Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of California
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The Supreme Court overturned the death penalty for Scott Peterson, who, in 2002, was convicted of killing his wife, Laci Peterson, and the couple's unborn son, holding that the trial court made a series of clear and significant errors in jury selection that undermined Peterson's right to an impartial jury at the penalty phase.The Supreme Court affirmed the judgment as to guilt but reversed the judgment as to the sentence of death, holding (1) Defendant received a fair trial as to guilt; (2) the trial court erred by dismissing many prospective jurors because of written questionnaire responses expressing opposition to the death penalty, even though the jurors gave no indication that their views would prevent them from following the law; and (3) under United States Supreme Court precedent, these errors required reversal of the death sentence in this case. View "People v. Peterson" on Justia Law

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The Supreme Court affirmed the judgments of the of the trial court convicting Defendants of first degree murder and other crimes and sentencing both defendants to death, holding that no prejudice resulted from any error of the trial court.Separate juries convicted Daniel Silveria and John Travis of first degree murder, second degree robbery, and second degree burglary. After retrials, a single penalty jury returned death verdicts. The Supreme Court affirmed, holding (1) during the guilt phase, the trial court did not err in denying Travis's motion to suppress or in instructing the jury on first degree murder; and (2) during the joint penalty retrial, there was no abuse of discretion in denying Defendants' severance motions, the trial court did not wrongfully excuse for cause prospective jurors, the trial court did not err in admitting portions of Silveria's first penalty phase testimony, any error in placing conditions on proffered testimony by Travis's trial counsel was harmless, and any other assumed or actual error was not prejudicial. View "People v. Silveria" on Justia Law

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Here, the Supreme Court addressed the propriety of a criminal defense subpoena served on Facebook seeking restricted posts and private messages of one of its users, who was a victim and critical witness in the underlying attempted murder prosecution, holding that the trial court erred in denying Facebook's motion to quash the subpoena.Lance Touchstone, the defendant in the prosecution below, argued that the trial court properly denied Facebook's motion to quash. The Supreme Court disagreed, holding that the trial court erred by conducting an incomplete assessment of the relevant factors and interests when it found that Defendant established good cause to acquire the communications at issue from Facebook. After highlighting seven factors a trial court should explicitly consider and balance in ruling on a motion to quash a subpoena directed to a third party the Supreme Court vacated the trial court's order denying the motion to quash and remanded the matter to the trial court to conduct further proceedings consistent with the guidelines set forth in this opinion. View "Facebook, Inc. v. Superior Court" on Justia Law

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The Supreme Court affirmed Defendant's convictions for four counts of first degree murder and other crimes and sentence of death, holding that, considering any actual or assumed errors altogether, their cumulative effect did not warrant reversal of Defendant's convictions or sentence.Specifically, the Supreme Court held (1) assuming that the trial court erred by using an unsworn, uncertified interpreter during the preliminary hearing and to interpret a victim's outburst, there was no prejudice; (2) sufficient evidence supported the theory of felony murder for two murders, and even assuming there was no sufficient evidence, the first degree murder verdicts would still be upheld; (3) there was assumed or found error during trial regarding difficulties that made it difficult to hearing the court proceedings, the accuracy of interpreters, and other issues, but there was no prejudice; and (4) none of the assumed or actual errors, considered either individually or collectively, warranted reversal of Defendant's convictions or sentence. View "People v. Suarez" on Justia Law

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The Supreme Court affirmed Defendant's conviction of three counts of first degree murder and one count of second degree murder with a multiple murder special circumstance and various gun use enhancements, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion for a venue change; (2) the trial court did not err in denying Defendant's motion to suppress items discovered during a warrantless search of his vehicle; (3) Defendant's decision not to testify was knowing, intelligent, and voluntary; (4) the trial court did not improperly exclude a defense expert; (5) the trial court did not err by denying Defendant's pretrial motion to exclude evidence of his gang membership; (6) there was no instructional error; (7) the prosecutor did not commit misconduct during penalty phase argument; and (8) Defendant's challenges to the victim impact testimony were unavailing. View "People v. Duong" on Justia Law

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The Supreme Court affirmed Defendant's conviction of four counts of first degree murder and other crimes, holding that there was no error or abuse of discretion during the guilt phase or penalty phase of trial.Specifically, the Supreme Court held (1) the evidence was sufficient to show that Defendant committed the murders with premeditation and deliberation; (2) the trial court did not err in admitting testimony of the People's crime scene reconstruction expert; (3) the trial court did not abuse its discretion by admitting certain crime scene and autopsy photographs of the victims; and (4) during the penalty phase, the trial court did not err by admitting victim impact testimony or in instructing the jury. View "People v. Morales" on Justia Law

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The Supreme Court reversed the judgment of the trial court convicting Defendant of first degree murder, attempted deliberate and premeditated murder, and other crimes, holding that Defendant's statements were improperly admitted in violation of Miranda v. Arizona, 384 U.S. 436 (1966) and Edwards v. Arizona, 451 U.S. 477 (1981), and the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued that his statements to police were taken in violation of his Fifth Amendment right to counsel. Specifically, Defendant argued that his unequivocal request for counsel was not honored. The Supreme Court agreed, holding (1) under Edwards, the officers were required to stop the interrogation once Defendant unequivocally requested counsel, but because the officers did not do so Defendant's statements were inadmissible as substantive evidence at trial; and (2) the erroneous admission of Defendant's statements was not harmless beyond a reasonable doubt as to any of the jury's findings. View "People v. Henderson" on Justia Law

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The Supreme Court reversed the judgment of the court of appeal affirming Defendant's sentence in connection with his convictions for several offenses, including five counts of second degree robbery, holding that the trial court erred in imposing five twenty-five-year-to-life enhancements in connection with counts as to which the enhancements had not been alleged.As to each of the five counts of second degree robbery, the information alleged personal firearm use enhancements. After the close of the evidence, however, the trial court instructed the jury on a set of more serious firearm enhancements based on the theory that Defendant was vicariously responsible for a coparticipant's harmful discharge of a firearm. None of the vicarious firearm discharge enhancements had been alleged in connection with the robbery counts. The jury returned true findings. The trial court enhanced Defendant's sentence for the robberies by five consecutive additional terms of twenty-five years to life. The court of appeal affirmed. The Supreme Court reversed, holding that the trial court committed a pleading error because Defendant did not receive adequate notice that the prosecution was seeking to impose additional punishment on the robbery counts, and the error was not harmless. View "People v. Anderson" on Justia Law

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The Supreme Court answered a question posed by the Court of Appeals for the Ninth Circuit regarding the time gap between the denial of a petition for a writ of habeas corpus in a lower California court and the filing of a new petition in a higher California court raising the same claims for purposes of determining whether a claim was timely presented.The Court summarized the procedures relevant to gap delay and then answered that, during the process, the delay between the filing of a habeas corpus petition challenging a state court judgment in a high court after the lower court denied relief is relevant to the overall question of timeliness of the claims presented in the petition, but no specific time limits exist. Specifically, delay of up to 120 days would not be considered substantial delay and would not alone make the claim untimely if the petition had otherwise presented the claim without substantial delay. Gap delay of more than 120 days is not automatically considered substantial delay but is a relevant factor in a court's analysis under In re Robbins, 18 Cal.4th, 770 (1998). View "Robinson v. Lewis" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first degree murder and other crimes and sentence of death, holding that there was no prejudicial error in the trial proceedings.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized during a warrantless probation search of his home; (2) the trial court did not abuse its discretion in denying Defendant's motion to sever the capital charges from his remaining charges; (3) the evidence was sufficient to support the convictions; (4) Defendant's challenges to the trial court's guilt phase instructions lacked merit; (5) a failure of consular notification under the Vienna Convention occurred in this case, but no prejudice resulted from it; (6) the trial court did not err in denying Defendant's motion to modify the verdict; and (7) Defendant's challenges to California's death penalty law were unavailing. View "People v. Vargas" on Justia Law