continuing validity rule (California) · Go Syfert
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continuing validity rule in California

15 California opinions name it 2 courts 1970–2020 0 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (21)

CaseFollowedCited
Thornton v. Dennis M.green
cal · 1969 · cited in 3 California opinions naming this issue, 1970–1972
2 sentences

1972The courts have created the defense as a control on illegal police conduct ‘out of regard for [the court’s] own dignity, and in the exercise of its power and the performance of its duty to formulate and apply proper standards for judicial enforcement of the criminal law.’ (People v. Benford, supra, 53 Cal.2d 1, 9 [ 345 P.2d 928 ].) Moreover, this court acknowledged the continuing validity of the rule of the Valverde case in In re Dennis M. (1969) 70 Cal.2d 444, 457, fn. 10 [ 75 Cal.Rptr. 1 , 450 P.2d 296 ]. 3 ” The rale of Winship is not contrary to the rale of Moran.

1972The courts have created the defense as a control on illegal police conduct ‘out of regard for [the court’s] own dignity, and in the exercise of its power and the performance of its duty to formulate and apply proper standards for judicial enforcement of the criminal law.’ (People v. Benford, supra, 53 Cal.2d 1, 9 [ 345 P.2d 928 ].) Moreover, this court acknowledged the continuing validity of the rule of the Valverde case in In re Dennis M. (1969) 70 Cal.2d 444, 457, fn. 10 [ 75 Cal.Rptr. 1 , 450 P.2d 296 ]. 3 ” The rale of Winship is not contrary to the rale of Moran.

33
People v. Pratergreen
calctapp · 1977 · cited in 2 California opinions naming this issue, 2013–2013
2 sentences

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

22
People v. Correagreen
cal · 2012 · cited in 2 California opinions naming this issue, 2013–2013
2 sentences

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

22
People v. Benfordgreen
cal · 1959 · cited in 3 California opinions naming this issue, 1970–1972
2 sentences

1972The courts have created the defense as a control on illegal police conduct ‘out of regard for [the court’s] own dignity, and in the exercise of its power and the performance of its duty to formulate and apply proper standards for judicial enforcement of the criminal law.’ (People v. Benford, supra, 53 Cal.2d 1, 9 [ 345 P.2d 928 ].) Moreover, this court acknowledged the continuing validity of the rule of the Valverde case in In re Dennis M. (1969) 70 Cal.2d 444, 457, fn. 10 [ 75 Cal.Rptr. 1 , 450 P.2d 296 ]. 3 ” The rale of Winship is not contrary to the rale of Moran.

1972The courts have created the defense as a control on illegal police conduct ‘out of regard for [the court’s] own dignity, and in the exercise of its power and the performance of its duty to formulate and apply proper standards for judicial enforcement of the criminal law.’ (People v. Benford, supra, 53 Cal.2d 1, 9 [ 345 P.2d 928 ].) Moreover, this court acknowledged the continuing validity of the rule of the Valverde case in In re Dennis M. (1969) 70 Cal.2d 444, 457, fn. 10 [ 75 Cal.Rptr. 1 , 450 P.2d 296 ]. 3 ” The rale of Winship is not contrary to the rale of Moran.

13
People v. Wattersongreen
calctapp · 1991 · cited in 2 California opinions naming this issue, 2006–2006
2 sentences

2006(See People v. Watterson (1991) 234 Cal.App.3d 942, 944-947 , 286 Cal.Rptr. 13 ; People v. Thomas, supra, 231 Cal.App.3d at pp. 304-306, 282 Cal.Rptr. 258 .) We need not decide this question, because those cases, even if still valid, are irrelevant to the issue here.

2006(See People v. Watterson (1991) 234 Cal.App.3d 942, 944-947 , 286 Cal.Rptr. 13 ; People v. Thomas, supra, 231 Cal.App.3d at pp. 304-306, 282 Cal.Rptr. 258 .) We need not decide this question, because those cases, even if still valid, are irrelevant to the issue here.

12
People v. Gallardogreen
cal · 2017 · cited in 1 California opinions naming this issue, 2019–2019
1 sentence

2019(See, e.g., People v. Anderson (1987) 43 Cal.3d 1104 , 1138–1141; id. at p. 1141 [“it is our duty to reconsider” precedent when subsequent United States Supreme Court decisions cast doubt on our reading of that court’s earlier decisions]; see also, e.g., People v. Gallardo (2017) 4 Cal.5th 120 , 134–135 [reconsidering precedent in light of reasoning of subsequent high court decisions].) Of necessity, then, we retain “the flexibility to consider emerging United States Supreme Court case law when considering earlier decisions on federal issues . . . even when the 17 PEOPLE v. LOPEZ Opinion of th

11
People v. Reedgreen
cal · 2006 · cited in 1 California opinions naming this issue, 2016–2016
1 sentence

2016But the court stated it did not have to decide that question because Rogers and two other authorities, even if valid, were not relevant to the elements test issue decided in Reed. ( Reed, supra, at p. 1228, fn. 2 .) Justice Moreno in a concurring and dissenting opinion in Reed argued for the application of both the elements test and a modified version of the accusatory pleading test when deciding whether multiple convictions were proper.

11
Samaniego v. Empire Today, LLCgreen
calctapp · 2012 · cited in 1 California opinions naming this issue, 2013–2013
1 sentence

2013(Concepcion, at p. 1746.) Third, the California Courts of Appeal have recognized that “Concepcion did not eliminate state law unconscionability as a defense to the enforcement of arbitration agreements subject to the Federal Arbitration Act.” (Sparks v. Vista Del Mar Child and Family Services (2012) 207 Cal.App.4th 1511, 1519 ; accord, Nelsen v. Legacy Partners Residential, Inc. (2012) 207 Cal.App.4th 1115 , 1123– 1126; Samaniego v. Empire Today, LLC (2012) 205 Cal.App.4th 1138, 1141, 1150 .) In Concepcion, the court held that, under the Federal Arbitration Act, a state may not rely on categor

11
Nelsen v. Legacy Partners Residential, Inc.green
calctapp · 2012 · cited in 1 California opinions naming this issue, 2013–2013
1 sentence

2013(Concepcion, at p. 1746.) Third, the California Courts of Appeal have recognized that “Concepcion did not eliminate state law unconscionability as a defense to the enforcement of arbitration agreements subject to the Federal Arbitration Act.” (Sparks v. Vista Del Mar Child and Family Services (2012) 207 Cal.App.4th 1511, 1519 ; accord, Nelsen v. Legacy Partners Residential, Inc. (2012) 207 Cal.App.4th 1115 , 1123– 1126; Samaniego v. Empire Today, LLC (2012) 205 Cal.App.4th 1138, 1141, 1150 .) In Concepcion, the court held that, under the Federal Arbitration Act, a state may not rely on categor

11
People v. Nguyengreen
cal · 2001 · cited in 1 California opinions naming this issue, 2009–2009
2 sentences

2009“It has been settled law for nearly a century that an essential element of the crime of robbery is that property be taken from the possession of the victim.” (People v. Nguyen (2000) 24 Cal.4th 756, 762 [ 102 Cal.Rptr.2d 548 , 14 P.3d 221 ] (Nguyen).) We affirmed the continuing validity of that principle in Nguyen , overruling an appellate court decision, People v. Mai (1994) 22 Cal.App.4th 117 [ 27 Cal.Rptr.2d 141 ], that had dispensed entirely with the requirement of possession.

2009“It has been settled law for nearly a century that an essential element of the crime of robbery is that property be taken from the possession of the victim.” (People v. Nguyen (2000) 24 Cal.4th 756, 762 [ 102 Cal.Rptr.2d 548 , 14 P.3d 221 ] (Nguyen).) We affirmed the continuing validity of that principle in Nguyen , overruling an appellate court decision, People v. Mai (1994) 22 Cal.App.4th 117 [ 27 Cal.Rptr.2d 141 ], that had dispensed entirely with the requirement of possession.

11
United States v. Kevin Williams-Davisgreen
cadc · 1996 · cited in 1 California opinions naming this issue, 2004–2004
1 sentence

2004(See, e.g., U.S. v. Dutkel (9th Cir.1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir.1998) 143 F.3d 923, 934 ["the Remmer presumption of prejudice cannot survive Phillips and Olano , " and remains applicable "only when the court determines that prejudice is likely"]; U.S. v. Williams-Davis (D.C.Cir.1996) 90 F.3d 490, 496 [presumption exists but is "not ... particularly forceful"]; U.S. v. Zelinka (6th Cir.1988) 862 F.2d 92, 95 [" Smith v. Phillips reinterpreted Remmer to shift the burden of showing bias to the defendant rather than placin

11
cluster 509297green
ca4 · 1988 · cited in 1 California opinions naming this issue, 2004–2004
1 sentence

2004(See, e.g., U.S. v. Dutkel (9th Cir.1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir.1998) 143 F.3d 923, 934 ["the Remmer presumption of prejudice cannot survive Phillips and Olano , " and remains applicable "only when the court determines that prejudice is likely"]; U.S. v. Williams-Davis (D.C.Cir.1996) 90 F.3d 490, 496 [presumption exists but is "not ... particularly forceful"]; U.S. v. Zelinka (6th Cir.1988) 862 F.2d 92, 95 [" Smith v. Phillips reinterpreted Remmer to shift the burden of showing bias to the defendant rather than placin

11
United States v. Robert Zelinkagreen
ca6 · 1988 · cited in 1 California opinions naming this issue, 2004–2004
1 sentence

2004(See, e.g., U.S. v. Dutkel (9th Cir.1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir.1998) 143 F.3d 923, 934 ["the Remmer presumption of prejudice cannot survive Phillips and Olano , " and remains applicable "only when the court determines that prejudice is likely"]; U.S. v. Williams-Davis (D.C.Cir.1996) 90 F.3d 490, 496 [presumption exists but is "not ... particularly forceful"]; U.S. v. Zelinka (6th Cir.1988) 862 F.2d 92, 95 [" Smith v. Phillips reinterpreted Remmer to shift the burden of showing bias to the defendant rather than placin

11
United States v. Mark Sylvester, Leon Brown, and Willie Earl Culleygreen
ca5 · 1998 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(See, e.g., U.S. v. Dutkel (9th Cir. 1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir. 1998) 143 F.3d 923, 934 [“the Remmer presumption of prejudice cannot survive Phillips and Olano,” and remains applicable “only when the court determines that prejudice is likely”]; U.S. v. Williams-Davis (D.C.

2004(See, e.g., U.S. v. Dutkel (9th Cir.1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir.1998) 143 F.3d 923, 934 ["the Remmer presumption of prejudice cannot survive Phillips and Olano , " and remains applicable "only when the court determines that prejudice is likely"]; U.S. v. Williams-Davis (D.C.Cir.1996) 90 F.3d 490, 496 [presumption exists but is "not ... particularly forceful"]; U.S. v. Zelinka (6th Cir.1988) 862 F.2d 92, 95 [" Smith v. Phillips reinterpreted Remmer to shift the burden of showing bias to the defendant rather than placin

11
United States v. Michael Vernon Dutkelgreen
ca9 · 1999 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(See, e.g., U.S. v. Dutkel (9th Cir. 1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir. 1998) 143 F.3d 923, 934 [“the Remmer presumption of prejudice cannot survive Phillips and Olano,” and remains applicable “only when the court determines that prejudice is likely”]; U.S. v. Williams-Davis (D.C.

2004(See, e.g., U.S. v. Dutkel (9th Cir.1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir.1998) 143 F.3d 923, 934 ["the Remmer presumption of prejudice cannot survive Phillips and Olano , " and remains applicable "only when the court determines that prejudice is likely"]; U.S. v. Williams-Davis (D.C.Cir.1996) 90 F.3d 490, 496 [presumption exists but is "not ... particularly forceful"]; U.S. v. Zelinka (6th Cir.1988) 862 F.2d 92, 95 [" Smith v. Phillips reinterpreted Remmer to shift the burden of showing bias to the defendant rather than placin

11
Lucchesi v. Giannini & Uniackgreen
calctapp · 1984 · cited in 1 California opinions naming this issue, 1996–1996
2 sentences

1996(Ibid.; see also Gause v. McClelland (1951) 102 Cal.App.2d 762, 764 [ 228 P.2d 91 ]; Black v. Knight (1919) 44 Cal.App. 756, 770 [ 187 P. 89 ]; Lucchesi v. Giannini & Uniack (1984) 158 Cal.App.3d 777, 785-788 [ 205 Cal.Rptr. 62 ].) The several references in Sheldon Appel to freedom from “unjustifiable” and “unreasonable” litigation suggest the continuing validity of the rule that a prior determination of “probable cause” cannot be second-guessed in a malicious prosecution action even where the judgment in the underlying action is reversed on appeal. 8 It follows necessarily that where, as here

1996(Ibid.; see also Gause v. McClelland (1951) 102 Cal.App.2d 762, 764 [ 228 P.2d 91 ]; Black v. Knight (1919) 44 Cal.App. 756, 770 [ 187 P. 89 ]; Lucchesi v. Giannini & Uniack (1984) 158 Cal.App.3d 777, 785-788 [ 205 Cal.Rptr. 62 ].) The several references in Sheldon Appel to freedom from “unjustifiable” and “unreasonable” litigation suggest the continuing validity of the rule that a prior determination of “probable cause” cannot be second-guessed in a malicious prosecution action even where the judgment in the underlying action is reversed on appeal. 8 It follows necessarily that where, as here

11
Gause v. McClellandgreen
calctapp · 1951 · cited in 1 California opinions naming this issue, 1996–1996
2 sentences

1996(Ibid.; see also Gause v. McClelland (1951) 102 Cal.App.2d 762, 764 [ 228 P.2d 91 ]; Black v. Knight (1919) 44 Cal.App. 756, 770 [ 187 P. 89 ]; Lucchesi v. Giannini & Uniack (1984) 158 Cal.App.3d 777, 785-788 [ 205 Cal.Rptr. 62 ].) The several references in Sheldon Appel to freedom from “unjustifiable” and “unreasonable” litigation suggest the continuing validity of the rule that a prior determination of “probable cause” cannot be second-guessed in a malicious prosecution action even where the judgment in the underlying action is reversed on appeal. 8 It follows necessarily that where, as here

1996(Ibid.; see also Gause v. McClelland (1951) 102 Cal.App.2d 762, 764 [ 228 P.2d 91 ]; Black v. Knight (1919) 44 Cal.App. 756, 770 [ 187 P. 89 ]; Lucchesi v. Giannini & Uniack (1984) 158 Cal.App.3d 777, 785-788 [ 205 Cal.Rptr. 62 ].) The several references in Sheldon Appel to freedom from “unjustifiable” and “unreasonable” litigation suggest the continuing validity of the rule that a prior determination of “probable cause” cannot be second-guessed in a malicious prosecution action even where the judgment in the underlying action is reversed on appeal. 8 It follows necessarily that where, as here

11
Black v. Knightgreen
calctapp · 1919 · cited in 1 California opinions naming this issue, 1996–1996
11
People v. Figueroagreen
cal · 1986 · cited in 1 California opinions naming this issue, 1990–1990
11
People v. Kiihoagreen
cal · 1960 · cited in 1 California opinions naming this issue, 1970–1970
11
People v. Perezgreen
cal · 1965 · cited in 1 California opinions naming this issue, 1970–1970
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
People v. Thomas green
calctapp · 1991
2 sentences

2016(Ibid.) Reed further noted the continuing validity of the rule announced in Rogers was dubious in light of more recent authorities, citing Watterson and People v. Thomas (1991) 231 Cal.App.3d 299, 304-305 .

2006(See People v. Watterson (1991) 234 Cal.App.3d 942, 944-947 , 286 Cal.Rptr. 13 ; People v. Thomas, supra, 231 Cal.App.3d at pp. 304-306, 282 Cal.Rptr. 258 .) We need not decide this question, because those cases, even if still valid, are irrelevant to the issue here.

22006–2016
People v. Jones green
cal · 2012
2 sentences

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

22013–2013
People v. Mesa green
cal · 2012
2 sentences

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

2013(People v. Correa (2012) 54 Cal.4th 331, 334, 344 .) 10 People v. Prater (1977) 71 Cal.App.3d 695, 699 [punishment permitted on each count of assault with a firearm under the “multiple victim” exception].) O’Sullivan asks us to ignore the “multiple victim” exception on the grounds Neal v. State of California was wrongly decided on that issue and the continuing validity of the exception has been undercut by recent Supreme Court decisions in People v. Jones (2012) 54 Cal.4th 350 and People v. Mesa (2012) 54 Cal.4th 191 .

22013–2013
People v. Arbuckle green
cal · 1978
2 sentences

2020Because of that discretion, “the propensity in sentencing demonstrated by a particular judge is an inherently significant factor in the defendant’s decision to enter a guilty plea.” (Id. at p. 757.) Recently, in K.R. v. Superior Court (2017) 3 Cal.5th 295 (K.R.), the Supreme Court affirmed the continuing validity of the rule announced in Arbuckle, supra, 22 Cal.3d 749 : “[W]e adhere to the plain and original understanding of Arbuckle that in every plea in both adult and juvenile court, an implied term is that the judge who accepts the plea will be the judge who pronounces sentence.” ( K.R., su

2020Because of that discretion, “the propensity in sentencing demonstrated by a particular judge is an inherently significant factor in the defendant’s decision to enter a guilty plea.” (Id. at p. 757.) Recently, in K.R. v. Superior Court (2017) 3 Cal.5th 295 (K.R.), the Supreme Court affirmed the continuing validity of the rule announced in Arbuckle, supra, 22 Cal.3d 749 : “[W]e adhere to the plain and original understanding of Arbuckle that in every plea in both adult and juvenile court, an implied term is that the judge who accepts the plea will be the judge who pronounces sentence.” ( K.R., su

12020–2020
K.R. v. Superior Court of Sacramento Cnty. green
cal · 2017
2 sentences

2020Because of that discretion, “the propensity in sentencing demonstrated by a particular judge is an inherently significant factor in the defendant’s decision to enter a guilty plea.” (Id. at p. 757.) Recently, in K.R. v. Superior Court (2017) 3 Cal.5th 295 (K.R.), the Supreme Court affirmed the continuing validity of the rule announced in Arbuckle, supra, 22 Cal.3d 749 : “[W]e adhere to the plain and original understanding of Arbuckle that in every plea in both adult and juvenile court, an implied term is that the judge who accepts the plea will be the judge who pronounces sentence.” ( K.R., su

2020Because of that discretion, “the propensity in sentencing demonstrated by a particular judge is an inherently significant factor in the defendant’s decision to enter a guilty plea.” (Id. at p. 757.) Recently, in K.R. v. Superior Court (2017) 3 Cal.5th 295 (K.R.), the Supreme Court affirmed the continuing validity of the rule announced in Arbuckle, supra, 22 Cal.3d 749 : “[W]e adhere to the plain and original understanding of Arbuckle that in every plea in both adult and juvenile court, an implied term is that the judge who accepts the plea will be the judge who pronounces sentence.” ( K.R., su

12020–2020
MA Carpenter's Coll. v. U.S. Fidelity & Guar green
ca1 · 2000
1 sentence

2019Co. (1st Cir. 2000) 215 F.3d 136 , 141.) This is so even when the high court’s decision does not directly address the continuing validity of the rule in question; the high court’s guidance may nonetheless erode the analytical foundations of the old rule or make clear that the rule is substantially out of step with the broader body of relevant federal law.

12019–2019
People v. Anderson red
cal · 1987
1 sentence

2019(See, e.g., People v. Anderson (1987) 43 Cal.3d 1104 , 1138–1141; id. at p. 1141 [“it is our duty to reconsider” precedent when subsequent United States Supreme Court decisions cast doubt on our reading of that court’s earlier decisions]; see also, e.g., People v. Gallardo (2017) 4 Cal.5th 120 , 134–135 [reconsidering precedent in light of reasoning of subsequent high court decisions].) Of necessity, then, we retain “the flexibility to consider emerging United States Supreme Court case law when considering earlier decisions on federal issues . . . even when the 17 PEOPLE v. LOPEZ Opinion of th

12019–2019
Sparks v. Vista Del Mar Child & Family Services green
calctapp · 2012
1 sentence

2013(Concepcion, at p. 1746.) Third, the California Courts of Appeal have recognized that “Concepcion did not eliminate state law unconscionability as a defense to the enforcement of arbitration agreements subject to the Federal Arbitration Act.” (Sparks v. Vista Del Mar Child and Family Services (2012) 207 Cal.App.4th 1511, 1519 ; accord, Nelsen v. Legacy Partners Residential, Inc. (2012) 207 Cal.App.4th 1115 , 1123– 1126; Samaniego v. Empire Today, LLC (2012) 205 Cal.App.4th 1138, 1141, 1150 .) In Concepcion, the court held that, under the Federal Arbitration Act, a state may not rely on categor

12013–2013
People v. Van Mai green
calctapp · 1994
2 sentences

2009“It has been settled law for nearly a century that an essential element of the crime of robbery is that property be taken from the possession of the victim.” (People v. Nguyen (2000) 24 Cal.4th 756, 762 [ 102 Cal.Rptr.2d 548 , 14 P.3d 221 ] (Nguyen).) We affirmed the continuing validity of that principle in Nguyen , overruling an appellate court decision, People v. Mai (1994) 22 Cal.App.4th 117 [ 27 Cal.Rptr.2d 141 ], that had dispensed entirely with the requirement of possession.

2009“It has been settled law for nearly a century that an essential element of the crime of robbery is that property be taken from the possession of the victim.” (People v. Nguyen (2000) 24 Cal.4th 756, 762 [ 102 Cal.Rptr.2d 548 , 14 P.3d 221 ] (Nguyen).) We affirmed the continuing validity of that principle in Nguyen , overruling an appellate court decision, People v. Mai (1994) 22 Cal.App.4th 117 [ 27 Cal.Rptr.2d 141 ], that had dispensed entirely with the requirement of possession.

12009–2009
Remmer v. United States green
scotus · 1954
2 sentences

2004It is reasonable to infer that the declarations of K.A. and E.M. both refer to the same statement by B.P., in which case E.M.'s declaration demonstrates that it was said during deliberations. [3] In the wake of two more recent decisions by the United States Supreme Court ( United States v. Olano (1993) 507 U.S. 725 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 ; Smith v. Phillips (1982) 455 U.S. 209 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ), there is doubt as to the continuing validity of the presumption of prejudice articulated in Remmer v. United States, supra, 347 U.S. 227 , 74 S.Ct. 450 , 98 L.Ed. 654 .

2004It is reasonable to infer that the declarations of K.A. and E.M. both refer to the same statement by B.P., in which case E.M.'s declaration demonstrates that it was said during deliberations. [3] In the wake of two more recent decisions by the United States Supreme Court ( United States v. Olano (1993) 507 U.S. 725 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 ; Smith v. Phillips (1982) 455 U.S. 209 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ), there is doubt as to the continuing validity of the presumption of prejudice articulated in Remmer v. United States, supra, 347 U.S. 227 , 74 S.Ct. 450 , 98 L.Ed. 654 .

12004–2004
United States v. Olano green
scotus · 1993
2 sentences

2004It is reasonable to infer that the declarations of K.A. and E.M. both refer to the same statement by B.P., in which case E.M.'s declaration demonstrates that it was said during deliberations. [3] In the wake of two more recent decisions by the United States Supreme Court ( United States v. Olano (1993) 507 U.S. 725 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 ; Smith v. Phillips (1982) 455 U.S. 209 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ), there is doubt as to the continuing validity of the presumption of prejudice articulated in Remmer v. United States, supra, 347 U.S. 227 , 74 S.Ct. 450 , 98 L.Ed. 654 .

2004It is reasonable to infer that the declarations of K.A. and E.M. both refer to the same statement by B.P., in which case E.M.'s declaration demonstrates that it was said during deliberations. [3] In the wake of two more recent decisions by the United States Supreme Court ( United States v. Olano (1993) 507 U.S. 725 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 ; Smith v. Phillips (1982) 455 U.S. 209 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ), there is doubt as to the continuing validity of the presumption of prejudice articulated in Remmer v. United States, supra, 347 U.S. 227 , 74 S.Ct. 450 , 98 L.Ed. 654 .

12004–2004
People v. Nesler green
cal · 1997
2 sentences

2004(See, e.g., U.S. v. Dutkel (9th Cir.1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir.1998) 143 F.3d 923, 934 ["the Remmer presumption of prejudice cannot survive Phillips and Olano , " and remains applicable "only when the court determines that prejudice is likely"]; U.S. v. Williams-Davis (D.C.Cir.1996) 90 F.3d 490, 496 [presumption exists but is "not ... particularly forceful"]; U.S. v. Zelinka (6th Cir.1988) 862 F.2d 92, 95 [" Smith v. Phillips reinterpreted Remmer to shift the burden of showing bias to the defendant rather than placin

2004(See, e.g., U.S. v. Dutkel (9th Cir.1999) 192 F.3d 893, 894-896 [presumption applies to cases of jury tampering]; U.S. v. Sylvester (5th Cir.1998) 143 F.3d 923, 934 ["the Remmer presumption of prejudice cannot survive Phillips and Olano , " and remains applicable "only when the court determines that prejudice is likely"]; U.S. v. Williams-Davis (D.C.Cir.1996) 90 F.3d 490, 496 [presumption exists but is "not ... particularly forceful"]; U.S. v. Zelinka (6th Cir.1988) 862 F.2d 92, 95 [" Smith v. Phillips reinterpreted Remmer to shift the burden of showing bias to the defendant rather than placin

12004–2004
Smith v. Phillips green
scotus · 1982
2 sentences

2004It is reasonable to infer that the declarations of K.A. and E.M. both refer to the same statement by B.P., in which case E.M.'s declaration demonstrates that it was said during deliberations. [3] In the wake of two more recent decisions by the United States Supreme Court ( United States v. Olano (1993) 507 U.S. 725 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 ; Smith v. Phillips (1982) 455 U.S. 209 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ), there is doubt as to the continuing validity of the presumption of prejudice articulated in Remmer v. United States, supra, 347 U.S. 227 , 74 S.Ct. 450 , 98 L.Ed. 654 .

2004It is reasonable to infer that the declarations of K.A. and E.M. both refer to the same statement by B.P., in which case E.M.'s declaration demonstrates that it was said during deliberations. [3] In the wake of two more recent decisions by the United States Supreme Court ( United States v. Olano (1993) 507 U.S. 725 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 ; Smith v. Phillips (1982) 455 U.S. 209 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ), there is doubt as to the continuing validity of the presumption of prejudice articulated in Remmer v. United States, supra, 347 U.S. 227 , 74 S.Ct. 450 , 98 L.Ed. 654 .

12004–2004
In Re WINSHIP green
scotus · 1970
11972–1972

Statutes the citing opinions construe

CA § Cal. Penal Code § 1538.5 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 15 (1970–2020) PA 15 (1970–2018) CT 8 (1991–2004) MI 6 (1976–2019) IL 4 (1964–1981) LA 3 (1975–1987) MA 3 (1987–2015) KS 3 (2015–2017) ME 3 (2010–2018) NY 3 (1948–1983) TX 3 (1980–2015) WY 2 (1986–2010) FL 2 (1979–1994)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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