Justia Criminal Law Opinion Summaries

Defendant was convicted of the first degree murder of a Los Angeles County Deputy Sheriff and the premeditated attempted murder of the deputy sheriff's partner. The jury found true the special circumstance allegations that the murder of the deputy sheriff was committed for the purpose of avoiding and preventing a lawful arrest and that the deputy sheriff was a peace officer engaged in the performance of his duties when defendant knowingly and intentionally killed him. The jury also found true the allegations that defendant personally used a firearm in the murder and attempted murder, previously had been convicted of a serious felony, and had served two prior prison terms. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues related to the denial of a motion for discovery of law enforcement officers' personnel files; the denial of a motion to continue the trial; asserted errors during voir dire; guilt phase challenges; penalty phase challenges; assertedly improper denial of motion for new trial based upon insufficiency of the evidence; assertedly improper role of race in the proceedings; asserted denial of an impartial judge; challenges to the constitutionality of California's death penalty statutes; and cumulative prejudicial effects of asserted errors.

Defendant was convicted of first degree murder of two victims, with a multiple-murder special circumstance finding. Defendant was also convicted of assault with a deadly weapon on another victim, with a a great bodily injury finding. Firearm use and criminal street gang findings were made as to all three counts. Defendant was sentenced to death and this appeal was automatic. The court affirmed the judgment after addressing issues involving the admissibility of defendant's confession; the trial court's refusal to instruct on heat of passion; instructions on perfect and imperfect self-defense; defendant's waiver of his right to testify; victim impact evidence; asserted improper prosecutorial argument; lack of remorse; refusal to instruct on lingering doubt; and challenges to the death penalty law and instructions.

Defendant was convicted of murder in the first degree with the special circumstance of murder during the commission of a robbery and sentenced to death. Defendant was also convicted of robbery and assault with a deadly weapon, using a handgun to commit both the robbery and assault. On automatic appeal, the court addressed pretrial and jury selection issues; issues relating to guilt; issues relating to penalty; and the adequacy of the appellate record. The court ultimately affirmed the judgment.

Defendant was sentenced to death on a first degree murder conviction by trying to suffocate the victim, putting her in the trunk of a car and driving to a remote location, pouring gasoline on her and the outside of the trunk, and lighting the gasoline on fire. The victim burned to death trapped inside of the trunk. On automatic appeal, the court affirmed the convictions of first degree murder and the other charged felonies, but the court reversed as to the penalty of death and set aside the kidnapping special circumstances finding because the trial court erroneously instructed the jury.

Defendant was convicted of various crimes against a number of victims. At issue was whether there was sufficient evidence to support defendant's conviction of second degree murder under a theory of implied malice when defendant cracked the victim's skull by punching him during a fight. The Court of Appeal reduced the conviction to voluntary manslaughter because of insufficient evidence of implied malice, focusing solely on the subjective component of implied malice. The court held, however, that the evidence was sufficient to satisfy both the physical and mental components of implied malice. Accordingly, the court held that the Court of Appeal erred in finding otherwise.

Defendant was convicted of crimes arising out of two separate assaults. At issue was whether California courts could apply a higher standard of mental competence for self-representation than for competency to stand trial in light of the Supreme Court's holding under Indiana v. Edwards. Because California law has long been that criminal defendants have no right of self-representation, the court concluded that California courts could deny self-representation when the U.S. Constitution permitted such denial. The court also concluded that the trial court acted within its discretion in revoking defendant's self-representation status.

Defendant was convicted of first degree murder and the jury made true findings as to the burglary-murder and robbery-murder special circumstances. The jury was fully instructed as to the elements of the felony-murder special circumstances for a defendant who was the actual killer. However, the jury was not fully instructed as to the elements of the special circumstances for a defendant who was not the actual killer, including the requirement that a nonkiller, in the absence of a showing of intent to kill, must have acted with reckless indifference to human life and as a major participant in the commission of the underlying felony. The Court of Appeal determined the omission in the instructions was harmless and affirmed the judgment. The court agreed that the instructional error was amenable to harmless-error review, but found that the error here was prejudicial. Therefore, the court reversed the jury's findings on the special circumstances of burglary murder and robbery murder, as well as defendant's sentence of life imprisonment without the possibility of parole, remanding the matter for further proceedings.

Defendant, a 15-year-old, was tried as an adult and convicted of the murder of a 72-year-old and of five first degree burglaries relating to the residences of the victim and two other women. At issue was whether defendant made a postwaiver invocation of his Miranda rights by asking several times to speak to his mother or by making certain other statements while being questioned. The court held that juveniles claiming a postwaiver invocation of their Miranda rights were properly subject to the Davis v. United States standard. Applying that standard, the court concluded that the trial court did not err in finding that defendant's requests to speak to his mother and other statements were not sufficiently clear to require cessation of the interrogation. Accordingly, defendant's confessional statements were properly admitted at trial, and the contrary judgment of the Court of Appeal must be reversed.

Defendant was convicted, among other things, for first degree murder and sentenced to death. The jury found that the murder was committed during the course of robbery, kidnapping, rape, and sexual penetration by a foreign object, and that it involved the infliction of torture. On automatic appeal, the court affirmed the convictions of first degree murder and the other charged felonies. The court reversed as to the sentence of death, the jury's findings that defendant personally used a dangerous or deadly weapon, the jury's true finding on the special circumstance of murder with the infliction of torture, and the state prison sentence. The court remanded for a new penalty trial and for resentencing.

Defendant was convicted by a jury of a petty theft offense, but admitted a prior felony conviction. Defendant appealed only the admission of the prior conviction. At issue was whether Penal Code section 1237.5 applied under these circumstances. The court held that People v. Fulton erroneously determined that section 1237.5 applied to appeals where the defendant had not pleaded guilty or nolo contendere. The court also held that section 1237.5's underlying purpose of promoting economy would not be advanced by extending it to convictions after pleas of not guilty. Accordingly, the court reversed the Court of Appeal and remanded for further proceedings.