Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of California
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of two murders and finding true the special circumstances that one murder occurred during the commission of a robbery, that the other murder involved the killing of a witness and that Defendant had been convicted of multiple murders, and sentencing Defendant to death, holding that no errors required reversal of the judgment.Specifically, the Supreme Court held (1) substantial evidence supported the excusal of juror J.W. for cause; (2) assuming that the trial court erred when it allowed the prosecution to introduce "other acts" evidence at the guilt phase of trial, any error was harmless; (3) assuming that the trial court erred in introducing evidence at the penalty phase regarding Defendant's participation in mutual combat was harmless; and (4) there was no cumulative error requiring reversal of the judgment below. View "People v. Pineda" on Justia Law

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The Supreme Court affirmed the order of the trial court entering judgment upon the jury's verdict that Defendant committed first degree murder, robbery, burglary, and firearm possession by a felon and sentencing him to death, holding that while the court committed statutory error, there were no additional errors or rulings that caused Defendant undue prejudice.On appeal, Defendant asserted that several errors in the guilt and penalty phases occurred, resulting in cumulative prejudice warranting reversal of his convictions. The Supreme Court disagreed and affirmed, holding (1) the trial court erred by allowing Defendant to be absent from trial without a written waiver, but the error was not prejudicial; and (2) Defendant failed to identify any other reversible error on appeal. View "People v. Poore" on Justia Law

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The Supreme Court held that Proposition 57, a measure that amended the law governing the punishment of juvenile offenses in adult criminal court by requiring hearings to determine whether the offenses should instead by hearing in juvenile court, applied during resentencing where the criminal court sentence imposed on Defendant, a juvenile offender, was issued before the initiative's passage but was since vacated.Defendant was originally sentenced before Proposition 57 was enacted, but his sentence was later vacated on habeas corpus, and the case was returned to the trial court for imposition of a new sentence. At issue was whether Proposition 57 applied to Defendant's resentencing. The Supreme Court affirmed the judgment of the court of appeal, holding that Proposition 57 applied to Defendant's resentencing because the judgment in his case became nonfinal when his sentence was vacated on habeas corpus. View "People v. Padilla" on Justia Law

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The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of first degree murder and the jury's findings of the lying-in-wait special circumstance and the special circumstance allegations that Defendant intentionally killed the victim for financial gain while engaged in the commission or attempted commission of rape, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion by failing to initiate competency proceedings; (2) there was no error in the trial court's evidentiary rulings; (3) sufficient evidence supported the jury's true findings of the special circumstances, and the special circumstances, as applied, are not unconstitutional; (4) there was no instructional error; (5) Defendant's claims of prosecutorial misconduct were without merit; and (6) Defendant's remaining claims of error were unavailing. View "People v. Parker" on Justia Law

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In this case regarding conservatorships authorized by the Lanterman-Petris-Short (LPS) Act for persons gravely disabled by a mental disorder or chronic alcoholism the Supreme Court held that, for purposes of the right against compelled testimony, those facing an LPS conservatorship due to an inability to care for themselves are sufficiently similar to persons found not guilty of crimes by reason of insanity (NGIs) that equal protection principles require the government to justify its disparate treatment of these proposed conservatees.The Contra Costa County Public Guardian petitioned for an LPS conservatorship on the ground that Appellant was gravely disabled. Appellant requested a jury trial and objected to giving compelled testimony.The court overruled the petition. Appellant was called to testify during trial. The jury found Appellant gravely disabled, and the court appointed the Public Guardian as conservator. On appeal, Appellant challenged the order compelling his testimony. The court of appeals held that LPS conservatives and similarly situated with NGIs for the purposes of NGI extension proceedings but that the error in compelling Appellant's testimony was harmless. The Supreme Court affirmed, holding (1) traditional LPS conservatees are similarly situated with NGI’s for purposes of the right against compelled testimony; but (2) a remand was not appropriate in this case. View "In re Conservatorship of Eric B." on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of the first-degree murder of his father and the second-degree murders of his stepmother and stepsister and sentencing him to death, holding that Defendant's second-degree murder convictions must be reversed.A federal court vacated Defendant's initial conviction and sentence. After a retrial, Defendant was convicted of first- and second-degree murder, and the jury found true a multiple-murder special-circumstance finding and various firearm- and weapon-use findings. Defendant was sentenced to death. At trial, Defendant's counsel conceded his responsibility for the deaths of all three victims, but Defendant was willing to accept responsibility only for the killing of his father and objected to admitting responsibility for the other two deaths. The Supreme Court held (1) defense counsel violated Defendant's Sixth Amendment rights to choose the fundamental objectives of his defense; and (2) while the error did not affect Defendant's first-degree murder conviction or the associated firearm-use finding, the error requires reversal of the remainder of the judgment and the judgment of death. View "People v. Bloom" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and death sentence, holding that there was no prejudicial error.After a jury trial, Defendant was convicted of the first-degree murder of a nine-year-old girl, with special circumstances for committing the murder while engaged in kidnapping, lewd act on a child under fourteen, and oral copulation. A death sentence was imposed. The Supreme Court affirmed, holding (1) there was no prejudicial prefiling delay; (2) Defendant was not prejudiced by the trial court's order that he wear leg chains during trial; (3) the trial court did not err in excluding third party culpability evidence; (4) the trial court did not improperly allow certain victim impact testimony; and (5) Defendant's challenges to the constitutionality of the death penalty were unavailing. View "People v. Bracamontes" on Justia Law

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The Supreme Court reversed the judgment of the court of appeal affirming Defendant's life sentence for his conviction of conspiracy to commit home invasion robbery under Cal. Penal Code 186.22(b)(4), holding that the superior court erred in sentencing Defendant to an indeterminate life term under that provision.Section 186.22(b)(4) prescribes indeterminate life terms for specified felonies, including home invasion robbery. At issue was whether Defendant was properly sentenced to an indeterminate life term even though he was convicted of the crime of conspiracy and not yet completed home invasion robbery. The Supreme Court answered the question in the negative, holding that section 186.22(b)(4) does not apply to conspiracy convictions. View "People v. Lopez" on Justia Law

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The Supreme Court affirmed the judgment of the the trial court convicting defendants Karl Holmes, Herbert McClain, and Lorenzo Newborn of three counts of murder, five counts of attempted murder, and one count of conspiracy to commit murder and sentencing each defendant to death, holding that no prejudicial error occurred at either stage of the proceedings.After the jury failed to reach a penalty verdict, a new penalty phase was held, and death verdicts were returned against all defendants. On appeal, Defendants asserted several allegations of error argued that the cumulative prejudicial errors in both the guilt and penalty phases of the trials required the reversal of their convictions and sentences. The Supreme Court affirmed, holding (1) in the few instances in which this Court found or assumed error, no prejudice resulted; and (2) whether the claims are considered separately or cumulatively, no prejudicial error occurred. View "People v. Holmes" on Justia Law

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The Supreme Court reversed the judgment of the court of appeal affirming the decision of the trial court to sentence Defendant to three years for robbery with a twenty-five-years-to-life enhancement under Cal. Penal Code 12022.53(d), holding that the the trial court erred in denying Defendant's motion to strike.A jury convicted Defendant of second degree robbery, assault with a semiautomatic firearm, and driving under the influence. The jury found true the firearm use enhancements on the robbery and assault counts. Before sentencing, Defendant moved under Cal. Penal Code 12022.53(h) to strike the firearm enhancement under section 12022.53(d). The court denied Defendant's motion. On appeal, Defendant argued that the trial court abused its discretion because it was unaware that it could strike the enhancement at issue and then impose a lesser enhancement under either section 12022.53(b) or (c). The court of appeal affirmed, concluding that the trial court could not strike the enhancement and substitute a different unalleged enhancement. The Supreme Court reversed, holding that the Legislature has permitted courts to impose a section 12022.53(b) or (c) penalty when only a section 12022.53(d) enhancement is charged and found true. View "People v. Tirado" on Justia Law