Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeal concluding that a defense counsel's failure to object at trial, before People v. Sanchez, 63 Cal.4th 665 (2016), was decided, forfeited a claim that a gang expert's testimony related case-specific hearsay in violation of the confrontation clause, holding that a defense counsel's failure to object under such circumstances does not forfeit a claim based on Sanchez.Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for her opinion unless the facts are independently proven or fall within a hearsay exception. Defendants in the instant case were each convicted of two counts of first degree special circumstance murder and other crimes. Before Defendants' appeals were resolved, the Supreme Court issued its opinion in Sanchez. On appeal, one of the defendants argued that a gang expert testified to case-specific hearsay in violation of the confrontation clause. The court of appeal held that the defendant's failure to object to case-specific hearsay in expert testimony at trial forfeited any Sanchez claim on appeal. The Supreme Court reversed, holding that the court of appeal erred in finding that the defendant forfeited his claim on appeal based on Sanchez by failing to object at a trial that occurred before Sanchez was decided. View "People v. Perez" on Justia Law

The Supreme Court granted Petitioner habeas corpus relief, holding that Petitioner was denied his constitutional right to the assistance of competent counsel at the guilt phase of his criminal trial, and trial counsel's deficient performance undermined the reliability of the jury's guilty verdict.Petitioner was convicted of the first degree murder of a police officer and sentenced to death. While his appeal was pending, Petitioner filed his first petition for a writ of habeas corpus, arguing that the judgment should be vacated because he had received constitutionally ineffective assistance of counsel. During the habeas proceedings, the Supreme Court found that Petitioner's trial counsel had defrauded Petitioner in order to induce Petitioner to retain him instead of the public defender. Counsel went on to commit serious errors during the penalty phase undermining the reliability of the death verdict. The Supreme Court granted the petition and ordered a new penalty phase trial. Petitioner later filed this petition for a writ of habeas corpus challenging his convictions. The Supreme Court granted the writ and vacated Defendant's conviction for first degree murder, holding that Petitioner was denied the effective assistance of counsel at the guilt phase of his trial. View "In re Gay" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree murder, finding Defendant was sane at the time of the crimes, and sentencing Defendant to death, but struck an improperly imposed restitution fine, holding that the restitution fine should be stricken from the abstract of judgment and that any other error was not prejudicial.The trial court imposed a $10,000 restitution fine but did not impose the fine at the sentencing hearing. Rather, the fine was later added to the abstract of judgment. The Supreme Court ordered the restitution fine stricken from the record and the minutes because the trial court never imposed the fine in open court in Defendant's presence. The Court assumed other errors during the trial proceedings but found no prejudice. Further, the Court held that the error regarding the restitution fine and any assumed error were not cumulatively prejudicial. View "People v. Frederickson" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and kidnapping and sentence of death, holding that Defendant was not entitled to relief.Specifically, the Court held (1) the superior court did not err in exercising its jurisdiction in this matter; (2) the trial court did not err in the voir dire proceedings; (3) Defendant's argument that there was a material variance between the kidnap alleged in the indictment and the prosecutor's argument regarding his actual offense was unavailing; (4) the trial court did not err in admitting Defendant's custodial confession; (5) the trial court did not err by compelling Defendant to testify as a foundation for testimony by Defendant's expert that his confession was false; (6) the trial court did not err by limiting expert witness testimony; (7) the trial court did not err by compelling Defendant to undergo a prosecution-conducted psychiatric examination; (8) the prosecutor did not commit misconduct during the guilt phase closing argument; (9) there was no instructional error; (10) there was sufficient evidence to support the kidnap-murder special circumstance; (11) Defendant's claims of prosecutorial misconduct during the penalty phase closing argument lacked merit; and (12) Defendant's remaining penalty phase claims were unavailing. View "People v. Hoyt" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of murder and one count of attempted murder and sentence of death for one murder and life imprisonment without the possibility of parole for the other murder, holding that there was no prejudicial error in the proceedings below.Specifically, the Court held (1) the trial court did not err in admitting Defendant's convictions because there was no basis to conclude Defendant's Miranda waiver was anything other than knowing, intelligent, and voluntary; (2) any error in instructing the jury was harmless; (3) Defendant's challenges to the constitutionality of California's death penalty scheme were unavailing; and (4) the potential errors in the instructions were harmless, and even considered together, the errors did not warrant reversal. View "People v. Leon" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming Defendant's conviction of four felony counts of accessory after the fact to murder and one misdemeanor count of contempt of court, holding that a witness's refusal to testify in the face of a valid subpoena, while punishable as contempt, does not by itself amount to harboring, concealing, or aiding a principal within the meaning of Cal. Penal Code 32.On appeal, Defendant argued that her failure to testify did not support the accessory conviction because her silence did not fulfill the "overt or affirmative assistance" requirement of the crime of accessory. The Supreme Court agreed and reversed, holding that Defendant's silence did not constitute overt or affirmative assistance and did not transform her misdemeanor offense of contempt into four felony offenses of accessory after the fact to murder. View "People v. Partee" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the judgment of the trial court dismissing this complaint filed by Plaintiffs, two therapists and one counselor, alleging that the basic norm of confidentiality protected by the psychotherapist-patient privilege applies to admissions by certain patients of downloading or electronically viewing child pornography, holding that Plaintiffs asserted a cognizable privacy interest under the California Constitution and that their complaint survived demurrer.Specifically, Plaintiffs claimed that the 2014 amendment to Cal. Pen. Code 11165.1(c)(3), which requires Plaintiffs to report to law enforcement and child welfare authorities patients who have admitted to downloading or electronically viewing child pornography, violated their patents' right to privacy under the Fourteenth Amendment to the United States Constitution and Cal. Const. art. I, 1. Defendants filed demurrers, arguing that Plaintiffs failed to establish a valid constitutional privacy claim. The trial court dismissed the complaint, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiffs' allegations satisfied the threshold inquiry for a cognizable privacy claim. View "Mathews v. Becerra" on Justia Law

The Supreme Court reversed Defendant's convictions involving one of the witnesses that testified during Defendant's trial, holding that the trial court violated Defendant's right of confrontation under the Sixth Amendment by positioning a computer monitor so that the witness could not see Defendant while the witness testified and Defendant could not see the witness.Defendant was convicted of multiple sex offenses involving several minor victims. Three of the victims testified with the repositioned monitor. The court of appeal affirmed Defendant's convictions. The Supreme Court reversed in part, holding (1) as to one of the witnesses, Defendant's constitutional right of confrontation was violated when he could not see the witness and the witness testified because the trial court repositioned a computer monitor on the witness stand to allow the witness to testify without seeing Defendant; (2) as to the other two witnesses, Defendant forfeited his claim by failing to object to the trial court's action; and (3) Defendant failed to establish that he received ineffective assistance of counsel. View "People v. Arredondo" on Justia Law

The Supreme Court granted review in this criminal case to determine the continued viability of Cal. Penal Code 632(d) in light of the limits placed on the exclusion of evidence by the "Right to Truth in Evidence" provision of the California Constitution, holding that nothing in the amendments to section 632 evidenced an intent on the part of the Legislature to render surreptitious recordings once again inadmissible in criminal proceedings.Defendant was convicted of two counts of committing a lewd and lascivious act upon a child. The conviction was largely based on a secretly recorded conversation that violated section 632. The court of appeal, however, found that section 632(d), which prohibits the admission of "evidence obtained...in violation of this section...in any judicial, administrative, legislative, or other proceeding," had been abrogated by the Right to Truth in Evidence constitutional provision, which instructs that "except as provided by statute hereafter enacted...relevant evidence shall not be excluded in any criminal proceeding." The Supreme Court affirmed, holding (1) to the extent section 632(d) demanded suppression of relevant evidence in a criminal proceeding, it was abrogated by the voters' approval of Proposition 8; and (2) none of the Legislature's subsequent amendments to section 632 revived the exclusionary remedy of section 632(d). View "People v. Guzman" on Justia Law

The Supreme Court affirmed, as modified in this opinion, the judgments of the trial court convicting James David Beck and Gerald Dean Cruz of four counts of first degree murder and entering judgments of death based on the murders, holding that certain true findings as to Defendants' convictions of conspiracy to commit murder were unauthorized.Defendants were convicted of four counts of first degree murder and of conspiracy to commit murder. The jury also found true a multiple murder special circumstance allegation and allegations of personal use of a deadly weapon. The trial court entered judgments of death. The Supreme Court vacated the multiple murder special circumstances true findings as to conspiracy to commit murder, as well as the death sentences imposed for that count, and otherwise affirmed, holding (1) the trial court erred in imposing a death sentence based upon Defendants' conspiracy convictions because conspiracy to commit murder alone cannot make a defendant death eligible; and (2) there was error but no prejudice in some of the trial court's instructions, the prosecutor's argument during the penalty phase, the imposition of the death penalty for the convictions of conspiracy to commit murder, and in the admission of certain testimony, but these errors were not prejudicial when considered individually or cumulatively. View "People v. Beck" on Justia Law