Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to modify the jury's verdicts of burglary and first degree murder, first degree forcible rape, second degree robbery and false imprisonment by violence and sentencing Defendant to death, holding that considering assumed errors altogether, reversal was not warranted.Defendant, an African-American, was charged with raping and murdering a White woman. On appeal, Defendant argued, among other things, that the prosecutor improperly exercise peremptory challenges to excuse two prospective jurors, who were African-American, in violation of Batson v. Kentucky, 476 U.S. 79, and People v. Wheeler, 22 Cal.3d 258, 276-277. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) substantial evidence supported the trial court's conclusion that the prosecutor struck the potential jurors for reasons other than his race; (2) there was no error in the trial court's decision to excuse two jurors for cause; (3) there was no merit to Defendant's allegations of error during the guilt phase; and (4) any assumed errors during the competency phase and penalty phase were not prejudicial and, considered cumulatively, did not require reversal. View "People v. Miles" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal finding that the trial court acted within its discretion when it denied bail to Petitioner, holding that the trial court's decision to order Petitioner detained was not an abuse of discretion.Petitioner was charged with felony offenses involving acts of violence and sexual assault. The trial court denied bail. Petitioner challenged the no-bail order by filing a petition for writ of habeas corpus. The court of appeal upheld the trial court's findings and denied relief. The Supreme Court affirmed, holding (1) a reasonable fact finder could conclude that Petitioner was guilty of at least one of the offenses for which he was charged beyond a reasonable doubt; (2) a court could conclude by clear and convincing evidence that there was a substantial likelihood that Petitioner's release could result in great bodily harm to others; and (3) the trial court did not abuse its discretion in ordering Petitioner detained on this basis. View "In re White" on Justia Law

The Supreme Court affirmed the decision of the court of appeal reversing Defendant's conviction of two counts of assault by an inmate with a deadly weapon and other offenses, holding that the prosecutor impermissibly vouched for testifying officers' credibility.Specifically, the court of appeals held that the prosecutor impermissibly vouched for witness credibility by asserting in closing argument that two testifying officers would not lie because each would not put his "entire career on the line" and would not subject himself to "possible prosecution for perjury." The court further held that the error was prejudicial. The Attorney General petitioned for review solely on the question of whether the prosecutor's argument constituted impermissible vouching. The Supreme Court affirmed, holding (1) the prosecutor's closing argument constituted improper vouching; and (2) while the court of appeals appears to have overstated the import and effect of the prosecutor's remarks, the Attorney General did not argue harmlessness, and this Court expresses no view on the appellate court's conclusions that the statements were prejudicial. View "People v. Rodriguez" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of first degree murder and his sentence of death, holding that the three or four minor errors at Defendant's trial were harmless and did not interfere with his due process right to a fair trial.Specifically, the Supreme Court held (1) no error occurred during jury selection; (2) Defendant was not prejudiced by any misstatements by the prosecutor; (3) assuming certain evidence was inadmissible, the court's admonition to the jury and the court's instruction cured the resultant harm; (4) the trial court erred in admitting testimony that the victim was afraid of Defendant, but the error was harmless; and (5) Defendant's remaining allegations of error were without merit. View "People v. Flores" on Justia Law

The Supreme Court reversed the judgment of the court of appeal with instructions to remand to the trial court to reduce Defendant's forgery conviction to a misdemeanor, holding that the mere fact that a defendant possessed separate stolen identification and forged instruments together at the same time did not provide a sufficient connection between the two offenses to bar him from a sentence reduction pursuant to Cal. Penal Code 473(b).Among the offenses that Proposition 47 amended was forgery not exceeding $950 dollars. Proposition 47 included an exception providing that the sentencing reduction for forgery was not applicable to a defendant convicted both of forgery and identity theft. In People v. Gonzalez, 6 Cal.5th 44 (2018), the Supreme Court held that the exception applies only when there is a meaningful connection between a defendant's forgery conviction and his identity theft conviction. In this case, the Supreme Court held (1) a meaningful connection between forgery and identity theft for purposes of the exception requires a facilitative relationship between the two offenses; and (2) where Defendant merely possessed two separate items of contraband at the same time, a "meaningful relationship" was not established, and Defendant was entitled to a sentence reduction. View "People v. Guerrero" on Justia Law

The Supreme Court held that section Cal. Penal Code 459.5(b) prohibits charging shoplifting and theft of the same property, even in the alternative, and that, as a general rule, section 459.5(b) prohibits a prosecutor from charging theft when there is probable cause that a defendant has committed shoplifting of the same property.Defendant stole items worth $496.37. Defendant was charged with shoplifting and theft but was convicted solely of theft. Defendant appealed, arguing that he had been charged in violation of section 459.5(b), which provides that no person who is charged with shoplifting may also be charged with burglary or theft of the same property. The court of appeal concluded that Defendant had been improperly charged but that Defendant was not prejudiced by his trial counsel's failure to object to the charges because section 459.5(b) permitted the prosecutor to amend the information to charge shoplifting and theft in the alternative. The Supreme Court reversed, holding that the court of appeal (1) correctly concluded that Defendant was charged in violation of section 459.5(b)'s prohibition on charging a person with shoplifting and theft of the same property; but (2) erred in concluding that section 459.5(b) would have permitted the prosecutor to charge Defendant with shoplifting and theft in the alternative. View "People v. Lopez" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming the judgment of the trial court denying Appellant's request for expungement of his misdemeanor conviction under Cal. Penal Code 1203.4a, subd. (a), holding that a person may live "an honest and upright life" even if that person has been in custody since completing the sentence imposed for the misdemeanor.Defendant completed his term of imprisonment for his misdemeanor conviction in 2012 and had been in federal immigration custody up until he brought his action. While in immigration custody, Defendant sought expungement of the conviction under section 1203.4a(a), alleging that he had obeyed all laws since being convicted and had participated in fire camp and Alcoholics Anonymous. The trial court denied the request, concluding that custodial time did not qualify as honest and upright living for expungement purposes. The court of appeals affirmed. The Supreme Court reversed and remanded the case, holding that conduct while in custody is relevant to determining whether a defendant has satisfied the honest and upright life requirement of section 1203.4a. View "People v. Maya" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first degree murder and of conspiracy to commit murder and sentencing Defendant to death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the admission of Defendant's surreptitiously recorded jailhouse statement did not violate Defendant's Sixth Amendment right to counsel, his Fifth Amendment right to counsel and privilege against self-incrimination, his Fourth Amendment right to be free from unreasonable detention, his rights under the Sixth Amendment's confrontation clause, or attendant protections under Evidence Code sections 352 and 1101; (2) one instance of prosecutorial misconduct committed at the guilt phase was not prejudicial; and (3) Defendant was not entitled to relief on his remaining claims of guilt phase and penalty phase error. View "People v. Fayed" on Justia Law

The Supreme Court affirmed the decision of the court of appeal ruling that Proposition 47's revision to Cal. Penal Code 496, making the offense of receiving stolen property a misdemeanor when the value of the property is $950 or less, does not extend to convictions for receiving a stolen vehicle under section 496d, holding that Proposition 47's amendment to section 496(a) did not affect convictions for receiving stolen property under section 496d.Proposition 47 amended section 496, the general statute criminalizing receipt of stolen property, by making the offense a misdemeanor if the value of the property does not exceed $950. Proposition 47, however, did not amend 496d. Defendant pleaded guilty to unlawfully buying, receiving, concealing, selling or withholding a stolen vehicle in violation of section 496d. Defendant filed a motion under Proposition 47 to reduce his convictions to misdemeanors. The trial court denied the motion, and the court of appeal affirmed. The Supreme Court affirmed, holding that Proposition 47's revision to section 496 does not extend to convictions under section 496d. View "People v. Orozco" on Justia Law

In this case involving whether Proposition 47 requires a court to draw a distinction under Cal. Veh. Code 10851 between permanent and temporary vehicle takings, the Supreme Court held that a person who has unlawfully taken a vehicle in violation of section 10851 is not disqualified from Proposition 47 relief because the person cannot prove he or she intended to keep the vehicle away from the owner indefinitely.Proposition 47 reduced felony offenses consisting of theft of property worth $950 or less to misdemeanors. While liability for theft generally requires that the defendant have an intent permanently to deprive the owner of possession, section 10581 does not distinguish between temporary takings and permanent ones. At issue in this case was whether Proposition 47 grant sentencing relief to people who take vehicles permanently but denies relief to people who take vehicles temporarily. The Supreme Court answered the question in the negative and reversed the superior court's denial of resentencing for Defendant's 10851 conviction, holding that Proposition is neither categorically inapplicable to section 10851 convictions nor is a defendant not entitled to resentencing because he lacked the intent permanently to deprive the vehicle's owner of its possession. View "People v. Bullard" on Justia Law