Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the trial court upholding Defendants' convictions of two counts of attempted murder, holding that the evidence was insufficient to support an instruction on the kill zone theory in connection with one of the two alleged attempted murder victims.Defendants were jointly charged and tried on counts including first degree murder and two attempted murders. The trial court gave a kill zone instruction in connection with one of the two alleged attempted murder victims. Under the kill zone theory, a defendant may be convicted of the attempted murder of an individual who was not the defendant's primary target. The court of appeals upheld the attempted murder convictions. The Supreme Court reversed, holding (1) a jury may convict a defendant under the kill zone theory only when the evidence supports a finding that the defendant harbored the requisite specific intent to kill both the primary target and everyone within the zone of fatal harm; and (2) there was insufficient evidence in the record to support an instruction on the kill zone theory. View "People v. Canizales" on Justia Law

The Supreme Court affirmed the judgment of the trial court sentencing Defendant Socorro Susan Caro to death for killing three of her four children, holding that any error in the admission of statements from a detective's interview of Defendant in the hospital after she underwent emergency surgery for a gunshot wound to her head was harmless.Specifically, the court held (1) the trial court committed certain evidentiary errors, but the errors were harmless, were not cumulatively prejudicial, and did not affect Defendant's right to present a defense; (2) assuming error on Defendant's claim that the prosecution should have provided its investigatory material about prospective jurors, the error was harmless; and (3) assuming that the prosecution committed misconduct, the misconduct did not require reversal. View "People v. Caro" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming the decision of a resentencing court refusing to dismiss Defendant's conviction for street terrorism after Proposition 47 came into effect, holding that Defendant was entitled to have his street terrorism conviction dismissed.Proposition 47 reclassified as misdemeanors certain narcotics and theft offenses previously cast as felonies. The gang crime of street terrorism occurs when "a person who actively participates in any criminal street gang...willfully promotes, furthers, or assists in any felonious criminal conduct by members of that gang." On the basis of his act of stealing a bicycle Defendant was convicted of both felony grand theft and street terrorism. After Proposition 47 took effect, the resentencing court refused to dismiss Defendant's street terrorism conviction even though the theft of the bicycle supplied the "felonious criminal conduct" necessary for the commission of the offense. The court of appeal affirmed. The Supreme Court reversed, holding that Defendant was entitled to have his street terrorism conviction dismissed in a full resentencing. View "People v. Valenzuela" on Justia Law

The Supreme Court reversed the judgment of the court of appeal granting Anthony Cook's petition for writ of habeas corpus and remanded the matter to the court of appeal with directions to deny the petition, holding that resort to a petition for writ of habeas corpus was unnecessary in this case, at least in the first instance.Cook was convicted of two counts of first degree murder and one count of premeditated attempted murder. Cook, who was seventeen years old when he committed the murders, was sentenced to life with the possibility of parole for the attempted murder and five consecutive terms of twenty-five years to life for the murders and enhancements. Cook later filed a petition for writ of habeas corpus arguing that his sentence was cruel and unusual punishment in violation of the Eighth Amendment and Miller v. Alabama, 567 U.S. 460 (2012). The court of appeal granted the writ, holding that, in light of People v. Franklin, 63 Cal.4th 261 (2016), Cook was entitled to make a record before the superior court of mitigating evidence tied to his youth. The Supreme Court reversed, holding that Cal. Penal Code 1203.01 provides an adequate remedy at law to preserve evidence of youth-related factors. View "In re Cook" on Justia Law

In this criminal case, the Supreme Court held that, when a defendant posts bail, the trial court has authority to impose reasonable conditions related to public safety but that the question had become moot as to the Defendant in the instant case.Defendant was arrested and charged with two felony counts. Defendant posted bail and was released from custody. At arraignment, the court imposed as an additional condition of release that Defendant waive her Fourth Amendment right to be free of warrantless or unreasonable searches. The District Attorney petitioned for review, asking whether trial courts possess inherent authority to impose reasonable bail conditions related to public safety on felony defendants who are released on bail. The Supreme Court answered in the affirmative, holding (1) trial courts have authority to impose release conditions on persons who post bail; but (2) the question was moot as to Defendant, and therefore, this Court need not decide whether the specific condition was valid. View "In re Webb" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first degree murder and personal use of a deadly weapon and Defendant's sentence of death on both counts, holding that no prejudicial error occurred in the proceedings below.Specifically, the Court held (1) the trial court did not abuse its discretion by admitting evidence of other crimes; (2) the trial court did not violate Defendant's right to an impartial penalty phase jury under the federal and state Constitutions by excusing a prospective juror for cause because of her views on the death penalty; (3) penalty retrial following a hung jury was not unconstitutional; (4) the trial court did not err by denying Defendant's motion to declare the death penalty unconstitutional in practice; and (5) an instruction during the penalty phase was given in error, but the error was harmless. View "People v. Erskine" on Justia Law

The Supreme Court affirmed as modified the judgment of the trial court convicting Defendant and sentencing him to death for the murder of a peace officer, holding that modification of the judgment was required to reduce the restitution and parole revocation fines.Specifically, the Court held (1) the evidence was sufficient to support the jury's finding that Defendant committed a premeditated and deliberate murder; (2) any error in the jury instructions was harmless beyond. Reasonable doubt; (3) the evidence was sufficient to sustain the gang-related enhancement; (4) the trial court did not abuse its discretion in its in camera review process of sealed transcripts; (5) the trial court erred in admitting uncharged misconduct to support the prosecution's argument that Defendant premeditated the murder, but the error was harmless; (6) the guilt phase errors did not cumulatively amount to prejudice requiring reversal of Defendant's conviction; (7) any error in the penalty proceedings was harmless; and (8) the trial court erred by imposing two fines in excess of the statutory maximum - the restitution fine and the parole revocation fine. View "People v. Rivera" on Justia Law

The Supreme Court vacated as unauthorized the death sentence imposed upon Defendant in connection with his conviction for conspiracy to commit murder and vacated the jury's lying in wait special-circumstance true finding and affirmed, as modified, the judgment in all other respects, holding that no substantial evidence supported the lying in wait special-circumstance finding and that the trial court erred in imposing the death penalty for Defendant's conviction of conspiracy to commit murder.Defendant was convicted of conspiracy to commit murder and first degree murder. The jury found true lying in wait and torture-murder special-circumstance allegations. The jury returned a death verdict. In addition to the errors found on appeal, the Supreme Court assumed error in (1) the trial court's preclusion of impeachment of witnesses with their felony convictions or pending charges; (2) the admission of certain evidence; (3) certain aspects of the prosecutor's guilt phase closing argument; and (4) the trial court's failure to instruct on its own motion that a coperetrator's guilty plea could only be used to assess her credibility. The Court held that the errors and assumed errors, whether considered individually or cumulatively, did not require reversal of Defendant's murder or conspiracy convictions but that the death sentence and lying in wait special-circumstance true finding were improperly imposed. View "People v. Dalton" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder in the course of a robbery and related crimes and sentencing Defendant to death, holding that any assumed errors were harmless.Specifically, the Court held (1) even if it was error for the trial court to admit testimony arguably conveying the substance of a hearsay declarant's out-of-course identification, the error was harmless; (2) assuming there was error in Defendant's absence during one day of the penalty phase trial, the error was harmless; (3) any other possible errors contemplated by this Court were harmless; and (4) Defendant's challenges to the constitutionality of California's capital sentencing scheme were unavailing. View "People v. Bell" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's automatic motion to modify the jury's verdict convicting Defendant of two counts of first degree murder and sentencing him to death, holding that any errors were minimal and did not warrant reversal.Specifically, the Court held (1) even assuming that the trial court erred in excluding Defendant's proffered statements to impeach a witness's credibility, the error was harmless and not so severe as to violate Defendant's right under the United States Constitution to confront the witnesses against him; (2) any error in the trial court's ruling permitting certain cross-examination when Defendant testified was harmless; (3) any impropriety on the part of the prosecutor during his guilt phase closing argument to the jury was not prejudicial; and (4) any error in the admission of evidence that Defendant. committed a crime involving force or violence against his stepdaughter was harmless. View "People v. Sanchez" on Justia Law