dolan framework, which protects property owners from government exactions, applies to both legislative and administrative actions.

The Court vacated the lower court’s decision and remanded the case for further proceedings, instructing the lower courts to reconsider the fee using the Nollan/Dolan test to determine whether the fee was properly tailored to mitigate the specific traffic impacts of Sheetz’s development.

Let Continuing Education of the Bar (CEB) Guide Your Practice

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