Justia Criminal Law Opinion Summaries

Two defendants, Phalon Amad Hall and Patrick Redman, were convicted of home invasion robbery and kidnapping, with additional gang-related sentencing enhancements. Hall was identified as one of the robbers, while Redman was accused of aiding and abetting by recruiting a robber, providing a firearm, and acting as the getaway driver. The case involved a violent home invasion where the victim, A.T., was beaten, forced to open a safe, and tied up while the robbers looted his house.In the Superior Court of San Bernardino County, both defendants were found guilty of home invasion robbery and kidnapping. The jury also found multiple sentencing enhancements to be true, including gang-related enhancements. Hall received a sentence of 15 years to life for robbery, while Redman was sentenced to 60 years to life. Both defendants appealed their convictions and sentences.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court reversed the kidnapping convictions, ruling that the movement of the victim within his home was not substantial enough to constitute kidnapping. The court also reversed the gang-related sentencing enhancements due to legislative changes that retroactively altered the definition and proof requirements for establishing a criminal street gang. The court affirmed the robbery convictions and other aspects of the judgment but remanded the case for complete resentencing in light of the reversals. View "People v. Hall" on Justia Law

In 2008, a jury convicted Travis Lanell Montgomery of multiple charges, including conspiracy to commit robbery, robbery, attempted robbery, and possession of a firearm by a felon. The trial court sentenced him to 61 years to life, which was later reduced to 26 years to life on appeal. In January 2024, Montgomery filed a declaration alleging racial bias under the California Racial Justice Act (RJA) and requested discovery of evidence to support his claims. The trial court treated this as a petition for writ of habeas corpus and denied it for failing to state a prima facie case for relief. The court also denied the discovery motion, citing lack of jurisdiction.Montgomery appealed the trial court's denial of his discovery motion, arguing that it was appealable as an order affecting his substantial rights. The Court of Appeal, Fourth Appellate District, dismissed the appeal, stating that the trial court's order was not appealable. The court explained that a trial court order denying relief that it has no jurisdiction to grant does not affect a defendant’s substantial rights and is therefore not appealable under section 1237, subdivision (b).The Court of Appeal held that the RJA does not authorize a freestanding discovery motion; such a motion must be ancillary to an ongoing action or proceeding. Since Montgomery's petition for writ of habeas corpus was summarily denied, there was no pending proceeding in which the discovery motion could be considered. Consequently, the trial court correctly denied the discovery motion for lack of jurisdiction. The appeal was dismissed, but Montgomery retains the option to file a new petition for writ of habeas corpus in the Court of Appeal, where he can renew his discovery motion. View "In re Montgomery" on Justia Law

In January 2008, Ignacio Ruiz, Jr., participated in an attack on rival gang members, resulting in one death. Ruiz, who was 16 at the time, was found guilty by a jury of first-degree murder, attempted murder, and street terrorism, with several gang and firearm enhancements. In August 2010, he was sentenced to life in prison without the possibility of parole for the murder charge, among other consecutive terms. Ruiz was resentenced in 2016, but his sentence remained nearly the same.Ruiz filed a petition for resentencing in March 2023 under California Penal Code section 1170, subdivision (d), which allows individuals sentenced to life without parole for crimes committed as minors to seek resentencing after 15 years of incarceration. The Superior Court of Orange County denied the petition, calculating Ruiz’s incarceration period from his sentencing date in August 2010, and found he had not been incarcerated for 15 years.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court agreed with Ruiz’s argument that his period of incarceration began in January 2008 when he was taken into custody, not from his sentencing date. The court interpreted the term "incarcerated" in section 1170, subdivision (d)(1)(A) to mean the time when Ruiz was first placed in jail, which was January 29, 2008. Since Ruiz had been continuously incarcerated since that date, he had been incarcerated for more than 15 years by the time he filed his petition in March 2023.The Court of Appeal reversed the trial court’s order and remanded the case for reconsideration of Ruiz’s petition for resentencing, instructing the lower court to consider the petition based on the correct interpretation of the statute. View "People v. Ruiz" on Justia Law

In 2000, the petitioner was convicted of second-degree murder and sentenced to 15 years to life, plus an additional four years for a firearm enhancement. While serving this sentence, he was convicted in 2008 of aggravated assault by a prisoner and received a four-year determinate sentence under the Three Strikes law, to be served consecutively. In 2022, the petitioner was considered for parole under the Elderly Parole Program, which applies to inmates over 50 who have served at least 20 years. The parole board found him suitable for parole, but the California Department of Corrections and Rehabilitation (CDCR) required him to serve his four-year determinate sentence first.The petitioner filed a writ of habeas corpus in the Kings County Superior Court, arguing that he was entitled to immediate release and that his determinate sentence should not apply. The superior court denied the petition, ruling that the petitioner was ineligible for parole under the Elderly Parole Program because he had been sentenced under the Three Strikes law.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court held that the Three Strikes exclusion under section 3055, subdivision (g), applies to prisoners who were convicted and sentenced under the Three Strikes law, even if they had already commenced serving a prison sentence. The court rejected the petitioner’s arguments, stating that his "current sentence" included the term imposed under the Three Strikes law, making him ineligible for early parole release under the Elderly Parole Program. The court also found that the legislative history confirmed this interpretation and that the case of In re Hoze did not apply because it did not address the Three Strikes exclusion. The petition for writ of habeas corpus was denied. View "In re Brown" on Justia Law

Flor de Maria Mejia was involved in a hit-and-run accident where she struck a bicyclist, William McGill, with her van and fled the scene. The collision caused significant damage to her vehicle and injuries to herself. Shortly after the incident, a parking control officer observed Mejia driving the damaged van and later identified her as the driver. Mejia and her boyfriend subsequently burned the van. Mejia sought medical attention, claiming her boyfriend had assaulted her, but refused a rape examination. Evidence from the burned van and Mejia's social media messages linked her to the crime.The Superior Court of Los Angeles County convicted Mejia of fleeing the scene of an injury accident, resulting in a three-year prison sentence. The jury found her guilty of violating Vehicle Code § 20001, subd. (b)(2), and imposed a restitution obligation of $7,500. Mejia's defense included multiple inconsistent statements to the police and an attempt to shift blame to her boyfriend, Carter, who also testified at trial.The California Court of Appeal, Second Appellate District, reviewed the case. Mejia challenged the identification process, the prosecutor's comments during closing arguments, and the sentencing enhancement for personal infliction of great bodily injury. The court found the identification process was not unduly suggestive, and any assumed Griffin error (prosecutor's comment on Mejia's failure to testify) was harmless beyond a reasonable doubt. The court also addressed the prosecutor's improper comment during rebuttal, concluding that the trial court's immediate and forceful admonition to the jury mitigated any potential prejudice.The court upheld the jury's finding of the sentencing enhancement, stating substantial evidence supported the conclusion that Mejia's failure to render aid exacerbated McGill's injuries. The court affirmed the trial court's restitution order, finding no abuse of discretion. The judgment of the Superior Court was affirmed. View "People v. Mejia" on Justia Law

Nathaniel DiMaggio filed a petition for writ of mandate to challenge the denial of his motion to suppress evidence obtained from his cellphone and tablet. DiMaggio argued that the Monterey County Sheriff’s Office exceeded the scope of the search warrant and that the trial court erred in finding the sheriff’s office acted in good faith. The Monterey County District Attorney contended that the sheriff’s office properly executed the search warrant and acted in good faith.The Monterey County Superior Court issued a search warrant authorizing the search of DiMaggio’s cellphone and tablet for evidence related to a sexual assault within a specific date range. During the search, the sheriff’s office found images of suspected child pornography, which were outside the specified date range. DiMaggio filed a motion to suppress this evidence, arguing it was obtained in violation of the Fourth Amendment. The trial court found that the sheriff’s office exceeded the scope of the warrant but denied the motion to suppress, applying the good faith exception to the exclusionary rule.The California Court of Appeal, Sixth Appellate District, reviewed the case and agreed with DiMaggio. The court found that the sheriff’s office knowingly exceeded the scope of the search warrant by including items without timestamps, which were not authorized by the warrant. The court held that the good faith exception did not apply because the actions of the sheriff’s office were not objectively reasonable and were part of a standard protocol that disregarded the warrant’s limitations. The court issued a peremptory writ of mandate directing the trial court to vacate its order denying the motion to suppress and to enter a new order suppressing any evidence obtained outside the date and time limitations set forth in the search warrant. View "DiMaggio v. Superior Court" on Justia Law

The defendant was charged with vehicle theft and receiving stolen property. He pled no contest to misdemeanor vehicle theft, and the court placed him on three years of probation, reserving the issue of victim restitution. The prosecutor did not inform the court or the defendant of a $440 restitution claim submitted by the victim before the probation period ended. The court did not order the defendant to pay any specific restitution amount during his probation.The defendant's probation expired without any restitution order being issued. He then filed a petition for dismissal under Penal Code section 1203.4, asserting he had fulfilled all probation conditions. The probation department supported his petition, confirming he met all terms and no victim restitution was ordered. However, the prosecutor objected, claiming the defendant still owed $440 in restitution. The trial court denied the petition, citing the reserved restitution.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. The court held that the defendant fulfilled all probation conditions since no specific restitution amount was ordered during his probation. The court emphasized that reserving restitution is not equivalent to ordering payment of a specific amount. The court also noted that the prosecutor's failure to pursue the restitution claim during the probation period meant the defendant was not responsible for any unpaid restitution. Consequently, the court reversed the trial court's order denying the defendant's petition for dismissal. View "People v. Daffeh" on Justia Law

In 1987, Michael Hill was convicted of two murders and sentenced to death. Hill maintained that the murders were committed by Michael McCray, whose statements to the police incriminated both himself and Hill. McCray did not testify at trial, invoking his privilege against self-incrimination, but his statements were admitted under the hearsay rule. Decades later, Hill discovered that the prosecution had failed to disclose a promise not to prosecute McCray for his involvement in the case. Hill filed a habeas corpus petition alleging violations of Brady v. Maryland and Napue v. Illinois.The trial court dismissed Hill’s claims, finding he failed to establish a prima facie case. The court concluded that the evidence against Hill was overwhelming and that the failure to disclose the non-prosecution agreement did not undermine confidence in the verdict. The court also found that Hill did not plead that false evidence was presented to the jury, as required under Napue.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court found that Hill established a prima facie case for both Brady and Napue violations. The court noted that McCray’s testimony at the preliminary hearing was misleading and that the prosecution’s suppression of the non-prosecution agreement allowed McCray to assert his privilege against self-incrimination, leading to the admission of his statements without cross-examination. The court concluded that the suppressed evidence was material and could have affected the jury’s verdict. The court reversed the trial court’s order and remanded the case for further proceedings, directing the trial court to issue an order to show cause. View "In re Hill" on Justia Law

The case involves a shooting incident that occurred around midnight on October 7, 2020, in San Francisco. The victim, who was intoxicated, was walking home when a white SUV approached him. After a brief interaction, the SUV drove away, but the victim made an obscene gesture, prompting the driver to return and fire two shots, one of which hit the victim's leg. The police later found a nine-millimeter Luger cartridge case at the scene. Six days later, officers located a white Mercedes SUV matching the description, arrested Raymond Tidd, and found a loaded gun and a similar cartridge in the vehicle.In the Superior Court of San Francisco, Tidd was charged with attempted murder, assault with a semiautomatic firearm, and discharging a firearm from a motor vehicle. He pled guilty to additional firearm possession charges. At trial, the prosecution presented expert testimony from a firearms toolmark analyst, Jacobus Swanepoel, who claimed that the cartridge case found at the scene matched a test-fired cartridge from Tidd's gun. Despite the defense's objections, the trial court allowed this testimony. The jury convicted Tidd of assault with a firearm and discharging a firearm from a motor vehicle but could not reach a verdict on the attempted murder charge.The California Court of Appeal, First Appellate District, reviewed the case. The court found that the trial court had abused its discretion by admitting Swanepoel's testimony without sufficient evidence of its reliability. The court noted that Swanepoel's method lacked objective standards and was based on subjective judgment without supporting studies or validation. Consequently, the court held that the admission of this expert testimony was prejudicial and reversed the judgment, remanding the case for further proceedings. View "People v. Tidd" on Justia Law

In 2017, a minor admitted to two counts of assault with intent to commit rape and was initially placed in a Level B program. Due to multiple probation violations, the juvenile court later committed him to the Division of Juvenile Justice (DJJ) in 2019. After being discharged from DJJ in April 2023, the juvenile court imposed a probation condition requiring the minor to register as a sex offender under Penal Code section 290.008. The minor appealed, arguing that this requirement violated his equal protection rights because it treated him differently from minors who committed similar offenses after the juvenile justice realignment, which closed DJJ and transferred responsibilities to county facilities.The Superior Court of Sacramento County upheld the probation condition, rejecting the minor's equal protection argument. The court found that the sex offender registration requirement did not involve a loss of liberty and thus did not implicate a fundamental right, applying the rational basis standard of review. The court reasoned that the Legislature could have determined that minors in county facilities have a lower risk of recidivism due to more effective treatment, justifying the differential treatment.The California Court of Appeal, Third Appellate District, reviewed the case de novo and affirmed the lower court's decision. The court held that the rational basis standard applied because the sex offender registration requirement did not involve a fundamental right or suspect classification. The court found that a rational basis existed for the differential treatment, as the Legislature could have reasonably concluded that minors already in DJJ custody posed a higher risk of recidivism and required continued registration to protect public safety. Thus, the court found no equal protection violation and affirmed the dispositional order. View "People v. I.B." on Justia Law