Justia California Supreme Court Opinion Summaries

In this case, the defendant was charged with multiple violent crimes arising from two separate incidents in Los Angeles County in 1991. The first incident involved the fatal shooting of Benson Jones, the attempted murder of Benjamin Jones, and an assault with a firearm on Linda Jones. The second incident involved the murder of Jesus Sanchez and the attempted murder of Ernest Johnson. The prosecution’s theory focused on gang affiliations as the motive for the shootings, supported by eyewitness identifications, gang expert testimony, and forensic evidence. Bankston was also charged with being a felon in possession of a firearm.At the initial trial in the Los Angeles County Superior Court, the jury convicted Bankston of murdering Benson Jones, the attempted murder of Benjamin Jones, and firearm possession, but could not reach verdicts on the charges related to Sanchez, Johnson, and Linda Jones, resulting in a mistrial for those counts. During the retrial, Bankston was acquitted of Johnson’s attempted murder but convicted of Sanchez’s murder and assaulting Linda Jones with a firearm. The jury found true the multiple-murder special-circumstance allegation, and after the penalty phase, returned a death verdict.On automatic appeal to the Supreme Court of California, the court reviewed numerous claims, including trial management, evidentiary rulings, jury selection, and self-representation. The court held that the guilt and special circumstance phases were free from prejudicial error, affirming the convictions and upholding most trial procedures. However, both parties agreed that the penalty phase closing argument by the prosecutor involved racially discriminatory language in violation of the California Racial Justice Act of 2020, Penal Code section 745. The Supreme Court held that this error was not harmless beyond a reasonable doubt under the Act and reversed the death sentence, remanding for further proceedings on penalty. The court affirmed the judgment in all other respects. View "P. v. Bankston" on Justia Law

The defendant was convicted by a jury of the first degree murders of his two young children, with special findings that the murders involved torture and multiple victims. The evidence at trial showed a prolonged pattern of severe physical abuse and neglect inflicted by the defendant on the children, including daily beatings, deliberate starvation, and ultimately fatal injuries. The abuse was corroborated by testimony from family members, expert medical evidence, and the circumstances of the children’s deaths. After a penalty phase hearing, the jury returned a death verdict, and the trial court imposed a sentence of death, staying punishment on the other counts.Prior to review by the Supreme Court of California, the case was tried in the Los Angeles County Superior Court. The jury found the defendant guilty of several crimes including first degree murder, child abuse homicide, child endangerment, and corporal injury to a child, and found true multiple special circumstance allegations. The defendant’s appeals centered on the sufficiency of the evidence for first degree murder and special circumstance findings, the admission of certain expert testimony, the adequacy of jury instructions, alleged prosecutorial misconduct, and claims under the California Racial Justice Act.The Supreme Court of California reviewed each of the defendant’s claims in detail. It held that the evidence was sufficient to support the first degree murder convictions and special circumstance findings under both theories of torture-murder and premeditated, deliberate murder. The court found any error in the admission of certain expert testimony or in the instructions to be harmless beyond a reasonable doubt. The court also assumed, without deciding, that certain prosecutorial comments may have violated the Racial Justice Act, but concluded that any such errors were harmless. The Supreme Court affirmed the judgment in its entirety, upholding the convictions and the death sentence. View "P. v. Barrera" on Justia Law

An 11-year-old girl disappeared while visiting her parents in Oakland in July 1999 and was found dead the next day. Investigators discovered she had been raped and strangled. Within weeks, the defendant, a nearby resident, confessed to the crime after matching DNA evidence was found. In his confession, the defendant described luring the victim into his apartment, assaulting and killing her, and disposing of her body. The prosecution further corroborated the confession with testimony from a neighbor and other witnesses, and confirmed the DNA link. The defense did not present evidence at the guilt phase but presented mitigating evidence at the penalty phase, including character witnesses and information about the defendant’s background.The Superior Court of Alameda County conducted the trial. Before trial, the court denied the defendant’s motion to suppress evidence related to the police’s collection of his blood sample and confession, finding the encounter to be consensual and not a detention under the Fourth Amendment. The defendant was convicted of first-degree murder with special circumstances and sentenced to death. His post-trial motions, including those to discharge a juror and for a mistrial based on alleged juror bias, were denied.The Supreme Court of California reviewed the case on automatic appeal. The court held that the defendant was not unlawfully detained before consenting to the blood draw, that evidence obtained was admissible, and that no juror bias or improper admission of evidence rose to the level of reversible error. The court also addressed and rejected challenges to victim impact evidence, admission of unadjudicated criminal acts, and claims of constitutional violations in the penalty phase, including a claim under California’s Racial Justice Act regarding the prosecutor’s language. The judgment, including the death sentence, was affirmed. View "P. v. Demolle" on Justia Law

Two defendants were jointly tried before separate juries for a series of violent crimes committed in Sacramento and Pomona in 1995. These included the robbery and murders of members of the Le family, the attempted murder of Quyen Luu, a burglary, an attempted robbery, and the murder of Miguel Vargas Avina with the attempted murder of Rodolfo Huerta. Both were also implicated in an uncharged murder (Bun) and alleged to have acted for the benefit of a criminal street gang. The prosecution relied on eyewitnesses, accomplice testimony, forensic evidence, and admissions from the defendants. The defense challenged witness identifications, introduced expert testimony on eyewitness reliability, and presented extensive mitigating evidence about the defendants' traumatic backgrounds.The Los Angeles County Superior Court allowed the charges from different counties to be joined under Penal Code section 790(b), leading to a joint capital trial. Both men were convicted of all charges and special circumstance allegations, and each jury returned a verdict of death. The trial court entered death judgments for both, finding true additional special circumstances.The Supreme Court of California reviewed the case automatically. For one defendant, the court affirmed the judgment except for vacating the gang enhancement finding, due to legislative changes that barred the use of the charged offense to establish a pattern of criminal gang activity. For the other defendant, the court reversed the judgment in its entirety. It held that defense counsel's closing argument conceding guilt on the defendant’s behalf, over his express objection, violated the defendant’s constitutional right to decide the objective of his defense, as articulated in McCoy v. Louisiana (2018). This error was deemed structural, requiring automatic reversal of all convictions and enhancements for that defendant. The case was remanded for further proceedings as to both defendants as specified. View "P. v. Chhuon" on Justia Law

The defendant was observed by a police officer driving recklessly in Ukiah, California, nearly hitting pedestrians and engaging in dangerous maneuvers while under the influence of alcohol. After a high-speed pursuit, she was arrested and charged with multiple felonies, including assault and reckless evasion, as well as misdemeanors related to driving under the influence. She had a prior robbery conviction, making her subject to enhanced sentencing under the Three Strikes law. Through a negotiated plea, she pled no contest to one felony and one misdemeanor, admitted her prior strike, and agreed to a stipulated upper-term sentence of three years (doubled to six years), with the remaining charges dismissed.After her conviction, but while her appeal was pending, California amended Penal Code section 1170 to require that aggravating facts justifying an upper-term sentence be either stipulated to by the defendant or found true beyond a reasonable doubt. The defendant argued on appeal that this amendment should apply retroactively to her nonfinal judgment, requiring reduction of her sentence since the new requirements were not met. The California Court of Appeal rejected her claim, holding that the amendment did not affect stipulated sentences from plea bargains, since no judicial discretion was exercised in those cases.The Supreme Court of California reversed the Court of Appeal. The Supreme Court held that defendants with nonfinal judgments who agreed to an upper-term sentence as part of a plea bargain are entitled to seek the retroactive benefit of amended section 1170(b). However, a stipulated upper-term sentence remains valid only if the defendant knowingly and voluntarily waives the new requirements. On remand, the defendant may either waive these requirements and reaffirm the plea (reinstating the original sentence), or invoke them, in which case the parties may renegotiate the plea or the defendant may withdraw her plea and proceed to trial. The Supreme Court of California thus vacated the lower court’s judgment and set forth these remedies. View "P. v. Mitchell" on Justia Law

Two men attacked a couple as they entered their condominium, robbing them and sexually assaulting the woman. During the incident, the male victim was fatally shot. Decades later, DNA evidence linked one of the assailants, Morris, to the crime. In 2013, Morris was convicted by a jury of first degree murder, with special circumstances for rape, robbery, and murder for financial gain. The jury found that Morris acted with intent to kill, and the trial court sentenced him to life without parole. The conviction was affirmed on appeal.After changes to California’s felony-murder rule under Senate Bill 1437, Morris filed a petition for resentencing under Penal Code section 1172.6, arguing he was ineligible for murder liability as a nonkiller under the amended law. The Superior Court summarily denied the petition at the prima facie stage, reasoning that the jury’s findings established Morris’s intent to kill, making him ineligible for relief. The California Court of Appeal, in a split decision, affirmed the denial. The majority held that, under the amended law, it was sufficient that Morris acted with intent to kill and aided the underlying felony, even if he was not the actual killer. The dissenting judge argued that the law requires a nonkiller to have aided the actual killer in the lethal act itself, not just in the underlying felony.The Supreme Court of California reviewed the case to resolve a conflict among appellate courts regarding the actus reus requirement for nonkiller aiders and abettors under section 189, subdivision (e)(2). The Supreme Court held that, for a nonkiller to be liable for felony murder under this provision, the prosecution must prove that the nonkiller, with intent to kill, aided or abetted the actual killer in the commission of the lethal act itself—not merely in the commission of the underlying felony. The Court reversed the Court of Appeal and remanded for further proceedings. View "P. v. Morris" on Justia Law

The defendant used a false pretense to enter the motel room of Carole Sund, her daughter Juli Sund, and family friend Silvina Pelosso. Once inside, he brandished a gun, used duct tape to bind the three, and murdered Carole and Silvina by strangulation and suffocation. Over several hours, he sexually assaulted Juli, then kidnapped her, assaulted her again, and ultimately killed her by slitting her throat. Months later, he also kidnapped, murdered, and decapitated Joie Armstrong. The defendant confessed to these crimes in detail. Physical evidence and testimony corroborated his confession. Evidence related to the Armstrong murder, prosecuted federally, was introduced during the penalty phase.A jury in the Santa Clara County Superior Court convicted the defendant of three counts of first-degree murder and one count of kidnapping. The jury found true multiple enhancement allegations, including use of a deadly weapon and firearm, and five special circumstances: multiple murders, kidnapping murder, attempted rape murder, forcible oral copulation murder, and burglary murder. The jury found not true the alleged robbery-murder special circumstance. In a separate sanity phase, the jury found the defendant sane at the time of the offenses, and in the penalty phase, recommended the death penalty. The trial court denied motions for a new trial and sentence modification, imposing death plus a consecutive prison term.On automatic appeal, the Supreme Court of California reviewed numerous claims, including challenges to the admission of the defendant’s confession, claims of evidentiary and procedural error, allegations of juror misconduct, and arguments regarding the constitutionality of California’s death penalty scheme. The Court held that the confession was properly admitted, the evidentiary and procedural rulings were within the trial court’s discretion, and that there was no prejudicial juror misconduct or judicial bias. The Court also rejected constitutional challenges to the death penalty statute. The Supreme Court of California affirmed the judgment in its entirety. View "People v. Stayner" on Justia Law

A man was arrested after attempting to purchase food at a restaurant using several credit cards, three of which were lost cards belonging to other individuals. When the first five cards were declined, he discarded them; the sixth card worked, but after a dispute with the manager over a refund, he left without the food and was later taken into custody. He was charged with multiple counts, including felony vandalism, identity theft, and petty theft. At arraignment, the trial court denied his motion for release on his own recognizance and set bail at $75,000, citing his extensive criminal history and past failures to appear. After further hearings, the trial court ultimately denied bail altogether.The defendant filed a petition for writ of habeas corpus in the California Court of Appeal, First Appellate District, Division Three, challenging the denial of bail. While the petition was pending, he entered a plea agreement, resulting in his release. The appellate court dismissed the petition as moot, but the Supreme Court of California directed the Court of Appeal to address unresolved constitutional questions regarding bail. The Court of Appeal issued a published opinion addressing the relationship between two California constitutional provisions on bail and whether a trial court may set bail above a defendant’s ability to pay. The appellate court's reasoning conflicted with another appellate decision, In re Brown.The Supreme Court of California reviewed the case to resolve these issues. It held that Article I, section 12, subdivisions (b) and (c), defines the exclusive circumstances under which bail may be denied in noncapital cases, and Article I, section 28(f)(3), can be harmonized with, but does not expand, these exceptions. The court further held that, except where pretrial detention is authorized, bail must be set in an amount reasonably attainable given the defendant’s circumstances; courts may not set bail at an amount that is objectively unattainable based solely on indigency. The Supreme Court affirmed the judgment of the Court of Appeal. View "In re Kowalczyk" on Justia Law

A 16-year-old defendant and several adult associates, all affiliated with a street gang, confronted perceived rivals outside a taco truck in Modesto. During the confrontation, one of the group’s members fatally shot a rival gang member. The defendant was convicted by a jury of murder, assault with a deadly weapon, and participation in a criminal street gang. Jury enhancements were applied for crimes committed for the benefit of a gang and for personal firearm use causing death. The prosecution’s theory at trial shifted, with arguments that either the defendant was the shooter or he aided and abetted the shooting. The jury was instructed on both perpetrator and accomplice liability, using standard instructions that later case law found potentially ambiguous as to whether malice could be imputed to an accomplice.Following the passage of Senate Bill 1437 and related legislation, which restricted murder liability and created a resentencing process for those convicted under prior, broader legal theories, the defendant petitioned for resentencing under Penal Code section 1172.6. The Stanislaus County Superior Court acknowledged a prima facie case for relief, but, after an evidentiary hearing, denied the petition, finding the defendant could be convicted as either the actual killer or a direct aider and abettor. The defendant appealed, arguing the instructions allowed conviction on an impermissible imputed malice theory. The California Court of Appeal affirmed the denial, holding the defendant’s claim was not cognizable in a section 1172.6 petition because he could have raised it on direct appeal and had therefore forfeited it.The Supreme Court of California reversed. It held that Penal Code section 1172.6, subdivision (a)(3), does not categorically bar resentencing relief for petitioners who could have raised instructional challenges to imputed malice on direct appeal but did not. The court remanded the case to the Court of Appeal for consideration of the merits of the defendant’s claims. View "People v. Lopez" on Justia Law

Two defendants were implicated in the 1985 kidnapping, rape, and murder of a woman in California. Evidence showed that they were previously involved in a string of armed robberies and planned to escape law enforcement by stealing a vehicle from a shopping center parking lot. They kidnapped the victim, drove her hundreds of miles, sexually assaulted her, and killed her before disposing of her body in a canal. Forensic evidence, including eyewitness testimony and DNA analysis, linked both men to the crimes. Both were arrested years later after advances in DNA technology allowed for retesting of biological evidence.The Sacramento County Superior Court tried the defendants together with separate juries. Each was found guilty of murder, rape, and kidnapping, with special circumstances for kidnapping-murder, robbery-murder, and rape-murder. One defendant was also convicted of sodomy with a sodomy-murder special circumstance. Both were sentenced to death after separate penalty phase trials. The court also imposed various prison terms and restitution fines, staying the execution of the prison sentences.The Supreme Court of California reviewed the case on automatic appeal. It affirmed the convictions of both defendants and the death sentence for one. However, it reversed the death sentence for the second defendant, finding that subsequent changes in the law—specifically regarding the competency of defendants with mental illness to represent themselves—required reversal of his sentence, including the death judgment. The court also vacated any balance of restitution fines for both defendants, pursuant to recent statutory amendments. The case was remanded for further proceedings as to the sentencing of the second defendant. View "P. v. Bertsch" on Justia Law