Justia Criminal Law Opinion Summaries

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

In 2017, the defendant pleaded no contest to attempted second-degree robbery with firearm enhancements, resisting a peace officer, hit and run, and assault with a firearm. He also admitted to a prior strike conviction. The court sentenced him to a total of 27 years and 8 months in prison. In 2019, the defendant filed a motion to reconsider the restitution fine, which was denied. In 2023, he filed a petition for resentencing under section 1172.6, which was also denied.The defendant then filed a "Request for Recall of Sentence and Resentencing" in March 2024, citing changes in the law under Assembly Bill 600 and section 1172.1. The Superior Court of Tulare County denied the petition, stating it lacked jurisdiction to resentence him. The defendant appealed this decision, arguing that the court had jurisdiction under the amended laws and should have exercised its discretion.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court concluded that the trial court had jurisdiction to resentence the defendant under section 1172.1, as amended by Assembly Bill 600, which allows for resentencing when applicable sentencing laws have changed. The appellate court found that the trial court erred in concluding it lacked jurisdiction and that the order denying the petition was appealable because it affected the defendant's substantial rights.The appellate court reversed the trial court's order and remanded the case for further proceedings, instructing the trial court to exercise its discretion in considering whether to recall and resentence the defendant under the amended laws. View "People v. Chatman" on Justia Law

Steven Ellis was convicted of kidnapping, attempted kidnapping, dissuading a witness from reporting a crime, and making criminal threats. The incident involved Ellis accosting two victims, Yasmin and Blanca, on separate occasions. Ellis forcibly moved Yasmin from a sidewalk to the middle of the street, and later grabbed Blanca from behind, placing her in a chokehold and threatening to kill her and her friend, Jessica. Ellis was identified by the victims and arrested the following day.The Superior Court of Los Angeles County found Ellis guilty on multiple counts, including the kidnapping of Yasmin. The jury did not reach a verdict on an alternative attempted kidnapping charge, which was subsequently dismissed. Ellis was sentenced to a total of nine years and six months in state prison, with the upper term of eight years for the kidnapping count. Ellis appealed the conviction, arguing insufficient evidence for the kidnapping charge and improper sentencing.The California Court of Appeal, Second Appellate District, reviewed the case. The court found that the evidence was insufficient to support the asportation element required for the kidnapping conviction. The movement of Yasmin was deemed not substantial in character, as it did not appreciably change her environment or increase the risk of harm. Consequently, the court reversed Ellis’s kidnapping conviction and reduced it to felony false imprisonment. The case was remanded for a full resentencing.The court also noted that the trial court must reconsider whether the sentences for the criminal threats convictions should be stayed under section 654, as concurrent sentences were initially imposed without proper consideration of this statute. The judgment was affirmed in part, reversed in part, and remanded for resentencing. View "People v. Ellis" on Justia Law

Defendant Benny Townes was convicted of multiple sexual offenses against his biological daughters, Jane Doe 1 and Jane Doe 2. Jane Doe 1, who was 16 years old, was raped and impregnated by the defendant. Jane Doe 2, who was 13 and 14 years old at the time, was raped, sodomized, and subjected to lewd acts by the defendant. The defendant admitted to having sexual intercourse with Jane Doe 1 but argued that it was consensual and not against her will.The Superior Court of Riverside County found the defendant guilty on all counts, including forcible rape, incest, lewd acts with a minor, and sodomy. The court sentenced him to 150 years to life in prison. The defendant appealed, contending that there was insufficient evidence to support the finding that he raped Jane Doe 1 by means of force or duress, and therefore, his convictions on counts 1 and 2 should be reversed. He also argued that the multiple victim enhancement allegations should be reversed if counts 1 and 2 were overturned.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case and affirmed the judgment. The court held that substantial evidence supported the finding of duress, which can be purely psychological. The defendant had instilled in Jane Doe 1 the belief that he was the son of God and that disobeying him would result in divine retribution. This psychological coercion was sufficient to constitute duress under Penal Code section 261, subdivisions (a)(2) and (b)(1). The court concluded that the threat of divine retribution, as taught by the defendant, was enough to uphold the convictions for forcible rape. View "People v. Townes" on Justia Law