due process clause in California

2026(Id. at p. 232; People v. Partida, supra, 37 Cal.4th at p. 439 [the admission of evidence, even if erroneous under state law, results in a due process violation only if it makes the trial fundamentally unfair].) In conclusion, we reject Ceja’s abuse of discretion and constitutional due process arguments regarding the trial court’s admission of the suicide attempt evidence.

2026Our Supreme Court has stated “the admission of evidence, 14. even if erroneous under state law, results in a due process violation only if it makes the trial fundamentally unfair.” (People v. Partida (2005) 37 Cal.4th 428, 439 .) “Absent fundamental unfairness, state law error in admitting evidence is subject to the traditional Watson test .…” (Ibid.; see generally People v. Fudge (1994) 7 Cal.4th 1075 , 1103–1104 [evaluating trial court’s ruling on hearsay objection under Watson]; People v. McDaniel (2019) 38 Cal.App.5th 986 , 1005–1006 [evaluating the erroneous admission of text messages und

2026(Chapman v. California (1967) 386 U.S. 18, 24 .) But the admission of evidence only results in a due process violation when “ ‘there are no permissible inferences the jury may draw from the evidence,’ ” such that its admission rendered the trial fundamentally unfair.

2025Section 1170 “The Sixth Amendment to the United States Constitution, applicable to the states through the Fourteenth Amendment’s due process clause, ‘provides that those “accused” of a “crime” have the right to a trial “by an impartial jury.” ’ ” (People v. Lynch, supra, 16 Cal.5th at p. 742 (Lynch); U.S. Const., 6th Amend.) Under the Sixth Amendment, “any fact that exposes a defendant to a greater potential sentence must be found by a jury, not a judge, and established beyond a reasonable doubt, not merely by a preponderance of the evidence.” (Cunningham v. California (2007) 549 U.S. 270, 281

2026A. Legal framework and standard of review California courts “may exercise jurisdiction on any basis not inconsistent with the Constitution of this state or of the United States.” (Code Civ. Proc., § 410.10.)4 “A state court’s assertion of personal jurisdiction over a nonresident defendant who has not been served with process within the state comports with the requirements of the due process clause of the federal Constitution if the defendant has such minimum contacts with the state that the assertion of jurisdiction does not violate ‘ “traditional notions of fair play and substantial justice.”

2023INTRODUCTION The due process clause of the United States Constitution “does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties, or relations.” (International Shoe Co. v. Washington (1945) 326 U.S. 310, 319 (International Shoe).) As such, “[t]he existence of personal jurisdiction . . . depends upon the presence of reasonable notice to the defendant that an action has been brought . . . and a sufficient connection between the defendant and the forum State to make it fair to require defense o

2024(See People v. Lopez, supra, 42 Cal.4th at p. 966 .) IV Shifted-Burden-of-Proof Claim The due process clause of the Fourteenth Amendment “protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged.” (In re Winship (1970) 397 U.S. 358, 364 .) Addiego contends the prosecutor improperly shifted the burden of proof onto the defense by (1) asking him if he would have agreed to show text messages on his phone to the deputy if the deputy had asked, (2) eliciting testimony from the digital forensics detec

2023The Supreme Court held that under this statutory scheme, placing the burden of proving heat of passion on the defendant violated “the due process requirement, as defined in [Winship, supra, 397 U.S. at p. 364 ], that the prosecution prove 17 PEOPLE v. SCHULLER Opinion of the Court by Groban, J. beyond a reasonable doubt every fact necessary to constitute the crime charged.” (Mullaney, supra, 421 U.S. at p. 685 .) In its analysis, the court acknowledged that “as a formal matter[,] the absence of the heat of passion on sudden provocation is not a ‘fact necessary to constitute the crime’ of [murd

2026“Under the ‘cumulative error’ doctrine, errors that are individually harmless may nevertheless have a cumulative effect that is prejudicial.” (In re Avena (1996) 12 Cal.4th 694, 772, fn. 32.) A claim of cumulative error is essentially a due process claim.

2026“Under the ‘cumulative error’ doctrine, errors that are individually harmless may nevertheless have a cumulative effect that is prejudicial.” (In re Avena (1996) 12 Cal.4th 694, 772, fn. 32 .) A claim of cumulative error is essentially a due process claim.

1991Reciprocity Challenge. (7) The foregoing due process clause has little to say about the amount of discovery which must be afforded the parties in a criminal prosecution. ( Wardius v. Oregon, supra, 412 U.S. 470, 474 [ 37 L.Ed.2d 82, 87 ] [ Wardius ]; but cf. Brady v. Maryland (1963) 373 U.S. 83 [ 10 L.Ed.2d 215 , 83 S.Ct. 1194 ] [ Brady; prosecutor has obligation to disclose exculpatory evidence].) The due process clause, however, "does *373 speak to the balance of forces between the accused and his accuser." ( Wardius, supra, at p. 474 [ 37 L.Ed.2d at p. 87 ], italics added.) That is, when th

1991Reciprocity Challenge. (7) The foregoing due process clause has little to say about the amount of discovery which must be afforded the parties in a criminal prosecution. ( Wardius v. Oregon, supra, 412 U.S. 470, 474 [ 37 L.Ed.2d 82, 87 ] [ Wardius ]; but cf. Brady v. Maryland (1963) 373 U.S. 83 [ 10 L.Ed.2d 215 , 83 S.Ct. 1194 ] [ Brady; prosecutor has obligation to disclose exculpatory evidence].) The due process clause, however, "does *373 speak to the balance of forces between the accused and his accuser." ( Wardius, supra, at p. 474 [ 37 L.Ed.2d at p. 87 ], italics added.) That is, when th

2026A. Legal framework and standard of review California courts “may exercise jurisdiction on any basis not inconsistent with the Constitution of this state or of the United States.” (Code Civ. Proc., § 410.10.)4 “A state court’s assertion of personal jurisdiction over a nonresident defendant who has not been served with process within the state comports with the requirements of the due process clause of the federal Constitution if the defendant has such minimum contacts with the state that the assertion of jurisdiction does not violate ‘ “traditional notions of fair play and substantial justice.”

2025Proc., § 410.10.) Constitutional limits on jurisdiction are “found in the due process clause.” (Doe v. Damron (2021) 70 Cal.App.5th 684 , 689 (Damron).) “A state court’s assertion of personal jurisdiction over a nonresident defendant who has not been served with process within the state comports with the requirements of the due process clause . . . if the defendant has such minimum contacts with the state that the assertion of jurisdiction does not violate ‘ “traditional notions of fair play and substantial justice.” ’ ” (Vons Companies, Inc. v. Seabest Foods, Inc. (1996) 14 Cal.4th 434, 444 (

2026A Legal Standards “The prosecution’s duty to disclose and retain evidence stems from the due process clause of the United States Constitution, as explained and interpreted by the three leading United States Supreme Court decisions on this subject— Brady, supra, 373 U.S. 83 ; Trombetta, supra, 467 U.S. 479 , and Arizona v. Youngblood (1988) 488 U.S. 51 (Youngblood ). [¶] Brady is the leading case on the prosecution’s duty to disclose exculpatory evidence. ‘[T]he suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material to

2026A Legal Standards “The prosecution’s duty to disclose and retain evidence stems from the due process clause of the United States Constitution, as explained and interpreted by the three leading United States Supreme Court decisions on this subject— Brady, supra, 373 U.S. 83 ; Trombetta, supra, 467 U.S. 479 , and Arizona v. Youngblood (1988) 488 U.S. 51 (Youngblood ). [¶] Brady is the leading case on the prosecution’s duty to disclose exculpatory evidence. ‘[T]he suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material to

2026(See Freeman, supra, 47 Cal.4th at p. 996 [noting that, “while a showing of actual bias is not required for judicial disqualification under the due process clause, neither is the mere appearance of bias sufficient,” and “[i]nstead, based on an objective assessment of the circumstances in the particular case, there must exist ‘“the probability of actual bias on the part of the judge or decisionmaker [that] is too high to be constitutionally tolerable”’”].) DISPOSITION The postjudgment order is affirmed.

2025(Cf. People v. Freeman (2010) 47 Cal.4th 993, 996 [“[O]nly the most ‘extreme facts’ would justify judicial disqualification based on the due process clause.”].) 3 DISPOSITION The appeal is dismissed.

2026The People responded that the release of the knife to the victim’s next of kin was not in bad faith and pursuant to Arizona v. Youngblood, supra, 488 U.S. 51 , it did not create a due process violation.

2026The People responded that the release of the knife to the victim’s next of kin was not in bad faith and pursuant to Arizona v. Youngblood, supra, 488 U.S. 51 , it did not create a due process violation.

2025DISCUSSION “Both the due process clause of the Fourteenth Amendment to the United States Constitution and state law prohibit the state from trying or convicting a criminal defendant while he or she is mentally incompetent.” (People v. Rogers (2006) 39 Cal.4th 826 , 846–847 (Rogers).) “If, during the pendency of an action and prior to judgment, . . . a doubt arises in the mind of the judge as to the mental competence of the defendant, the judge shall state that doubt in the record and inquire of the attorney for the defendant whether, in the opinion of the attorney, the defendant is mentally co

2025A. Competency to stand trial procedure “Both the due process clause of the Fourteenth Amendment to the United States Constitution and state law prohibit the state from trying or convicting a criminal defendant while he or she is mentally incompetent.” (People v. Rogers (2006) 39 Cal.4th 826, 846 .) This mandate is codified in section 1367, which provides that a person cannot be tried while “mentally incompetent,” which is defined to mean that “as a result of mental disorder or developmental disability, the defendant is unable to understand the nature of the criminal proceedings or to assist co

2026Standard of Review Where no due process violation has occurred—defendant does not claim his trial was fundamentally unfair or that a due process violation occurred here—we assess prejudice resulting from the improper admission of evidence following an exercise of discretion under the standard in People v. Watson (1956) 46 Cal.2d 818 .

2026(Watson, supra, 46 Cal.2d at p. 836 .) 29 No Cumulative Prejudicial Error Finally, Machleit contends that, regardless of whether the asserted errors were individually prejudicial, the “combined effect of multiple trial errors” rendered the trial fundamentally unfair creating a due process violation or alternatively establishes prejudice.

2026In Falsetta, our Supreme Court considered a due process challenge to another exception to the rule against propensity evidence: section 1108, which allows such evidence in sex offense cases if the evidence is admissible under section 352. (§ 1108, subd. (a); see Falsetta, supra, 21 Cal.4th at pp. 921-922.) Falsetta 9 held that “the trial court’s discretion to exclude propensity evidence under section 352 saves section 1108 from defendant’s due process challenge.” (Id. at p. 917.) Section 352 provides “ ‘a safeguard against the use of uncharged . . . offenses in cases where the admission of suc

2026In Falsetta, our Supreme Court considered a due process challenge to another exception to the rule against propensity evidence: section 1108, which allows such evidence in sex offense cases if the evidence is admissible under section 352. (§ 1108, subd. (a); see Falsetta, supra, 21 Cal.4th at pp. 921-922.) Falsetta 9 held that “the trial court’s discretion to exclude propensity evidence under section 352 saves section 1108 from defendant’s due process challenge.” (Id. at p. 917.) Section 352 provides “ ‘a safeguard against the use of uncharged . . . offenses in cases where the admission of suc

2025Specifically, Vaoifi argues that the evidence presented did not demonstrate beyond a reasonable doubt that: (1) she had the specific intent to convey a threat to kill John; and (2) her statements reflected an immediate prospect of execution. 6 A. Applicable Law and Standard of Review “In reviewing the sufficiency of evidence under the due process clause of the Fourteenth Amendment to the United States Constitution, the question … is ‘whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crim

2025Applicable Law and Standard of Review “In reviewing the sufficiency of evidence under the due process clause of the Fourteenth Amendment to the United States Constitution, the question . . . is ‘whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.’ ” (People v. Rowland (1992) 4 Cal.4th 238, 269 , quoting Jackson v. Virginia (1979) 443 U.S. 307, 319 .) The California Constitution requires the same standard.

2026Due Process of Law The federal and state Constitutions prohibit the state from depriving “any person of life, liberty, or property without due process of law.” (U.S. Const., 14th Amend., § 1; Cal. Const., art. 1, § 7.) “An individual bringing a due process claim must demonstrate: (1) a protected liberty or property interest and; (2) a lack of adequate procedural protections.” (Lewis, supra, 111 Cal.App.5th at p. 1093.) “‘“[D]ue process is the opportunity to be heard at a meaningful time and in a meaningful manner.”’” (Lewis, supra, 111 Cal.App.5th at p. 1093.) However, “procedural due process

2023Instead, ‘ “[d]ue process is flexible and calls for such procedural protections as the particular situation demands.” ’ ” (People v. Tilbury (1991) 54 Cal.3d 56, 68 .) “[W]e evaluate and balance these three elements in order to determine whether the Fourteenth Amendment’s due process clause requires Anders’s ‘prophylactic’ procedures for fundamental fairness: (1) the private interests at stake; (2) the state’s interests involved; and (3) the risk that the absence of the procedures in question will lead to an erroneous resolution of 12 PEOPLE v. DELGADILLO Opinion of the Court by Groban, J. the

2026(People v. Navarette (2003) 30 Cal.4th 458, 497 .) “[T]he admission of evidence, even if erroneous under state law, results in a due process violation only if it makes the trial fundamentally unfair.” (People v. Partida (2005) 37 Cal.4th 428, 439 ; Estelle v. McGuire (1991) 502 U.S. 62, 70 .) “‘Only if there are no permissible inferences the jury may draw from the evidence can its admission violate due process.

2026(See People v. Patino (1994) 26 Cal.App.4th 1737, 1747 ; see also Estelle v. McGuire (1991) 502 U.S. 62, 69-70 [the admission of relevant evidence of battered child syndrome does not violate the due process clause of the Fourteenth Amendment].) 21 III Admission of Defendant’s Sex Life and Preferences During cross-examination, the prosecutor asked defendant about pornography, masturbation, and his preferred physical characteristics in sexual partners.

2026As noted, in Ramirez, supra, 25 Cal.3d at page 269 , we held that courts examining a due process claim under the California Constitution must consider, in addition to the Mathews factors, “the dignitary interest in informing individuals of the nature, grounds and consequences of the [proposed government] action and in enabling them to present their side of the story before a responsible governmental official.” Although this dignitary interest is not explicitly identified in Barker, it is necessarily subsumed within its test.

2026As noted, in Ramirez, supra, 25 Cal.3d at page 269 , we held that courts examining a due process claim under the California Constitution must consider, in addition to the Mathews factors, “the dignitary interest in informing individuals of the nature, grounds and consequences of the [proposed government] action and in enabling them to present their side of the story before a responsible governmental official.” Although this dignitary interest is not explicitly identified in Barker, it is necessarily subsumed within its test.

2026(Id. at 658.) The court also noted that the defendant “had the opportunity to cross-examine [the eyewitness] and the investigating officers regarding her identifications and the procedures used during the photographic lineups,” and had “elicited numerous inconsistencies in other aspects of [her] recollection.” (Id. at 660.) Additionally, the defendant was permitted to introduce expert testimony to combat the potential for jurors to “infer that certainty is generally correlative of accuracy.” (Id. at pp. 657-658.) Although it rejected the defendant’s due process claim, the Lemke court acknowled

2026On appeal, the defendant argued that this instruction violated his due process rights to a fair trial, citing empirical research showing that a witness’s “confidence in an identification is generally not a reliable indicator of accuracy.” (Id. at p. 655.) By including certainty among the factors to consider, the defendant argued that the instruction implicitly caused jurors to “‘place more value than merited on the eyewitness’s confidence.’” (Ibid.) The Supreme Court rejected the due process claim, concluding that “considered in the context of the trial record as a whole, listing the witness’s

2026“In reviewing a challenge to the sufficiency of the evidence under the due process clause of the Fourteenth Amendment to the United States Constitution and/or the due process clause of article I, section 15 of the California Constitution, we review the entire record in the light most favorable to the judgment to determine whether it discloses substantial evidence—that is, evidence that is reasonable, credible, and of solid value— from which a reasonable trier of fact could have found the defendant guilty beyond a reasonable doubt.” (People v. Cole (2004) 33 Cal.4th 1158, 1212 .) We determine i

2025A. General Legal Principles “In reviewing a challenge to the sufficiency of the evidence under the due process clause of the Fourteenth Amendment to the United States Constitution and/or the due process clause of article I, section 15 of the California Constitution, we review the entire record in the light most favorable to the judgment to determine whether it discloses substantial evidence – that is, evidence that is reasonable, credible, and of solid value – from which a reasonable trier of fact could have found the defendant guilty beyond a reasonable doubt.” (People v. Cole (2004) 33 Cal.4

2023Sufficiency of Evidence “ ‘In reviewing the sufficiency of evidence under the due process clause of the Fourteenth Amendment to the United States Constitution, the question we ask is “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” ’ [Citations.] We apply an identical standard under the California Constitution. [Citation.] ‘In determining whether a reasonable trier of fact could have found defendant guilty beyond a reasonable doubt, the appellate court

2023Applicable Law and Standard of Review “In reviewing the sufficiency of evidence under the due process clause of the Fourteenth Amendment to the United States Constitution, the question we ask is ‘whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.’ ” (People v. Rowland (1992) 4 Cal.4th 238, 269 , quoting Jackson v. Virginia (1979) 443 U.S. 307, 319 ; People v. Young (2005) 34 Cal.4th 1149, 1175 .) “We apply an identical standard under the California Constit

2026Waiver of Right to Be Present “A criminal defendant, broadly stated, has a right to be personally present at trial under various provisions of law, including the confrontation clause of the Sixth Amendment to the United States Constitution, as applied to the states through the due process clause of the Fourteenth Amendment; the due process clause of the Fourteenth Amendment itself; section 15 of article I of the California Constitution; and sections 977 and 1043.” (People v. Waidla (2000) 22 Cal.4th 690, 741 .) However, “a defendant may waive his right to be present at his trial by being disru

2023(People v. Waidla (2000) 22 Cal.4th 690, 725 [ruling on admissibility of evidence reviewed for abuse of discretion].) Because Gudino fails to explain how admitting Cathey’s statement rises to the level of a constitutional error, we examine prejudice under the standard in People v. Watson (1956) 46 Cal.2d 818 — whether “it is reasonably probable that a result more favorable to [defendant] would have been reached in the absence of the error.” (Id. at p. 836; People v. Partida (2005) 37 Cal.4th 428, 439 [erroneous admission of evidence results in a due process violation only if it renders the tri