California v. Smith

Defendants Kiesha Smith and Michael Mitchell appealed their convictions for the murder of Josephine Kelley. In a prior opinion, the Court of Appeal reversed both convictions due to prejudicial error in the joint trial before separate juries. The State petitioned the Supreme Court for review with respect to reversal of Mitchell's conviction on the grounds the trial court erred in admitting against Mitchell, as statements against interest, hearsay evidence of statements made by codefendant Smith in which she inculpated Mitchell in the murder. The Supreme Court granted review on this issue and remanded this case back to the Court of Appeal reconsideration in light of California v. Grimes (2016) 1 Cal.5th 698 (Grimes). After reconsideration, a majority of the Court of Appeal found no error in the admission of evidence of statements Smith made which inculpated Mitchell. The Court also rejected the other issues Mitchell raised on appeal. Accordingly, Smith's conviction was once again reversed, but Mitchell's affirmed. View "California v. Smith" on Justia Law