Justia Criminal Law Opinion Summaries

Michael Lovelace was charged with multiple felonies, including rape and aggravated kidnapping, along with special sentencing enhancements and aggravating factors under California Rules of Court, rule 4.421(c). Lovelace challenged the constitutionality of the rule 4.421(c) residual clause, which allows for consideration of any other factors that reasonably relate to the defendant or the circumstances under which the crime was committed. He argued that this clause violated the separation of powers and due process principles.The trial court denied Lovelace's motion to set aside the information, leading him to seek interlocutory review by petition for a writ of prohibition. The Court of Appeal of the State of California, First Appellate District, Division Four, issued an order to show cause and held oral arguments. Following the Supreme Court's decision in People v. Lynch, which provided guidance on the interpretation and application of Senate Bill 567 amendments to section 1170, subdivision (b)(2), the court took supplemental briefing.The Court of Appeal granted writ relief, holding that the rule 4.421(c) residual clause is unconstitutionally vague and exceeds the Judicial Council’s delegated authority to adopt rules promoting uniformity in sentencing. The court found that the clause grants prosecutors and juries open-ended power to define sentencing criteria on an ad hoc basis, violating the separation of powers clause of the California Constitution. The court directed the trial court to vacate its order denying Lovelace's section 995 motion and to enter a new order sustaining the motion to the extent it seeks to invalidate the residual clause. The court prohibited the trial court from allowing a jury to consider any findings based on the rule 4.421(c) residual clause. View "Lovelace v. Superior Court" on Justia Law

Petitioner Kristopher Bunker filed a petition for writ of habeas corpus challenging the superior court's denial of his request for an automatic bail review hearing under Penal Code section 1270.2. At his arraignment, the superior court held a preliminary bail review hearing and ultimately decided to hold Bunker without bail, citing a substantial likelihood of great bodily injury if he were released. Bunker then requested a bail review hearing within five days, which the court denied, stating it was pending a change in circumstances.Bunker subsequently filed a writ of habeas corpus with the Court of Appeal of the State of California, Fourth Appellate District, Division Two, arguing that he was entitled to a bail review hearing within five days as a matter of right, without needing to demonstrate a change in circumstances. The Court of Appeal construed the petition as one seeking a writ of mandate and requested opposition, but no response was filed.The Court of Appeal held that under Penal Code section 1270.2, Bunker was entitled to an automatic bail review hearing within five days of the original bail order without needing to show a change in circumstances. The court found that the superior court erred in denying Bunker's request for such a hearing. Consequently, the Court of Appeal issued a peremptory writ of mandate directing the superior court to vacate its pretrial detention order and conduct a new bail hearing in accordance with section 1270.2. The decision was made final immediately. View "Bunker v. Superior Court" on Justia Law

In 2002, Juan Lara was convicted of two counts of attempted murder and sentenced to 29 years and 4 months in prison. In 2023, under section 1172.6, the trial court vacated these convictions and redesignated them as one count of shooting at an inhabited dwelling and three counts of assault with a firearm. Lara appealed the three counts of assault with a firearm.The Superior Court of Los Angeles County initially found sufficient evidence to support the redesignation of Lara’s attempted murder convictions. The court vacated the attempted murder convictions and redesignated one as shooting at an inhabited dwelling and added three counts of assault with a firearm. Lara argued that the evidence supporting the additional assault convictions was inadmissible hearsay and insufficient.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the redesignation of one count of assault with a firearm, finding it supported by substantial evidence. However, it reversed the additional two counts of assault with a firearm, concluding that the trial court lacked the authority to impose these new convictions. The appellate court held that section 1172.6, subdivision (e) does not permit the imposition of uncharged or unlitigated offenses when redesignating a vacated conviction. The court remanded the case for resentencing on the affirmed counts. View "P. v. Lara" on Justia Law

The defendant, Aquil Qadir Lawson, was convicted of murder after shooting Madison Rose Weiss while she was in her car. Lawson, who is Black, argued that the trial court's evidentiary rulings were influenced by implicit racial bias, violating the California Racial Justice Act of 2020. He claimed that the court's decisions emphasized his criminality while minimizing the victim's, who was white. Specifically, Lawson contended that the exclusion of evidence regarding Weiss's illegal activities and the inclusion of his Instagram posts and fraud activities demonstrated racial bias.In the Superior Court of Los Angeles County, the jury found Lawson guilty of second-degree murder and the firearm allegation true. The court excluded evidence of Weiss's involvement in sex work, vaccination card fraud, and other illegal activities, deeming them irrelevant to the case. The court also excluded evidence of a gun found near the crime scene, as it was not connected to the shooting. Conversely, the court admitted Lawson's Instagram posts, which contained statements related to the shooting, and evidence of his involvement in fraud, which was used to impeach his credibility.The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that the trial court's evidentiary rulings were based on relevance and did not demonstrate implicit racial bias under the Racial Justice Act's preponderance-of-the-evidence standard. The appellate court found that the trial court's decisions were ordinary evidentiary rulings and that Lawson failed to show by a preponderance of the evidence that the rulings were motivated by racial bias or animus. Consequently, the appellate court affirmed the judgment of the Superior Court. View "P. v. Lawson" on Justia Law

In the late hours of December 5, 2000, Tramell Vernon Taylor, Darryl McCoy, and Dewayne Richardson planned to rob several men at a nearby motel, including Kendall M., a drug dealer. In the early morning of December 6, 2000, a gun battle ensued at the motel, resulting in Kendall being shot and McCoy being fatally shot. Taylor and Richardson were believed to be members or associates of a gang, while Kendall was affiliated with a rival gang. Extensive ballistics evidence was collected, indicating multiple firearms were involved in the shooting.Taylor and Richardson were convicted of conspiracy to commit robbery and the first-degree murder of McCoy. The jury found true a gang enhancement and a special circumstance that the murder was committed during a robbery. Taylor was sentenced to life without the possibility of parole for the murder, with a concurrent 12-year sentence for the conspiracy. On appeal, the court affirmed the convictions with minor corrections to the abstract of judgment.Taylor filed a petition for resentencing under section 1172.6, which the trial court initially denied without a statement of reasons. On appeal, the denial was reversed, and the case was remanded for an evidentiary hearing. At the hearing, the trial court denied the petition, finding that Taylor could still be convicted of murder under the provocative act doctrine, as he was a major participant who acted with reckless indifference to human life.The California Court of Appeal, Fifth Appellate District, reviewed the case and found that the trial court had misconstrued the elements of the applicable offense. The appellate court held that the trial court's findings did not support a valid theory of murder under current law. The order denying the petition was reversed, and the case was remanded for further proceedings consistent with the appellate court's opinion. View "People v. Taylor" on Justia Law

Mariano Albert Valdez was sentenced to life without the possibility of parole (LWOP) for a murder he committed at age 17. In 2018, Valdez petitioned for resentencing under Penal Code section 1170(d)(1), which allows juvenile offenders sentenced to LWOP to seek resentencing after 15 years of incarceration. The trial court granted the petition and resentenced Valdez to 50 years to life. In 2024, Valdez filed another petition for resentencing, arguing that his 50-year-to-life sentence was the functional equivalent of LWOP, citing People v. Heard, which held that denying resentencing relief to juvenile offenders sentenced to the functional equivalent of LWOP violates equal protection.The trial court construed Valdez's filing as a petition under section 1170(d)(10), which allows for resentencing after 20 years of imprisonment if the defendant was resentenced to LWOP or its functional equivalent. The trial court granted the petition, reasoning that Valdez's 50-year-to-life sentence was the functional equivalent of LWOP and that excluding him from resentencing relief would violate equal protection.The People petitioned for a writ of mandate to compel the trial court to deny Valdez's resentencing relief. The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the reasoning in Heard does not apply to section 1170(d)(10) if the defendant was eligible for youth offender parole under the sentence imposed at resentencing under section 1170(d)(1). Since Valdez was eligible for youth offender parole under his 50-year-to-life sentence, it was not the functional equivalent of LWOP. Therefore, Valdez was not entitled to relief under section 1170(d)(10).The court granted the petition for writ of mandate, directing the trial court to vacate its order granting Valdez resentencing relief and to enter a new order denying the petition for resentencing. View "P. v. Superior Court" on Justia Law

Richard Martinez, a licensed plumber, contracted with Gayle Jelley to construct a pool in her backyard for $26,900. Jelley made several payments totaling $9,000, but Martinez abandoned the project after partially completing the excavation and rebar installation. It was later discovered that Martinez's contractor's license had expired before the project began. The Department of Consumer Affairs, Contractors State Licensing Board (CSLB) confirmed that Martinez had never held a valid contractor's license and had previously received three administrative citations for unlicensed contracting.The People charged Martinez with grand theft, acting as a contractor without a license, requiring an excessive downpayment, and unlawfully receiving payments exceeding the work performed. Martinez was arraigned on December 9, 2021, and later filed a motion to dismiss based on a violation of his speedy trial rights, citing a four-and-a-half-year delay in prosecution. He argued that the delay resulted in the loss of key witnesses and evidence, causing actual prejudice to his defense.The Superior Court of Riverside County granted Martinez's motion to dismiss, citing the prosecution's lack of effort to arrest Martinez after the complaint was filed. The People appealed the decision, arguing that the trial court applied an incorrect legal standard by not requiring Martinez to demonstrate actual prejudice.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that Martinez failed to affirmatively demonstrate actual prejudice resulting from the delay, as required under state constitutional law. The court also noted that the trial court did not conduct the necessary analysis of the four factors required to determine a federal speedy trial violation for the misdemeanor charges. The appellate court reversed the trial court's decision in part and remanded the case with directions to conduct the proper analysis for the federal speedy trial claim on the misdemeanor charges and to deny the motion to dismiss on the felony charge. View "People v. Martinez" on Justia Law

Jesse Gonzalez, Jr. was convicted in 2012 of attempted deliberate premeditated murder and assault with a deadly weapon, with enhancements for inflicting great bodily injury and using a dangerous weapon. He was sentenced to 17 years to life with the possibility of parole and credited with 700 days served. The sentence was later recalled, but the credit total remained unchanged. On direct appeal, the court corrected the sentence to life with the possibility of parole plus six years but did not address the credit count. Gonzalez filed a habeas corpus petition in 2022, claiming his credits were miscalculated. The trial court denied the petition, but the appellate court granted a partial remand for recalculating credits, denying Gonzalez's request to be present.The Superior Court of Imperial County recalculated the credits but initially made an error. After a letter from appellate counsel, the court corrected the credits to 771 days. Gonzalez appealed, arguing that the incorrect credit calculation was an unauthorized sentence and that he was entitled to full resentencing and to be present during the recalculation.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that a full resentencing was not warranted because the correction of custody credits did not affect the overall sentence or require the exercise of judicial discretion. The court also concluded that Gonzalez's presence was not necessary for the recalculation of credits, as it was a ministerial act. The court found no prejudice to Gonzalez from the trial court's actions and affirmed the order. View "People v. Gonzalez" on Justia Law

The petitioner, Dana Stubblefield, was convicted in 2020 of forcible rape and related offenses and sentenced to 15 years to life in prison. On direct appeal, the conviction was found legally invalid due to a violation of the California Racial Justice Act (RJA). The appellate court reversed the judgment, vacated the conviction and sentence, and remanded the case for new proceedings. Before the remittitur issued, Stubblefield filed a motion for release on his own recognizance or on bail, which the trial court denied, citing lack of jurisdiction.The trial court, upon receiving the jury's verdict in July 2020, remanded Stubblefield into custody, and he was sentenced in October 2020. Stubblefield appealed in November 2020, arguing that the prosecution violated the RJA. The appellate court agreed, reversed the conviction, and remanded the case. Stubblefield then sought release pending the final outcome of the appeal, but the trial court denied the motion, stating it lacked jurisdiction without the remittitur. Stubblefield petitioned the appellate court for a writ of mandate to compel the trial court to rule on his motion.The California Court of Appeal, Sixth Appellate District, reviewed the case and concluded that the trial court had jurisdiction to rule on Stubblefield's motion for release pending appeal, despite the remittitur not yet issuing. The court held that the trial court's jurisdiction to hear a motion for release is supported by the Penal Code, which allows for bail after conviction and pending appeal. The appellate court issued a peremptory writ of mandate directing the trial court to vacate its decision and rule on the merits of Stubblefield's motion for release. View "Stubblefield v. Super. Ct." on Justia Law

In 2011, the defendant was convicted by a jury of shooting at an occupied motor vehicle and six counts of assault with a firearm. The jury found true the allegations that the defendant personally and intentionally discharged a firearm causing great bodily injury or death. The court sentenced the defendant to a total of 32 years to life in prison.The defendant later filed a petition for resentencing under Assembly Bill 600 and Penal Code section 1172.1, arguing that he was a youth at the time of his conviction and had since participated in self-help groups and college courses while incarcerated. He requested the court to consider his youth and personal growth in resentencing. The Superior Court of Fresno County denied the petition, stating that under section 1172.1, a defendant is not entitled to file a petition seeking relief from the court.On appeal, the defendant's counsel filed a brief under People v. Delgadillo, asserting that there were no arguable issues on appeal. The California Court of Appeal, Fifth Appellate District, notified the defendant that he had 30 days to file a supplemental brief, but he did not do so. The court dismissed the appeal as abandoned, following the procedure outlined in People v. Delgadillo, which held that the Wende/Anders procedure does not apply to appeals from the denial of postconviction relief under section 1172.6. The court concluded that due process does not require independent review in this context and dismissed the appeal. View "P. v. Rosemond" on Justia Law