Articles Posted in Supreme Court of California

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The Supreme Court issued a writ of mandate directing the trial court to vacate its order denying Petitioner's request to release ballistics evidence for expert testimony in preparation for filing a habeas corpus petition, holding that the trial court erred in denying the request based solely in Petitioner's failure to establish good cause. Petitioner was sentenced to death for the first degree murders of two victims. In preparation for filing a habeas corpus petition, Petitioner filed his request for the ballistics evidence. The superior court denied Petitioner's request to release ballistics evidence for expert testimony under the authority of Cal. Penal Code 1054.9, which governs discovery in habeas corpus proceedings involving certain judgments, including a sentence of death. The court found specifically that Petitioner had failed to show good cause to believe his access to the evidence was reasonably necessary to obtain relief. The Supreme Court vacated the order, holding that, under the statute, a threshold showing of good cause is not required. View "Satele v. Superior Court of Los Angeles County" on Justia Law

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In this original habeas corpus action the Supreme Court granted Petitioner habeas corpus relief insofar as the petition sought relief from the judgment of death after accepting the finding of the referee that a prosecution witness had falsely identified Petitioner as the man who sexually assaulted her, holding that the false testimony was material. Petitioner was convicted of first degree murder and second degree murder and sentenced to death. Petitioner later filed a habeas corpus petition alleging, among other things, that a penalty phase witness had misidentified him as the man who assaulted and raped her. The Supreme Court appointed a referee who conducted an evidentiary hearing, after which the referee found that, during the penalty phase, the witness had testified falsely when she identified Petitioner as her assailant. Noting that the Court generally accepts the referee's findings, the Supreme Court granted Petitioner relief on the basis of false evidence by overturning his sentence of death, holding that the false testimony undermined this Court's confidence in the outcome of the trial and that Petitioner was entitled to relief on this claim as to the penalty verdict. View "In re Rogers" on Justia Law

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The Supreme Court affirmed Defendant's convictions of two counts of first degree murder and his sentence of death, holding that none of Defendant's challenges to his convictions and death sentence warranted reversal. Defendant was one of three members of a gang who were charged with the murders of Michael Faria and Jessica Salazar. This automatic appeal concerned only Defendant. The Supreme Court affirmed Defendant's conviction of two counts of first degree murder and death sentence, holding (1) any error in allowing a gang expert to testify was harmless; (2) the trial court did not err in declining to exclude two portions of a jailhouse conversation Defendant had with a friend; (3) there was sufficient evidence to support a finding that Defendant shot Faria; (4) the trial court did not abuse its discretion in limiting the cross-examination of a certain witness; (5) the trial court did not abuse its discretion in admitting a photograph depicting Faria's body; (6) the victim impact evidence admitting in this case was within the bounds of what precedents permit; and (7) Defendant's constitutional challenges to California's death penalty scheme failed. View "People v. Mendez" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first degree murder, with the special circumstance that the murder was committed during a rape, and Defendant's sentence of death holding that there was no prejudicial error in the proceedings below. Specifically, the Court held (1) the victim's brother testified at the penalty phase in contravention of a court order, but any prejudice was cured by the trial court's admonition and by other evidence undermining the significance of Defendant's assertions; (2) any assumed error in failing to instruct at the guilt phase on a good faith but unreasonable belief in consent to intercourse was not prejudicial; and (3) Defendant offered no compelling reasons for the Court to reconsider its precedent rejecting Defendant's constitutional challenges to California's death penalty scheme. View "People v. Molano" on Justia Law

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The Supreme Court affirmed Defendant's convictions for three counts of first degree murder and three counts of first degree attempted murder arising from two shootings committed by Defendant on the same day and Defendant's sentence of death, holding that only one error occurred during the proceeding, and the error was harmless beyond a reasonable doubt. Specifically, the Court held (1) none of Defendant's claims of error at the guilt phase had merit, and therefore, there was no cumulative error requiring reversal of his convictions; and (2) during the penalty phase, the trial court erred in failing to instruct the jury that a witness's prior conviction of a felony bore on his credibility, but the error was harmless, and therefore, there was no cumulative error requiring reversal of Defendant's penalty of death. View "People v. Mitchell" on Justia Law

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The Supreme Court reversed the judgment of the trial court upholding Defendants' convictions of two counts of attempted murder, holding that the evidence was insufficient to support an instruction on the kill zone theory in connection with one of the two alleged attempted murder victims. Defendants were jointly charged and tried on counts including first degree murder and two attempted murders. The trial court gave a kill zone instruction in connection with one of the two alleged attempted murder victims. Under the kill zone theory, a defendant may be convicted of the attempted murder of an individual who was not the defendant's primary target. The court of appeals upheld the attempted murder convictions. The Supreme Court reversed, holding (1) a jury may convict a defendant under the kill zone theory only when the evidence supports a finding that the defendant harbored the requisite specific intent to kill both the primary target and everyone within the zone of fatal harm; and (2) there was insufficient evidence in the record to support an instruction on the kill zone theory. View "People v. Canizales" on Justia Law

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The Supreme Court affirmed the judgment of the trial court sentencing Defendant Socorro Susan Caro to death for killing three of her four children, holding that any error in the admission of statements from a detective's interview of Defendant in the hospital after she underwent emergency surgery for a gunshot wound to her head was harmless. Specifically, the court held (1) the trial court committed certain evidentiary errors, but the errors were harmless, were not cumulatively prejudicial, and did not affect Defendant's right to present a defense; (2) assuming error on Defendant's claim that the prosecution should have provided its investigatory material about prospective jurors, the error was harmless; and (3) assuming that the prosecution committed misconduct, the misconduct did not require reversal. View "People v. Caro" on Justia Law

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The Supreme Court reversed the decision of the court of appeal affirming the decision of a resentencing court refusing to dismiss Defendant's conviction for street terrorism after Proposition 47 came into effect, holding that Defendant was entitled to have his street terrorism conviction dismissed. Proposition 47 reclassified as misdemeanors certain narcotics and theft offenses previously cast as felonies. The gang crime of street terrorism occurs when "a person who actively participates in any criminal street gang...willfully promotes, furthers, or assists in any felonious criminal conduct by members of that gang." On the basis of his act of stealing a bicycle Defendant was convicted of both felony grand theft and street terrorism. After Proposition 47 took effect, the resentencing court refused to dismiss Defendant's street terrorism conviction even though the theft of the bicycle supplied the "felonious criminal conduct" necessary for the commission of the offense. The court of appeal affirmed. The Supreme Court reversed, holding that Defendant was entitled to have his street terrorism conviction dismissed in a full resentencing. View "People v. Valenzuela" on Justia Law

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The Supreme Court reversed the judgment of the court of appeal granting Anthony Cook's petition for writ of habeas corpus and remanded the matter to the court of appeal with directions to deny the petition, holding that resort to a petition for writ of habeas corpus was unnecessary in this case, at least in the first instance. Cook was convicted of two counts of first degree murder and one count of premeditated attempted murder. Cook, who was seventeen years old when he committed the murders, was sentenced to life with the possibility of parole for the attempted murder and five consecutive terms of twenty-five years to life for the murders and enhancements. Cook later filed a petition for writ of habeas corpus arguing that his sentence was cruel and unusual punishment in violation of the Eighth Amendment and Miller v. Alabama, 567 U.S. 460 (2012). The court of appeal granted the writ, holding that, in light of People v. Franklin, 63 Cal.4th 261 (2016), Cook was entitled to make a record before the superior court of mitigating evidence tied to his youth. The Supreme Court reversed, holding that Cal. Penal Code 1203.01 provides an adequate remedy at law to preserve evidence of youth-related factors. View "In re Cook" on Justia Law

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In this criminal case, the Supreme Court held that, when a defendant posts bail, the trial court has authority to impose reasonable conditions related to public safety but that the question had become moot as to the Defendant in the instant case. Defendant was arrested and charged with two felony counts. Defendant posted bail and was released from custody. At arraignment, the court imposed as an additional condition of release that Defendant waive her Fourth Amendment right to be free of warrantless or unreasonable searches. The District Attorney petitioned for review, asking whether trial courts possess inherent authority to impose reasonable bail conditions related to public safety on felony defendants who are released on bail. The Supreme Court answered in the affirmative, holding (1) trial courts have authority to impose release conditions on persons who post bail; but (2) the question was moot as to Defendant, and therefore, this Court need not decide whether the specific condition was valid. View "In re Webb" on Justia Law