Justia Criminal Law Opinion Summaries

Defendant was found guilty of failing to stop at a red traffic light at an intersection. Defendant's conviction was based on evidence generated by an automated traffic enforcement system (ATES), otherwise known as a red light traffic camera. Defendant’s conviction was upheld on appeal. At issue before the Supreme Court was whether the trial court properly admitted the ATES evidence over Defendant’s objections of inadequate foundation and hearsay. The Supreme Court affirmed, holding (1) sufficient evidence was submitted for the court to sustain a finding that the ATES evidence was adequately authenticated; and (2) ATES evidence does not constitute hearsay. View "People v. Goldsmith" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted premeditated murder, two counts of second degree robbery and arson causing great bodily injury. The jury returned a verdict of death. The Supreme Court vacated Defendant’s arson-murder special-circumstance finding but otherwise affirmed the judgment in its entirety, holding (1) the trial court did not err in restricting Defendant’s counsel’s questioning of prospective jurors during voir dire; (2) the evidence was insufficient to support the arson-murder special circumstance because the arson did not involve an inhabited structure or property; (3) the trial court did not abuse its discretion in dismissing a juror during the trial; (4) the trial court did not prejudicially err in its instructions to the jury; (5) the trial court did not err in refusing to declare a mistrial after the penalty jury initially declared it was deadlocked; and (6) Defendant’s challenges to the constitutionality of California’s death penalty scheme were without merit. View "People v. Debose" on Justia Law

If a defendant commits a killing out of an unreasonable belief in the need for self-defense, he or she may be convicted of voluntary manslaughter but not murder. After a jury trial in this case, Defendant was convicted of first degree murder. On appeal, the court of appeal rejected Defendant’s argument that the trial court erred in failing to instruct the jury on unreasonable self-defense, concluding that the doctrine does not apply when belief in the need for self-defense arises solely from the defendant’s delusional mental state. The Supreme Court affirmed, holding (1) at a trial on the question of guilt, the defendant may not claim unreasonable self-defense based on insane delusion, and a purely delusion belief in the need to act in self-defense may be raised as a defense, but that defense is insanity; and (2) because Defendant’s claim of unreasonable self-defense was based entirely on a delusional mental state that amounted to legal insanity, the trial court properly denied Defendant’s request for an instruction on unreasonable self-defense. View "People v. Elmore" on Justia Law

After a jury trial, Defendant was found guilty of first degree willful, deliberate and premeditated murder on the theory that the Defendant either directly aided and abetted the murder or that Defendant aided and abetted the target offense of assault or disturbing the peace, the natural consequence of which was murder. The court of appeal reversed Defendant’s first degree murder conviction, holding that the trial court erred in failing to instruct the jury that it must find first degree premeditated murder, rather than first degree murder, was the natural and probable consequence of either target offense and that the error was not harmless. The Supreme Court affirmed the court of appeal but on different grounds, holding (1) an aider and abetter may not be convicted of first degree premeditated murder under the natural and probable consequences doctrine; rather, his liability for that crime must be based on direct aiding and abetting principles; and (2) because the jury in this case may have based its verdict of first degree premeditated murder on the natural and probable consequences theory, the first degree murder conviction must be reversed. View "People v. Chiu" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, sodomy, and forcible lewd act on a minor. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in failing to exclude expert testimony that the victim died by drowning in association with sexual assault; (2) the trial court did not err in the remainder of its evidentiary rulings; (3) the evidence was sufficient to support the convictions; (4) defense counsel provided constitutionally effective assistance; (5) the trial court did not err by accepting Defendant’s waiver of his right to present mitigating evidence; (6) Defendant’s voluntary absence during trial did not violate the federal Constitution; and (7) Defendant’s constitutional challenges to the death penalty law and related jury instructions were without merit. View "People v. Brown" on Justia Law

This appeal centered on the Realignment Act, which changed the punishment for some felony convictions. The Legislature provided that the sentencing changes “shall be applied prospectively to any person sentenced on or after October 1, 2011.” At issue in this case was whether the Act applies to defendants, such as the defendant in this case (Defendant), whose state prison sentences were imposed and suspended prior to October 1, 2011. The court of appeal determined that the trial court did not err in directing that Defendant’s sentence should be served in county jail rather than in state prison. The Supreme Court reversed, holding (1) the Act is not applicable to defendants who have had a state prison sentence imposed and suspended prior to October 1, 2011; and (2) therefore, upon revocation and termination of Defendant’s probation, the trial court erred, when ordering execution of Defendant’s previously imposed sentence, in committing Defendant to the county jail under the terms of the Act rather than to state prison according to the terms of the original sentence. View "People v. Scott" on Justia Law

Defendants, Stephen Edward Hajek and Loi Tan Vo, were convicted of, among other crimes, the murder of Su Hung. The jury found true lying-in-wait and torture-murder special circumstances as to both defendants. The jury also found true firearm use allegations as to Hajek and deadly or dangerous weapon use as to Vo, in Defendants’ commission of the murder, attempted murder, kidnapping, and false imprisonment counts. The jury returned verdict of death as to each defendant. The Supreme Court affirmed the death judgments, reversed the lying-in-wait special circumstances findings as to both defendants, and ordered that the firearm use enhancements found true as to Hajek be struck and replaced with deadly or dangerous weapon use enhancements, holding (1) there was insufficient evidence to show that Defendants intentionally killed the victim while lying in wait, but the reversal of the lying-in-wait special-circumstance findings did not require reversal of Defendants’ death sentences; and (2) a change in the law excluding pellet guns from the definition of a firearm required that Hajek’s firearm use enhancements involving the use of a pellet gun be struck, but the jury’s true findings on the firearm use enhancements necessarily included true findings on deadly or dangerous weapon use enhancements. View "People v. Hajek" on Justia Law

Defendants in these cases were both seventeen-year-old offenders who were convicted of special circumstance murder and sentenced to life imprisonment without the possibility of parole under Cal. Penal Code 190.5(b). After Defendants were sentenced, the U.S. Supreme Court decided Miller v. Alabama. On review, the California Supreme Court held (1) section 190.5(b), properly construed, confers discretion upon a trial court to sentence a juvenile convicted of special circumstance murder to life without parole, with no presumption in favor of life without parole; (2) Miller requires a trial court, in exercising its sentencing discretion, to consider the distinctive attributes of youth before imposing life without parole on a juvenile offender; (3) section 190.5(b) does not violate the Eighth Amendment to the U.S. Constitution because it authorizes and requires consideration of the distinctive attributes of youth highlighted in Miller, once the statute is understood not to impose a presumption in favor of life without parole; and (4) because the trial courts in these cases sentenced Defendants without awareness of the full scope of their discretion conferred by section 190.5(b) and without the guidance set forth in Miller, the cases must be remanded for resentencing. View "People v. Gutierrez" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted robbery, and second degree robbery. Following a retrial of the penalty phase trial, the jury sentenced Defendant to death for the murder conviction. The Supreme Court affirmed the judgment, including the death sentence, but ordered the clerk of the superior court to modify the abstract of judgment to reflect ninety-six days of conduct credit, holding that there was no reversible error in the jury selection and that the trial court did not err in its rulings during the guilt phase and the penalty phase, with the exception of denying Defendant presentence conduct credits. View "People v. Chism" on Justia Law

After a jury trial in 1995, Defendant was convicted of twelve counts of first degree murder and one count of attempted murder. Defendant’s victims abused drugs and worked as prostitutes. The trial court sentenced Defendant to death with respect to each of the twelve murder convictions. The Supreme Court affirmed, holding (1) the trial court’s denial of Defendant’s motion for a change of venue based on the public’s knowledge of his case did not deprive Defendant of due process of law or a fair trial; (2) the trial court did not err in denying Defendant’s motion to suppress evidence obtained as a result of a traffic stop; (3) the trial court did not err in denying discovery concerning murders of prostitutes with which Defendant was not charged; (4) the trial court did not err in failing to exclude evidence obtained during police questioning of Defendant and in making its other evidentiary rulings; (5) the extent and nature of the victim impact evidence did not deprive Defendant of his rights to due process, a fair trial, and a reliable penalty determination; and (6) California’s death penalty scheme, jury instructions, and procedures are constitutional. View "People v. Suff" on Justia Law