People v. Dalton

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The Supreme Court vacated as unauthorized the death sentence imposed upon Defendant in connection with his conviction for conspiracy to commit murder and vacated the jury's lying in wait special-circumstance true finding and affirmed, as modified, the judgment in all other respects, holding that no substantial evidence supported the lying in wait special-circumstance finding and that the trial court erred in imposing the death penalty for Defendant's conviction of conspiracy to commit murder. Defendant was convicted of conspiracy to commit murder and first degree murder. The jury found true lying in wait and torture-murder special-circumstance allegations. The jury returned a death verdict. In addition to the errors found on appeal, the Supreme Court assumed error in (1) the trial court's preclusion of impeachment of witnesses with their felony convictions or pending charges; (2) the admission of certain evidence; (3) certain aspects of the prosecutor's guilt phase closing argument; and (4) the trial court's failure to instruct on its own motion that a coperetrator's guilty plea could only be used to assess her credibility. The Court held that the errors and assumed errors, whether considered individually or cumulatively, did not require reversal of Defendant's murder or conspiracy convictions but that the death sentence and lying in wait special-circumstance true finding were improperly imposed. View "People v. Dalton" on Justia Law