Articles Posted in Supreme Court of California

by
The Supreme Court vacated as unauthorized the death sentence imposed upon Defendant in connection with his conviction for conspiracy to commit murder and vacated the jury's lying in wait special-circumstance true finding and affirmed, as modified, the judgment in all other respects, holding that no substantial evidence supported the lying in wait special-circumstance finding and that the trial court erred in imposing the death penalty for Defendant's conviction of conspiracy to commit murder. Defendant was convicted of conspiracy to commit murder and first degree murder. The jury found true lying in wait and torture-murder special-circumstance allegations. The jury returned a death verdict. In addition to the errors found on appeal, the Supreme Court assumed error in (1) the trial court's preclusion of impeachment of witnesses with their felony convictions or pending charges; (2) the admission of certain evidence; (3) certain aspects of the prosecutor's guilt phase closing argument; and (4) the trial court's failure to instruct on its own motion that a coperetrator's guilty plea could only be used to assess her credibility. The Court held that the errors and assumed errors, whether considered individually or cumulatively, did not require reversal of Defendant's murder or conspiracy convictions but that the death sentence and lying in wait special-circumstance true finding were improperly imposed. View "People v. Dalton" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder in the course of a robbery and related crimes and sentencing Defendant to death, holding that any assumed errors were harmless. Specifically, the Court held (1) even if it was error for the trial court to admit testimony arguably conveying the substance of a hearsay declarant's out-of-course identification, the error was harmless; (2) assuming there was error in Defendant's absence during one day of the penalty phase trial, the error was harmless; (3) any other possible errors contemplated by this Court were harmless; and (4) Defendant's challenges to the constitutionality of California's capital sentencing scheme were unavailing. View "People v. Bell" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court denying Defendant's automatic motion to modify the jury's verdict convicting Defendant of two counts of first degree murder and sentencing him to death, holding that any errors were minimal and did not warrant reversal. Specifically, the Court held (1) even assuming that the trial court erred in excluding Defendant's proffered statements to impeach a witness's credibility, the error was harmless and not so severe as to violate Defendant's right under the United States Constitution to confront the witnesses against him; (2) any error in the trial court's ruling permitting certain cross-examination when Defendant testified was harmless; (3) any impropriety on the part of the prosecutor during his guilt phase closing argument to the jury was not prejudicial; and (4) any error in the admission of evidence that Defendant. committed a crime involving force or violence against his stepdaughter was harmless. View "People v. Sanchez" on Justia Law

by
In this case concerning the proper interpretation of Proposition 47, the ballot initiative that reduced certain felony offenses to misdemeanors, the Supreme Court held that defendants who had not yet been sentenced as of Proposition 47's effective date were entitled to initial sentencing under Proposition 47's amended penalty provisions without regard to the resentencing procedures applicable to those who were already serving their sentences. Proposition 47 took effect after Defendant committed his offense but before he was charged, tried, or sentenced. On appeal, Defendant argued that his felony Vehicle Code section 10851 conviction must be reduced to a misdemeanor under Cal. Penal Code 490.2(a), the new Penal Code provision added by Proposition 47. The court of appeal affirmed Defendant's felony conviction and sentence. The Supreme Court granted Defendant's petition for review and held (1) the court of appeal erred in holding that Proposition 47 is inapplicable to violations of Cal. Veh. Code 10581; but (2) the court of appeal correctly affirmed Defendant's conviction on that charge because the evidence at trial was sufficient to sustain a felony conviction under Cal. Veh. Code 10851. View "People v. Lara" on Justia Law

by
The Supreme Court held that the rule set forth in Stone v. Superior Court, 31 Cal.3d 503, that a court must accept a partial verdict of acquittal as to a charged greater offense when a jury has expressly indicated that it has acquitted on that offense but has deadlocked on uncharged lesser included offenses, has not been abrogated by the United States Supreme Court's decision in Blueford v. Arkansas, 566 U.S. 599, which concluded that federal double jeopardy principles do not require a court to accept a partial verdict. Defendant was charged with murder. At the close of evidence, the court instructed the jury on first degree murder and uncharged lesser included offenses. The jury foreperson reported that jurors were split between second degree murder, voluntary manslaughter, and a not guilty verdict. The court concluded that the jury was deadlocked and declared a mistrial. Defendant moved to dismiss the first degree murder allegation on double jeopardy grounds, arguing that the court's failure to receive a partial acquittal verdict on first degree murder barred a retrial on that charge. The court dismissed the first degree murder charge. The court of appeal affirmed. The Supreme Court affirmed, holding (1) Stone survives Blueford under California law; and (2) the trial court improperly declared a mistrial as to first degree murder. View "People v. Aranda" on Justia Law

by
The Supreme Court reversed the judgment of the court of appeals ruling that Defendant did not have a right to appointed counsel to respond to the prosecution's appeal of the order of the trial court granting Defendant's motion to suppress the prosecution's evidence against her, holding that Defendant had a right to appointed counsel in the present appeal. Defendant was charged by misdemeanor complaint with driving under the influence of alcohol and driving while having a blood-alcohol content of 0.08 percent or higher. With the assistance of court-appointed counsel, Defendant filed a successful motion to suppress evidence collected during a warrantless traffic stop. The prosecution's appealed the suppression order. Defendant asked the appellate division to appoint new counsel to represent her, but the appellate division refused. Defendant then filed a petition for a writ of mandate, which the court of appeal denied. Without addressing whether the public defender remained appointed to represent Defendant, the court concluded that Defendant did not have the right to appointment of counsel on appeal. The Supreme Court reversed and remanded the case, holding that Defendant was entitled to the assistance of counsel to respond to the prosecution's appeal. View "Gardner v. Appellate Division of Superior Court" on Justia Law

by
The Supreme Court reversed the judgment of the Court of Appeal upholding the juvenile court's finding that H.W. possessed an "other instrument or tool with intent feloniously to break or enter" within the meaning of Cal. Penal Code 466, holding that the pair of pliers that H.W. was in possession of when he was apprehended were not an "other instrument or tool" within the meaning of section 466. H.W., a minor, entered a Sears department store with the intent to steal a pair of jeans. When H.W. was apprehended and searched, he had in possession the jeans and a pair of pliers approximately ten inches in length, with a half-inch blade. The juvenile court sustained the burglary tool possession allegation brought against H.W. The Court of Appeal upheld the juvenile court's determination. The Supreme Court reversed, holding (1) the record did not support the conclusion that H.W. intended to use the pliers to do anything other than remove the anti-theft tag from the jeans; and (2) therefore, there was insufficient evidence to support the section 466 allegation. View "In re H.W." on Justia Law

by
The Supreme Court modified the judgment of the trial court convicting Defendant of two counts of first degree murder and related crimes, sentencing Defendant to death, and imposing a four-year determinate term based on the age of the victims by striking the four-year determinate term but otherwise affirmed, holding that there was error in the elderly victim enhancements but no other prejudicial error. Specifically, the Court held (1) the evidence was sufficient to support Defendant's convictions; (2) there was no reversible error in the guilt-phase instructions given to the jury; (3) any statutory error in allowing an investigator to read aloud from his report of an interview with a driver of Defendant was harmless at the guilt phase, and the admission of the driver's statement during the guilt phase did not prejudice the jury's penalty determination; (4) no other error occurred during the penalty phase of trial; (5) murder is not one of the crimes eligible for an elderly victim enhancement; (6) any error on the part of the trial court in initially imposing a $10,000 restitution fine was harmless; and (7) none of Defendant's challenges to California's death penalty scheme had merit. View "People v. Potts" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court convicting codefendants Oswaldo Amezcua and Joseph Conrad Flores of four counts of first degree murder and sentencing each defendant to death for the murder convictions, holding that any errors in the proceedings below were not sufficiently prejudicial to require reversal of the judgment. A jury convicted Defendants of murder, finding true multiple-murder and drive-by-murder special circumstance allegations, as well as multiple counts of attempted willful, deliberate premeditated murder, false imprisonment, and other non-capital offenses. The trial court sentenced Defendants to death for the murder convictions and imposed determinate and indeterminate sentences for the noncapital convictions. The Supreme Court affirmed, holding (1) any error in the prosecutor’s guilt phase closing was harmless; (2) any error in a medical examiner’s testimony relating to autospy results derived from a different pathologist’s report was harmless; and (3) whether considered individually or cumulatively, the errors did not warrant reversal. View "People v. Amezcua" on Justia Law

by
The Supreme Court affirmed Defendant’s convictions of kidnapping, robbing, raping, torturing, and murder but reversed his death sentence, holding that multiple prospective jurors were improperly excused for cause. Defendant in this case was a black man sentenced to death for murdering a white woman. The prosecutor struck four black male jurors, leaving no black man on the jury. The Supreme Court held (1) under the standards of Witherspoon v. Illinois, 391 U.S. 510 (1968) and Wainwright v. Witt, 469 U.S. 412 (1985), the trial court erred by excusing jury candidates on the ground that they could not fairly and impartially consider whether death was the appropriate punishment; but (2) the trial court properly rejected Defendant’s Armstrong’s Batson claims. View "People v. Armstrong" on Justia Law