Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction for five counts of murder, one count of residential burglary, and three counts of residential robbery with enhancements for personal use of a firearm and Defendant's death sentence, holding that there was no reasonable possibility that any assumed error could have affected the verdict.Specifically, the Supreme Court assumed potential errors in the trial court's failure to admonish support persons each time they accompanied a witness and in admitting hearsay during the penalty phase of trial. The Court, however, found no reasonable possibility that either assumed error could have affected the verdict. The Court further concluded that no cumulative prejudice rendered Defendant's trial unfair and therefore affirmed Defendant's convictions and his sentence of death. View "People v. Chhoun" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and sentence of death, holding that any errors, found or assumed, were not prejudicial.Specifically, the Supreme Court held (1) at the guilt phase, assuming that the trial court erred in admitting certain DNA evidence, the error was not prejudicial; (2) at the penalty phase, assuming the trial court erred in admitting evidence of potential animal abuse, the error was not prejudicial; (3) any error in imposing a parole revocation fine was harmless; (4) even when viewed in combination, the guilt phase and penalty phase errors were not prejudicial; and (5) the abstract of judgment reflected a clerical error, which will be corrected. View "People v. Baker" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder, attempted murder, and other offenses, and sentencing Defendant to death, holding that any errors that occurred during the trial proceedings were not prejudicial.Specifically, the Supreme Court held (1) during the guilt phase, there was error with respect to the prosecutor's misstatement of the reasonable doubt standard and with respect to defense counsel's agreement with the prosecutor on a certain point of law, but there was no reasonable probability that the prosecutor's or defense counsel's misstatements were prejudicial; (2) at the penalty phase, the prosecutor's comment about Defendant during penalty phase arguments bordered on "inflammatory" rhetoric, but any error was not prejudicial; and (3) the cumulative effect of these errors did not rise to the level of prejudice necessary to reverse Defendant's conviction or sentence. View "People v. Johnsen" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and sentence of death, holding that there was no prejudicial error in the trial proceedings.Defendant was convicted of the first degree murder of San Leandro Police Officer Nels Niemi. The jury returned a verdict of death, and the trial court sentenced Defendant accordingly. The court also ordered Defendant to pay a restitution fine of $10,000. The Supreme Court affirmed, holding (1) there was no error in the guilt phase of the proceedings; (2) there was no cumulative effect of any purported errors occurring at the penalty phase; and (3) the trial court did not violate any statutory or constitutional law by imposing restitution. View "People v. Ramirez" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that William Palmer was entitled to release from all forms of custody, including parole supervision, holding that to the extent Palmer's continued incarceration at some point became constitutionally excessive, that alone did not justify ending his parole under the current statutory scheme.Palmer first sought release on parole in 1995. The Board of Parole Hearings denied parole. Palmer continued to seek release. After the Board's tenth denial, Palmer filed a petition for writ of habeas corpus alleging that the thirty years he had served on a life sentence for an aggravated kidnapping committed when he was a juvenile was constitutionally excessive. The Board subsequently ordered Palmer released on parole. Ruling on Palmer's writ, the court of appeals concluded that Palmer's now-completed term of imprisonment had become unconstitutional and ended his parole. The Supreme Court reversed, holding that, in the absence of any persuasive argument from Palmer that his parole term had become constitutionally excessive, his parole remained valid. View "In re Palmer" on Justia Law

The Supreme Court held that Defendant could be convicted of an attempt to commit trafficking of a minor under Cal. Penal Code 236.1(c) for attempting to recruit as a prostitute "Bella," who was, in fact, an undercover detective.Bella had identified herself to Defendant as a seventeen-year-old girl but was actually an undercover detective. Defendant was convicted of human trafficking of a minor, attempted pimping of a minor, and pandering. The court of appeal reversed Defendant's human trafficking conviction, holding that Defendant could not be convicted under section 236.1(c) but only under the general law of attempt. The Supreme Court reversed and remanded the case, holding that, in light of the statutory language and the state's long-standing application of attempt law, Defendant could be convicted of an attempt under the trafficking statute. View "People v. Moses" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal granting Petitioner's petition for habeas corpus relief on the grounds that the Department of Corrections and Rehabilitation did not have the authority to exclude from nonviolent offender parole consideration inmates with prior sex offense convictions requiring registration, holding that this categorial exclusion violates Cal. Const. art. I, 32.After the electorate approved Proposition 57, the Public Safety and Rehabilitation Act of 2016, Petitioner filed a petition for a writ of habeas corpus challenging the Department's determination that he did not qualify for nonviolent offender parole consideration. The trial court denied the petition. The court of appeal granted habeas relief, holding that the amended regulations improperly excluded Petitioner from nonviolent offender parole consideration based on his two prior sex offense convictions. The Supreme Court affirmed, holding (1) nonviolent offender parole eligibility must be based on an inmate's current conviction; and (2) an inmate may not be excluded from nonviolent offender parole consideration based on a current conviction for a registrable felony offense that the Department's regulations have defined as nonviolent. The Court directed the Department to treat as void and repeal California Code of Regulations, 3491(b)(3) and 3496(b). View "In re Gadlin" on Justia Law

The Supreme Court held that Senate Bill 1437 bars a conviction for second degree murder under the natural and probable consequences theory and that the procedure set forth in Cal. Penal Code 1170.95 is the exclusive mechanism for retroactive relief and that, therefore, the ameliorative provisions of Senate Bill 1437 do not apply to nonfinal judgments on direct appeal.Among other things, Senate Bill 1437 amended Cal. Penal Code 188 to provide that in order to be convicted of murder, a principal in a crime shall act with malice aforethought. At issue in this appeal was the affect of this amendment on the natural and probable consequences doctrine as it applies to second degree murder. The Supreme Court remanded this matter to the court of appeal to affirm Defendant's second degree murder conviction without prejudice to any petition for relief that Defendant may file under section 1170.95, holding (1) section 188(a)(3) bars conviction for second degree murder under a natural and probable consequences theory; and (2) the ameliorative provisions of Senate Bill 1437 do not automatically apply to nonfinal judgments on direct appeal. View "People v. Gentile" on Justia Law

The Supreme Court reversed the judgment of the court of appeal reversing the judgment of the trial court granting Defendant's petition for a writ of habeas corpus and reinstating Defendant's conviction, holding that trial counsel rendered objectively deficient performance that prejudiced Defendant's case.After a jury trial, Defendant was convicted of second degree murder and sentenced to a term of imprisonment of fifteen years to life. Defendant later filed a petition for a writ of habeas corpus on the grounds of ineffective assistance of counsel and actual innocence. The Supreme Court concluded that Defendant had stated a prima facie case for relief and issued an order to show cause. The trial court vacated Defendant's conviction, finding that Defendant's trial counsel rendered ineffective assistance. The court of appeal reversed, finding no deficient performance. The Supreme Court reversed, holding that counsel's failure to investigate the victim's time of death, in a case where the timeline was crucial, was an error sufficient to undermine confidence in the outcome. View "In re Long" on Justia Law

The Supreme Court reversed Defendant's conviction of fetal murder and affirmed his convictions of ten counts of murder, holding that hearsay was improperly admitted on the question of fetal viability.Defendant was convicted of murdering ten women and one viable fetus and sentenced to death. The primary issues on appeal were whether the trial court erred in admitting statistical evidence about the significance of DNA matches and in admitting hearsay testimony about the fetus's viability. The Supreme Court reversed the fetal murder conviction and otherwise affirmed, holding (1) the challenged testimony admitted in this case was hearsay, and the error in admitting the testimony was prejudicial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Turner" on Justia Law