Articles Posted in Civil Rights

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The Supreme Court reversed the judgment of the court of appeals ruling that Defendant did not have a right to appointed counsel to respond to the prosecution's appeal of the order of the trial court granting Defendant's motion to suppress the prosecution's evidence against her, holding that Defendant had a right to appointed counsel in the present appeal. Defendant was charged by misdemeanor complaint with driving under the influence of alcohol and driving while having a blood-alcohol content of 0.08 percent or higher. With the assistance of court-appointed counsel, Defendant filed a successful motion to suppress evidence collected during a warrantless traffic stop. The prosecution's appealed the suppression order. Defendant asked the appellate division to appoint new counsel to represent her, but the appellate division refused. Defendant then filed a petition for a writ of mandate, which the court of appeal denied. Without addressing whether the public defender remained appointed to represent Defendant, the court concluded that Defendant did not have the right to appointment of counsel on appeal. The Supreme Court reversed and remanded the case, holding that Defendant was entitled to the assistance of counsel to respond to the prosecution's appeal. View "Gardner v. Appellate Division of Superior Court" on Justia Law

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The Supreme Court modified the judgment of the trial court convicting Defendant of two counts of first degree murder and related crimes, sentencing Defendant to death, and imposing a four-year determinate term based on the age of the victims by striking the four-year determinate term but otherwise affirmed, holding that there was error in the elderly victim enhancements but no other prejudicial error. Specifically, the Court held (1) the evidence was sufficient to support Defendant's convictions; (2) there was no reversible error in the guilt-phase instructions given to the jury; (3) any statutory error in allowing an investigator to read aloud from his report of an interview with a driver of Defendant was harmless at the guilt phase, and the admission of the driver's statement during the guilt phase did not prejudice the jury's penalty determination; (4) no other error occurred during the penalty phase of trial; (5) murder is not one of the crimes eligible for an elderly victim enhancement; (6) any error on the part of the trial court in initially imposing a $10,000 restitution fine was harmless; and (7) none of Defendant's challenges to California's death penalty scheme had merit. View "People v. Potts" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting codefendants Oswaldo Amezcua and Joseph Conrad Flores of four counts of first degree murder and sentencing each defendant to death for the murder convictions, holding that any errors in the proceedings below were not sufficiently prejudicial to require reversal of the judgment. A jury convicted Defendants of murder, finding true multiple-murder and drive-by-murder special circumstance allegations, as well as multiple counts of attempted willful, deliberate premeditated murder, false imprisonment, and other non-capital offenses. The trial court sentenced Defendants to death for the murder convictions and imposed determinate and indeterminate sentences for the noncapital convictions. The Supreme Court affirmed, holding (1) any error in the prosecutor’s guilt phase closing was harmless; (2) any error in a medical examiner’s testimony relating to autospy results derived from a different pathologist’s report was harmless; and (3) whether considered individually or cumulatively, the errors did not warrant reversal. View "People v. Amezcua" on Justia Law

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The Supreme Court affirmed Defendant’s convictions of kidnapping, robbing, raping, torturing, and murder but reversed his death sentence, holding that multiple prospective jurors were improperly excused for cause. Defendant in this case was a black man sentenced to death for murdering a white woman. The prosecutor struck four black male jurors, leaving no black man on the jury. The Supreme Court held (1) under the standards of Witherspoon v. Illinois, 391 U.S. 510 (1968) and Wainwright v. Witt, 469 U.S. 412 (1985), the trial court erred by excusing jury candidates on the ground that they could not fairly and impartially consider whether death was the appropriate punishment; but (2) the trial court properly rejected Defendant’s Armstrong’s Batson claims. View "People v. Armstrong" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of first degree murder and sentence of death on the murder count, holding that no reversible error occurred in the proceedings below. Specifically, the Court held (1) the trial court did not err in denying Defendant’s motion to suppress; (2) the trial court did not err in denying Defendant’s challenges for cause concerning a prospective juror or Defendant’s motion for additional peremptory challenges; (3) the trial court did not abuse its discretion in deciding not to sequester the jury; (4) Defendant’s child pornography charge was validly joined with his kidnapping and murder charges; (5) assuming the trial court erred in allowing certain testimony, the error was harmless; (6) any other error in the trial court’s evidentiary rulings was harmless; (7) the trial court did not commit prejudicial error in its instructions to the jury; and (8) Defendant’s challenges to the constitutionality of California’s death penalty law were unavailing. View "People v. Westerfield" on Justia Law

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The Supreme Court affirmed the trial court’s judgment convicting Defendant of the first degree murders of her three children, vacated two of the jury’s three multiple-murder special-circumstance findings, reversed Defendant’s sentence of death, and remanded the matter for a new penalty determination. The Supreme Court held (1) the trial court did not commit reversible error in denying Defendant’s request for self-representation under Faretta v. California, 422 U.S. 806 (1975), and no other prejudicial error occurred during the guilt phase proceedings; (2) two of the three multiple-murder special-circumstance allegations were erroneously charged and found true in this case; and (3) the trial court erred in excusing a prospective juror for cause based solely on her written questionnaire responses concerning her personal views on the death penalty, requiring reversal of Defendant’s penalty judgment. View "People v. Buenrostro" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree murder and sentencing him to death, holding that Defendant suffered no prejudice in the proceedings below. Specifically, the Court held (1) Defendant’s guilty plea was valid because Cal. Penal Code 1018 allows advisory counsel to satisfy the statutory requirements imposed on counsel in the case of a defendant who has exercised the right to self-representation; (2) the restraints placed on Defendant during the penalty trial and the denial of any writing instrument did not violate Defendant’s right to participate in his own defense or any other constitutional rights; and (3) Defendant’s challenges to California’s death penalty scheme and standard jury instructions were unavailing. View "People v. Miracle" on Justia Law

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The Supreme Court reversed the judgment of the Court of Appeal and remanded with directions to reverse Defendant’s judgment of conviction, holding that the trial court erred in failing to suspend the criminal trial and initiate competency proceedings when defense counsel declared a doubt about her client’s competence. Here, Defendant, a formerly incompetent defendant, was restored to competence primarily through administration of medication. At the start of Defendant’s jury trial, Defendant began exhibiting signs of incompetence, and the trial court learned that Defendant had stopped taking his medication. After counsel declared a doubt as to Defendant’s competence the trial court conducted a brief colloquy with Defendant. The court then ruled that the trial could proceed. Defendant was ultimately convicted on several counts and sentenced to multiple life terms. The Supreme Court reversed, holding that the trial court’s failure to suspend proceedings and conduct a formal investigation into Defendant’s incompetence violated Defendant’s constitutional guarantee of due process. View "People v. Rodas" on Justia Law

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The Supreme Court affirmed in its entirety the judgment of the trial court imposing a sentence of death after a jury convicted Defendant of first degree murder, holding that no reversible error occurred in the proceedings below. Defendant was convicted of first degree murder, robbery, and grand theft. The jury found that the murder occurred during a robbery and that Defendant personally used a firearm. The jury then returned a verdict of death. The trial court imposed that sentence, as well as an aggregate determinate sentence of eight years four months. The Supreme Court affirmed, holding that no prejudicial error occurred during the pretrial proceedings, the guilt phase proceedings, or the penalty phase proceedings. Further, the Court held that Defendant’s death judgment did not constitute cruel and unusual punishment in light of his youth and intellectual shortcomings, that Defendant’s challenges to the constitutionality of California’s death penalty statute failed, and that Defendant’s claim of cumulative prejudice must be rejected. View "People v. Powell" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death following a second penalty proceeding, holding that there was no error requiring reversal. Specifically, the Court held (1) the Ireland merger doctrine did not bar Defendant’s convictions for torture murder and mayhem murder; (2) the evidence was sufficient to support Defendant’s convictions for torture murder and rape murder; (3) the trial court’s admission of gang affiliation evidence during the guilt phase of trial was harmless; (4) the evidence supported the special circumstance findings of torture murder and mayhem murder; (5) the jury’s finding that Defendant was sane at the time of the killing did not require reversal; (6) the trial court did not err in admitting evidence of Defendant’s possible gang affiliation and racist beliefs during the penalty phase; (7) imposition of the death penalty on a mentally ill defendant does not violate the Eighth Amendment; and (8) Defendant’s constitutional challenges to California’s imposition of the death penalty failed. View "People v. Powell" on Justia Law