Justia Criminal Law Opinion Summaries

The Supreme Court reversed Defendant's convictions of two counts of first-degree murder, holding that the district court erred in failing to initiate the competency procedures set forth in Cal. Penal Code 1368 and 1369.During pretrial proceedings and at the request of the court, a psychologist examined Defendant and issued a report finding Defendant incompetent to stand trial. The trial court rejected the psychologist's opinion without initiating the competency procedures set forth in sections 1368 and 1369. At both the guilt and penalty phases of trial, Defendant represented himself. Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court reversed the judgment in its entirety, holding that the trial court erred by failing to initiate the formal competency procedures set forth in sections 1368 and 1369. View "People v. Wycoff" on Justia Law

The Supreme Court held that possession of cannabis in prison remains a violation of Cal. Penal Code 4573.6 and that Proposition 64 - the Control, Regulate and Tax Adult Use of Marijuana Act - did not invalidate cannabis-related convictions under section 4573.6, which makes it a felony to possess a controlled substance in a state correctional facility.The five defendants in this case were each found in possession of cannabis in a state prison and were convicted of violating section 4573.6. After voters passed Proposition 64 in 2016, Defendants filed petitions arguing that their sentences for violating section 4573.6 should be dismissed because adult possession of less than one ounce of cannabis in prison no longer qualified as a crime. The trial court denied the petitions. The court of appeal reversed, holding that the conduct underlying Defendants' convictions was no longer criminal under section 4573.6. The Supreme Court reversed, holding that Cal. Health & Saf. Code 11362.5(d) - containing an exception providing that the Act does not amend or affect certain laws - is most reasonably construed as encompassing laws that prohibit the possession of cannabis in prison. View "People v. Raybon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal striking as unreasonable a condition of supervised release requiring Defendant to "submit to search of any electronic device either in his possession[,] including cell phone[,] and/or any device in his place of residence," holding that there was no error.At issue was how to assess the validity of a challenged condition of a period of mandatory supervision following service of a county jail sentence. The Supreme Court held (1) such discretionary conditions are to be evaluated for reasonableness on a case-by-case basis under the test set forth in People v. Lent, 15 Cal.3d 481 (1975); (2) a mandatory supervision condition that allows for a search of an individual's electronic devices is not per se reasonable in all cases; and (3) because the People did not review the court of appeal's case-specific outcome in this case, this Court accepts that concession and does not review the court of appeal's determination as to the condition imposed on Defendant. View "People v. Bryant" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's summary denial of Defendant's Cal. Penal Code 1170.95 petition, holding that the statutory language and legislative intent of section 1170.95 make clear that petitioners are entitled to the appointment of counsel upon the filing of a facially sufficient petition.Senate Bill No. 1437 eliminated natural and probable consequences liability for muder and limited the scope of the felony murder rule. The bill also added section 1170.95 to the Penal Code, which creates a procedure for convicted murderers who could not be convicted under the law as amended to retroactively seek relief. Defendant filed a section 1170.95 petition. The trial court considered Defendant's record of conviction without appointing counsel and summarily denied the petition. The Supreme Court reversed, holding (1) a petitioner is statutorily entitled to counsel, if requested, upon the filing of a facially sufficient petition, and section 1170.95, subdivision (c) describes only one prima facie showing; (2) a trial court can rely on the record of conviction in determining whether that single prima facie showing is made; and (3) the trial court's failure to appoint counsel to represent Defendant was state law error only, and the court of appeal shall determine on remand whether the error was prejudicial. View "People v. Lewis" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count each of murder and rape and his sentence of death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err in excluding defense evidence relating to third party culpability and victim character; (2) the trial court did not by admitting three photographs of the victim proffered by the prosecutor while excluding a booking photograph of the victim offered by Defendant; (3) the trial court did not abuse its discretion in excluding certain newspaper articles or evidence of other crimes; (4) the trial court did not err in permitting the prosecutor to elicit testimony from Defendant's wife and from the victim's father; (5) assuming the trial court's instruction pursuant to CALJIC No. 2.50.01 was erroneous, there was no prejudice; (6) the trial court did not abuse its discretion in denying Defendant discovery of a witness's medical records; (7) any error in the admission of evidence and regiment regarding Defendant's lack of remorse was harmless; (8) assuming that the prosecutor erred in her penalty phase argument, the error was not prejudicial; and (9) Defendant's challenges to his sentence were unavailing. View "People v. Dworak" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal in this case involving allegations of active gang participation and gang enhancements attached to other offenses, holding that the commission of two or more predicate offenses must be proven by independent admissible evidence, and such proof may not be established solely by the testimony of an expert who has no personal knowledge of facts otherwise necessary to satisfy the prosecution's burden.The two defendants in this case were charged with two counts of attempted murder, assault with a firearm, and active street gang participation. Gang and firearm enhancements were attached to the charges. The first trial ended when the jury hung on almost all charges, but a second jury convicted Defendants of the remaining allegations. The court of appeal reversed the active gang participation and enhancement allegations, as well as Defendant's firearm enhancements attached to those allegations, and otherwise affirmed, holding that some of an expert's testimony constituted inadmissible hearsay. The Supreme Court affirmed, holding (1) the jury was permitted to improperly rely on hearsay to conclude that the predicate offenses had been proven and that Defendants acted with intent to benefit a gang when they committed the crimes with which they were charged; and (2) the error was not harmless. View "People v. Valencia" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of kidnapping and killing Shirley and Andrew Demko after burglarizing and robbing their home, holding that there was no error in the proceedings below.On appeal, Defendant raised numerous allegations of error both during the guilt phase and the penalty phase. The Supreme Court rejected the claims and affirmed the judgment in its entirety, holding (1) the trial court did not err in denying Defendant's Batson/Wheeler motion upon finding that the prosecutor did not make a prima facie showing that the prosecutor exercised a peremptory challenge in a discriminatory manner; (2) assuming, without deciding, that the trial court erred in admitting statements that Defendant identified as implicating prior burglaries, any error was harmless as a matter of law; and (3) there were no penalty phase errors and no cumulative prejudice to consider. View "People v. Battle" on Justia Law

The Supreme Court reversed the order of the court of appeal denying a certificate of appealability in this case, holding that under the law as amended by Proposition 66 the requirement that habeas corpus petitioners must make a showing of actual innocence or death ineligibility if they seek a second chance to make an argument they could have made earlier does not apply to the habeas petition who raises a newly available claim at the first opportunity.Petitioner was convicted of a robbery murder and sentenced to death. In 2015, the Supreme Court denied Petitioner's habeas corpus petition. Petitioner then filed a federal habeas petition in the federal district court, which stayed proceedings to allow Petitioner to exhaust six claims in state court. Thereafter, Proposition 66 came into force. In 2018, Petitioner filed a second state habeas petition raising the six unexhausted claims. The state court dismissed Petitioner's recently filed habeas petition as successive. The court of appeals denied Petitioner's request for a certificate of appealability. The Supreme Court reversed, holding that Proposition 66 should be read to provide a means for appealing the superior court's determination that a subsequent petition is successive. View "In re Friend" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the judgment of the trial court imposing an additional three-year term of imprisonment for a great bodily injury enhancement, holding that the act of furnishing a controlled substance is not by itself sufficient to establish that the defendant "personally inflict[ed]" great bodily injury.A jury convicted Defendant of offering a controlled substance to a minor and furnishing or giving away a controlled substance to a minor. The jury also sustained the allegation that Defendant personally inflicted great bodily injury upon his girlfriend, who died from fentanyl intoxication, within the meaning of Cal. Penal Code 12022.7, subdivision (a). The trial court sentenced Defendant to nine years in prison, plus an additional three years for the great bodily injury enhancement. The court of appeal affirmed. The Supreme Court reversed and remanded the case, holding that the trial court erred as a matter of law by precluding defense counsel from arguing that, in light of the girlfriend's voluntary ingestion of the controlled substance, the facts did not support a great bodily injury enhancement. View "People v. Ollo" on Justia Law

The Supreme Court reversed the decision of the court of appeal concluding that Defendant's case was final because Defendant could have appealed his sentence when it was imposed, holding that when a defendant is placed on probation with execution of an imposed state prison sentence suspended the case is not yet final if the defendant may still timely obtain direct review of an order revoking probation and causing the state prison sentence to take effect.Defendant pleaded no contest to a felony. In 2015, the trial court suspended him. In 2018, the court found Defendant in violation of a condition of probation and ordered the sentence to take effect. During the pendency of Defendant's appeal, the Legislature amended the provision under which the trial court had imposed two one-year enhancements. The parties agreed that the amendment applies to all cases that were not final when the legislation took effect but disagreed as to whether Defendant's case was final. The court of appeals held that it was. The Supreme Court reversed, holding that legislation ameliorating punishment presumptively applies to suspended execution cases pending on appeal from an order causing a previously imposed sentence to take effect. View "People v. Esquivel" on Justia Law