Justia Criminal Law Opinion Summaries

The case involves a defendant who was facing felony charges in Orange County for assault with two serious felony priors. Due to continuances related to the COVID-19 pandemic and the defendant’s later failure to appear, no preliminary examination was held, and the felony complaint remained pending. While this complaint was outstanding, the defendant was sentenced in Riverside County to a six-year state prison term on unrelated charges. On the same day as sentencing, his counsel served the Orange County District Attorney with a demand under California Penal Code section 1381 to bring the pending felony charge to trial within 90 days. At that time, the defendant was still in county jail awaiting transfer to state prison. The District Attorney responded that the demand was invalid because it was made before the defendant had entered prison custody.A magistrate subsequently dismissed the felony complaint for failure to comply with the section 1381 demand. The Orange County District Attorney appealed to the California Court of Appeal, Fourth Appellate District, Division Three. The Court of Appeal affirmed the dismissal, holding that a section 1381 demand could be made after a defendant is sentenced to state prison, even if the defendant had not yet physically entered prison custody.The Supreme Court of California reviewed the case to resolve two legal questions: whether the Court of Appeal had appellate jurisdiction over the magistrate’s dismissal of a felony complaint, and whether a section 1381 demand is valid if made before a defendant’s delivery to prison custody. The Supreme Court held first that a magistrate’s dismissal of a felony complaint is appealable to the Court of Appeal as a dismissal in a “felony case.” Second, it held that a defendant has not “entered upon a term of imprisonment in a state prison” for purposes of section 1381 until actual delivery into prison custody. Therefore, a section 1381 demand made prior to prison entry is premature. The Supreme Court reversed the Court of Appeal’s judgment and ordered reinstatement of the felony complaint. View "P. v. Hyatt" on Justia Law

The defendant was tried for attempted murder and assault with a deadly weapon. During jury selection, the prosecutor used a peremptory challenge to excuse a prospective juror identified as Latino, prompting the defense to object under California Code of Civil Procedure section 231.7, which prohibits discrimination based on race or other protected status. The prosecutor gave multiple reasons for the strike, including that the juror was less attentive and engaged than others. The trial court confirmed the prosecutor’s observations and overruled the defense’s objection, without requiring a further explanation of why the juror’s behavior mattered to the case.The Court of Appeal, Second Appellate District, affirmed the trial court’s decision. The majority held that the prosecutor’s and court’s observations about the juror’s attentiveness were sufficient to overcome the statutory presumption that behavior-based reasons for a peremptory challenge are invalid, and independently sufficient to justify the strike. A dissenting justice argued that the prosecutor failed to explain why the juror’s behavior was relevant to the case, and thus the presumption of invalidity was not overcome.The Supreme Court of California reviewed the case. It clarified that section 231.7 requires both confirmation of the observed behavior and an explanation of its relevance to rebut the presumption of invalidity for behavior-based reasons. The court held that failing to rebut this presumption means the reason cannot justify the strike, but does not necessarily establish that the strike was unlawful; courts must still consider all reasons and circumstances to determine if there is a substantial likelihood that an objective observer would view race or other protected status as a factor. The Court reversed the judgment of the Court of Appeal and remanded for further proceedings. View "People v. Sanmiguel" on Justia Law

The defendant was charged with several robberies and related offenses, and the prosecution alleged that he had previously served a prison term under former Penal Code section 667.5(b). The defendant pleaded no contest, admitting the prior prison term allegation. At sentencing in 2017, the Santa Clara County Superior Court found the prior prison term allegation true but exercised its discretion to strike the punishment for the enhancement in the interest of justice, without striking the allegation itself. The abstract of judgment reflected the true finding. After the Legislature enacted Penal Code section 1172.75, which retroactively invalidated most prior prison term enhancements imposed before January 1, 2020, the defendant petitioned for resentencing.The Santa Clara County Superior Court denied the petition, concluding that section 1172.75 applied only to persons for whom a section 667.5(b) enhancement was imposed and executed, not to those for whom the enhancement was stayed, stricken, or dismissed. On appeal, the Sixth District Court of Appeal reversed the superior court’s decision, holding that section 1172.75 applies whenever a prior prison term enhancement was imposed, regardless of whether the punishment was executed, stayed, or struck. A dissenting opinion argued that a punishment-stricken enhancement is not “imposed” under section 1172.75(a) because it does not lengthen a defendant’s sentence.The Supreme Court of California granted review and addressed whether section 1172.75(a) invalidates a prior prison term enhancement for which punishment was stricken. The Court held that an enhancement is “imposed” when it is made part of a legally effective sentencing order, even if the punishment is stricken. Consequently, the defendant is entitled to resentencing under section 1172.75. The Supreme Court of California affirmed the judgment of the Court of Appeal. View "People v. Espino" on Justia Law

A defendant faced five separate criminal cases, each involving different charges of burglary, theft, and related offenses. The defendant was arrested and held in custody for varying periods in each case, sometimes being out on bail or released on his own recognizance in one or more cases while remaining in custody for others. Ultimately, all five cases were resolved together through a plea agreement, and the defendant was sentenced at a single hearing, receiving concurrent sentences in each matter.After sentencing, the defendant requested that the trial court award presentence custody credits in each case for all time served in custody on any of the cases, not just the time specifically attributable to each individual case. The Monterey County Superior Court declined, awarding presentence credits in each case only for custody time attributable to that particular case. The defendant appealed, and the California Court of Appeal, Sixth Appellate District, reversed. The appellate court concluded that, because all five cases were resolved and sentenced at one hearing, the defendant should receive custody credits in each case for all time spent in custody on any of the cases, except for time that preceded the arrest in a specific case.The Supreme Court of California reviewed the case. It held that, under Penal Code section 2900.5, subdivision (b), the term “proceedings” refers to a single criminal case, not all cases resolved at one sentencing hearing. Therefore, custody credits must be awarded in each case only for the time the defendant was actually in custody in that case, not time served in other cases, even if the cases were resolved and sentenced together. The Supreme Court of California reversed the judgment of the Court of Appeal. View "P. v. Cofer" on Justia Law

In this case, the defendant was charged with multiple violent crimes arising from two separate incidents in Los Angeles County in 1991. The first incident involved the fatal shooting of Benson Jones, the attempted murder of Benjamin Jones, and an assault with a firearm on Linda Jones. The second incident involved the murder of Jesus Sanchez and the attempted murder of Ernest Johnson. The prosecution’s theory focused on gang affiliations as the motive for the shootings, supported by eyewitness identifications, gang expert testimony, and forensic evidence. Bankston was also charged with being a felon in possession of a firearm.At the initial trial in the Los Angeles County Superior Court, the jury convicted Bankston of murdering Benson Jones, the attempted murder of Benjamin Jones, and firearm possession, but could not reach verdicts on the charges related to Sanchez, Johnson, and Linda Jones, resulting in a mistrial for those counts. During the retrial, Bankston was acquitted of Johnson’s attempted murder but convicted of Sanchez’s murder and assaulting Linda Jones with a firearm. The jury found true the multiple-murder special-circumstance allegation, and after the penalty phase, returned a death verdict.On automatic appeal to the Supreme Court of California, the court reviewed numerous claims, including trial management, evidentiary rulings, jury selection, and self-representation. The court held that the guilt and special circumstance phases were free from prejudicial error, affirming the convictions and upholding most trial procedures. However, both parties agreed that the penalty phase closing argument by the prosecutor involved racially discriminatory language in violation of the California Racial Justice Act of 2020, Penal Code section 745. The Supreme Court held that this error was not harmless beyond a reasonable doubt under the Act and reversed the death sentence, remanding for further proceedings on penalty. The court affirmed the judgment in all other respects. View "P. v. Bankston" on Justia Law

The defendant was convicted by a jury of the first degree murders of his two young children, with special findings that the murders involved torture and multiple victims. The evidence at trial showed a prolonged pattern of severe physical abuse and neglect inflicted by the defendant on the children, including daily beatings, deliberate starvation, and ultimately fatal injuries. The abuse was corroborated by testimony from family members, expert medical evidence, and the circumstances of the children’s deaths. After a penalty phase hearing, the jury returned a death verdict, and the trial court imposed a sentence of death, staying punishment on the other counts.Prior to review by the Supreme Court of California, the case was tried in the Los Angeles County Superior Court. The jury found the defendant guilty of several crimes including first degree murder, child abuse homicide, child endangerment, and corporal injury to a child, and found true multiple special circumstance allegations. The defendant’s appeals centered on the sufficiency of the evidence for first degree murder and special circumstance findings, the admission of certain expert testimony, the adequacy of jury instructions, alleged prosecutorial misconduct, and claims under the California Racial Justice Act.The Supreme Court of California reviewed each of the defendant’s claims in detail. It held that the evidence was sufficient to support the first degree murder convictions and special circumstance findings under both theories of torture-murder and premeditated, deliberate murder. The court found any error in the admission of certain expert testimony or in the instructions to be harmless beyond a reasonable doubt. The court also assumed, without deciding, that certain prosecutorial comments may have violated the Racial Justice Act, but concluded that any such errors were harmless. The Supreme Court affirmed the judgment in its entirety, upholding the convictions and the death sentence. View "P. v. Barrera" on Justia Law

Two defendants were jointly tried before separate juries for a series of violent crimes committed in Sacramento and Pomona in 1995. These included the robbery and murders of members of the Le family, the attempted murder of Quyen Luu, a burglary, an attempted robbery, and the murder of Miguel Vargas Avina with the attempted murder of Rodolfo Huerta. Both were also implicated in an uncharged murder (Bun) and alleged to have acted for the benefit of a criminal street gang. The prosecution relied on eyewitnesses, accomplice testimony, forensic evidence, and admissions from the defendants. The defense challenged witness identifications, introduced expert testimony on eyewitness reliability, and presented extensive mitigating evidence about the defendants' traumatic backgrounds.The Los Angeles County Superior Court allowed the charges from different counties to be joined under Penal Code section 790(b), leading to a joint capital trial. Both men were convicted of all charges and special circumstance allegations, and each jury returned a verdict of death. The trial court entered death judgments for both, finding true additional special circumstances.The Supreme Court of California reviewed the case automatically. For one defendant, the court affirmed the judgment except for vacating the gang enhancement finding, due to legislative changes that barred the use of the charged offense to establish a pattern of criminal gang activity. For the other defendant, the court reversed the judgment in its entirety. It held that defense counsel's closing argument conceding guilt on the defendant’s behalf, over his express objection, violated the defendant’s constitutional right to decide the objective of his defense, as articulated in McCoy v. Louisiana (2018). This error was deemed structural, requiring automatic reversal of all convictions and enhancements for that defendant. The case was remanded for further proceedings as to both defendants as specified. View "P. v. Chhuon" on Justia Law

An 11-year-old girl disappeared while visiting her parents in Oakland in July 1999 and was found dead the next day. Investigators discovered she had been raped and strangled. Within weeks, the defendant, a nearby resident, confessed to the crime after matching DNA evidence was found. In his confession, the defendant described luring the victim into his apartment, assaulting and killing her, and disposing of her body. The prosecution further corroborated the confession with testimony from a neighbor and other witnesses, and confirmed the DNA link. The defense did not present evidence at the guilt phase but presented mitigating evidence at the penalty phase, including character witnesses and information about the defendant’s background.The Superior Court of Alameda County conducted the trial. Before trial, the court denied the defendant’s motion to suppress evidence related to the police’s collection of his blood sample and confession, finding the encounter to be consensual and not a detention under the Fourth Amendment. The defendant was convicted of first-degree murder with special circumstances and sentenced to death. His post-trial motions, including those to discharge a juror and for a mistrial based on alleged juror bias, were denied.The Supreme Court of California reviewed the case on automatic appeal. The court held that the defendant was not unlawfully detained before consenting to the blood draw, that evidence obtained was admissible, and that no juror bias or improper admission of evidence rose to the level of reversible error. The court also addressed and rejected challenges to victim impact evidence, admission of unadjudicated criminal acts, and claims of constitutional violations in the penalty phase, including a claim under California’s Racial Justice Act regarding the prosecutor’s language. The judgment, including the death sentence, was affirmed. View "P. v. Demolle" on Justia Law

The defendant was observed by a police officer driving recklessly in Ukiah, California, nearly hitting pedestrians and engaging in dangerous maneuvers while under the influence of alcohol. After a high-speed pursuit, she was arrested and charged with multiple felonies, including assault and reckless evasion, as well as misdemeanors related to driving under the influence. She had a prior robbery conviction, making her subject to enhanced sentencing under the Three Strikes law. Through a negotiated plea, she pled no contest to one felony and one misdemeanor, admitted her prior strike, and agreed to a stipulated upper-term sentence of three years (doubled to six years), with the remaining charges dismissed.After her conviction, but while her appeal was pending, California amended Penal Code section 1170 to require that aggravating facts justifying an upper-term sentence be either stipulated to by the defendant or found true beyond a reasonable doubt. The defendant argued on appeal that this amendment should apply retroactively to her nonfinal judgment, requiring reduction of her sentence since the new requirements were not met. The California Court of Appeal rejected her claim, holding that the amendment did not affect stipulated sentences from plea bargains, since no judicial discretion was exercised in those cases.The Supreme Court of California reversed the Court of Appeal. The Supreme Court held that defendants with nonfinal judgments who agreed to an upper-term sentence as part of a plea bargain are entitled to seek the retroactive benefit of amended section 1170(b). However, a stipulated upper-term sentence remains valid only if the defendant knowingly and voluntarily waives the new requirements. On remand, the defendant may either waive these requirements and reaffirm the plea (reinstating the original sentence), or invoke them, in which case the parties may renegotiate the plea or the defendant may withdraw her plea and proceed to trial. The Supreme Court of California thus vacated the lower court’s judgment and set forth these remedies. View "P. v. Mitchell" on Justia Law

Two men attacked a couple as they entered their condominium, robbing them and sexually assaulting the woman. During the incident, the male victim was fatally shot. Decades later, DNA evidence linked one of the assailants, Morris, to the crime. In 2013, Morris was convicted by a jury of first degree murder, with special circumstances for rape, robbery, and murder for financial gain. The jury found that Morris acted with intent to kill, and the trial court sentenced him to life without parole. The conviction was affirmed on appeal.After changes to California’s felony-murder rule under Senate Bill 1437, Morris filed a petition for resentencing under Penal Code section 1172.6, arguing he was ineligible for murder liability as a nonkiller under the amended law. The Superior Court summarily denied the petition at the prima facie stage, reasoning that the jury’s findings established Morris’s intent to kill, making him ineligible for relief. The California Court of Appeal, in a split decision, affirmed the denial. The majority held that, under the amended law, it was sufficient that Morris acted with intent to kill and aided the underlying felony, even if he was not the actual killer. The dissenting judge argued that the law requires a nonkiller to have aided the actual killer in the lethal act itself, not just in the underlying felony.The Supreme Court of California reviewed the case to resolve a conflict among appellate courts regarding the actus reus requirement for nonkiller aiders and abettors under section 189, subdivision (e)(2). The Supreme Court held that, for a nonkiller to be liable for felony murder under this provision, the prosecution must prove that the nonkiller, with intent to kill, aided or abetted the actual killer in the commission of the lethal act itself—not merely in the commission of the underlying felony. The Court reversed the Court of Appeal and remanded for further proceedings. View "P. v. Morris" on Justia Law