Justia California Supreme Court Opinion Summaries

During the course of one evening, Defendant and another man burglarized two businesses, robbing several people inside, and killing off-duty peace officer Shayne York. After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a peace officer in retaliation for the performance of his duties and of murder during the commission of robbery and burglary. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed Defendant’s convictions, holding (1) the trial court did not err in its evidentiary rulings or in instructing the jury during the guilt phase; (2) sufficient evidence supported the finding that Defendant intentionally killed York in retaliation for the lawful performance of his duties, and the special circumstance allegation was constitutional; (3) Defendant’s challenges to the robbery-murder and burglary-murder special circumstances were unavailing; (4) Defendant’s Sixth Amendment right to self-representation was not violated at the penalty phase; (5) any error in the instructions during the penalty phase was harmless; and (6) Defendant’s death sentence was proportional and constitutional. View "People v. Boyce" on Justia Law

The assumption under the Three Strikes law is that a defendant has had two prior opportunities to reform before being found incorrigible and receiving a life sentence. At issue in this case was whether an offender’s two previous qualifying felony convictions that are closely connected in their commission can nevertheless constitute two separate strikes under the Three Strikes law. Here, Defendant’s two prior felony convictions were tried in the same proceeding, committed during the same course of criminal conduct, based on the same act, and committed as the same time and against the same victim. The trial court concluded that Defendant fell “squarely within the spirit of [Three] Strikes” and denied Defendant’s motion to dismiss one of the prior convictions. The Supreme Court vacated the judgment, holding that the trial court was required to dismiss one of the prior convictions because failure to do so would be inconsistent with the spirit of the Three Strikes law. Remanded. View "People v. Vargas" on Justia Law

Defendants Reynaldo Junior Eid and Alaor Docarmo Oliveira were charged in an amended information with two counts of kidnapping for ransom, which is punishable by life in prison. A jury found Defendants guilty of the lesser included crimes of attempted extortion and misdemeanor false imprisonment. The trial court sentenced Defendants to four years and six months in custody. Defendants argued on appeal that they could not be convicted of two lesser included offenses of a single greater offense. The court of appeals agreed with Defendants and struck Defendants’ convictions for misdemeanor false imprisonment, thus reducing each Defendant’s sentence to two years and six months. The Supreme Court reversed, holding that the jury may convict on more than one uncharged lesser included offense of a single charged greater offense. View "People v. Eid" on Justia Law

One of the jurors in Defendant’s criminal case prematurely decided to vote guilty, repeatedly talked about the case outside deliberations, prematurely reached a conclusion regarding the veracity of certain testimony, and adopted the mantle of an advocate, repeatedly telling the other jurors that Defendant was guilty. The trial court found that the juror engaged in serious misconduct but that Defendant did not suffer prejudice. Defendant appealed his conviction of two counts of first degree murder and death sentence on the basis of juror misconduct. The Supreme Court reversed, holding that, under the facts of this case, the People did not discharge their burden of establishing that there was no substantial likelihood that the juror was actually biased against Defendant. View "People v. Weatherton" on Justia Law

After a jury trial, Defendant was convicted of murder, rape, and kidnapping and sentenced to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in finding that Defendant was competent to stand trial; (2) the prosecutor did not improperly exercise a peremptory challenge to a prospective juror based on race; (3) during the guilt phase of trial, the trial court did not abuse its discretion in admitting crime scene and autopsy photographs and in instructing the jury; (4) no prejudicial error occurred during the penalty phase of trial; (5) the trial court did not err in denying Defendant’s motion for a new trial; and (6) Defendant’s challenges to California’s death penalty statute failed. View "People v. Sattiewhite" on Justia Law

After a jury trial, Defendant was convicted of kidnapping, committing two counts of lewd and lascivious acts on, and murdering a five-year-old girl. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding that the trial court (1) did not err in refusing to change venue from Orange County, as the record presented no reason to find a reasonable likelihood that Defendant did not receive a fair trial before impartial jurors; (2) did not err in denying Defendant’s request for additional peremptory challenges after he exhausted his statutory allotment of challenges because Defendant did not demonstrate that additional peremptory challenges were necessary to secure his right to a fair trial; (3) did not abuse its discretion in admitting evidence that Defendant had sexually molested three girls where Defendant had been charged with and acquitted of crimes concerning two of the girls; and (4) did not abuse its discretion in admitting photographs of the crime scene, evidence regarding the child pornography found on the computer to which Defendant had access, and victim impact evidence. View "People v. Avila" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder with a multiple-murder special circumstance, one count of attempted murder, and firearm enhancements for the shootings and attempted shootings of staff members at a hospital. After two penalty trials that resulted in hung juries, the third penalty jury returned a verdict of death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court’s denial of Defendant’s motion to recuse the district attorney’s office was not an abuse of discretion; (2) the trial court erred in its instructions to the jury, but the error was harmless; (3) retrial did not violate Defendant’s rights to due process and equal protection and the prohibition against cruel and unusual punishment; (4) Defendant was not deprived of the right to equal protection and trial by a representative jury because the jury included no Vietnamese-Americans; (5) although the prosecutor engaged in misconduct during the penalty phase, the improper questions did not influence the verdict; and (6) Defendant’s allegations of error in post-trial issues were without merit. View "People v. Trinh" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted premeditated murder, two counts of second degree robbery and arson causing great bodily injury. The jury returned a verdict of death. The Supreme Court vacated Defendant’s arson-murder special-circumstance finding but otherwise affirmed the judgment in its entirety, holding (1) the trial court did not err in restricting Defendant’s counsel’s questioning of prospective jurors during voir dire; (2) the evidence was insufficient to support the arson-murder special circumstance because the arson did not involve an inhabited structure or property; (3) the trial court did not abuse its discretion in dismissing a juror during the trial; (4) the trial court did not prejudicially err in its instructions to the jury; (5) the trial court did not err in refusing to declare a mistrial after the penalty jury initially declared it was deadlocked; and (6) Defendant’s challenges to the constitutionality of California’s death penalty scheme were without merit. View "People v. Debose" on Justia Law

Defendant was found guilty of failing to stop at a red traffic light at an intersection. Defendant's conviction was based on evidence generated by an automated traffic enforcement system (ATES), otherwise known as a red light traffic camera. Defendant’s conviction was upheld on appeal. At issue before the Supreme Court was whether the trial court properly admitted the ATES evidence over Defendant’s objections of inadequate foundation and hearsay. The Supreme Court affirmed, holding (1) sufficient evidence was submitted for the court to sustain a finding that the ATES evidence was adequately authenticated; and (2) ATES evidence does not constitute hearsay. View "People v. Goldsmith" on Justia Law

If a defendant commits a killing out of an unreasonable belief in the need for self-defense, he or she may be convicted of voluntary manslaughter but not murder. After a jury trial in this case, Defendant was convicted of first degree murder. On appeal, the court of appeal rejected Defendant’s argument that the trial court erred in failing to instruct the jury on unreasonable self-defense, concluding that the doctrine does not apply when belief in the need for self-defense arises solely from the defendant’s delusional mental state. The Supreme Court affirmed, holding (1) at a trial on the question of guilt, the defendant may not claim unreasonable self-defense based on insane delusion, and a purely delusion belief in the need to act in self-defense may be raised as a defense, but that defense is insanity; and (2) because Defendant’s claim of unreasonable self-defense was based entirely on a delusional mental state that amounted to legal insanity, the trial court properly denied Defendant’s request for an instruction on unreasonable self-defense. View "People v. Elmore" on Justia Law