Justia Criminal Law Opinion Summaries

The Supreme Court affirmed, as modified, the judgment of the trial court convicting Defendant of first degree murder, conspiracy to commit robbery and burglary, and two counts of residential burglary, including the judgment of death, and modified the judgment by striking a one-year enhancement the trial court imposed for the finding that Defendant had served one prior prison term.The Supreme Court held that no prejudicial error occurred during the guilt phase of trial or the penalty phase of trial, with the exception of the one-year enhancement for the prior prison term, holding that because the prison term was served for two of the convictions for which the Court also enhanced the sentence, the enhancement for the prior prison term must be stricken. View "People v. Anderson" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first degree murder and sentencing him to death.Defendant was convicted of first-degree murder for killing his girlfriend’s twenty-one-month-old granddaughter, assault resulting in the death of a child under eight years old, and committing lewd and lascivious conduct on a child under the age of fourteen. The Supreme Court affirmed, holding (1) the admission of testimony from child witnesses was not in error and did not violate Defendant’s due process rights; (2) the evidence was sufficient to support Defendant’s murder conviction; (3) the trial court did not err in admitting evidence of a witness’s broken leg; (4) the trial court did not improperly coerce a death verdict; (5) the trial court’s response to a jury question, coupled with the prosecutor’s argument, did not allow the jury to consider inadmissible evidence during its penalty determination; (6) the prosecutor did not commit error under Griffin v. California, 380 U.S. 609 (1965); and (7) the admission of rebuttal character evidence was not in error. View "People v. Lopez" on Justia Law

The Supreme Court reversed the decision of the court of appeal interpreting Cal. Civ. Code 3531 as authorizing a court to declare Cal. Penal Code 31910(b)(7)(A) unenforceable when a complainant alleges, and the court finds, that complying with the statute is impossible.Penal Code 31910(b)(7)(A) amended the definition of unsafe handguns under the Unsafe Handgun Act to include semiautomatic pistols that are not equipped with with dual placement microstamping. National Shooting Sports Foundation, Inc. (NSSF) filed a complaint seeking declaratory and injunctive relief, alleging that dual placement micro stamping technology was impossible to implement and, therefore, Penal Code 31910(b)(7)(A) was unenforceable on the basis of Civil Code 3531’s declaration that “[t]he law never requires impossibilities.” The court of appeals held that NSSF may present evidence of impossibility and that the judiciary may invalidate Penal Code 31910(b)(7)(A) if compliance is shown to be impossible. The Supreme Court reversed, holding that Civil Code 3531’s maxim that "[t]he law never requires impossibilities” is an interpretive aid that occasionally authorizes an exception to a statutory mandate in accordance with the Legislature’s intent behind the mandate and has never been recognized, nor will it be recognized in this case, as a ground for invalidating a statutory mandate altogether. View "National Shooting Sports Foundation, Inc. v. State" on Justia Law

A jailer’s authority “to set a time and place for the appearance of the arrested person” under Cal. Penal Code 1269b(a) makes that appearance “lawfully required” for purposes of forfeiting bail under Cal. Penal Code 1305, former subdivision (a)(4), under which a court may declare the bail forfeited if a defendant fails to appear on “[a]ny other occasion prior to the pronouncement of judgment if the defendant’s presence in court is lawfully required.”Based on a criminal defendant’s failure to personally appear for a pretrial conference, the trial court ordered her bail forfeited. The court then granted summary judgment on the forfeited bond and sent a demand for payment to Financial Casualty & Surety, Inc. Financial Casualty moved to set aside summary judgment on the ground that the defendant was not ordered to appear at the hearing. The trial court granted the motion. The Court of Appeal affirmed. The Supreme Court reversed, holding that the defendant’s obligation to appear to the hearing was “lawfully required” under section 1305 because, when she was released on bond, the jailer set the time and place for her next appearance, as authorized under section 1269b(a). View "County of Los Angeles v. Financial Casualty & Surety, Inc." on Justia Law

At issue was how to assess the validity of a stipulation entered into by Defendant, through counsel, that admitted all of the elements of a charged crime, making it tantamount to a guilty plea, when Defendant was neither advised of, nor expressly waived, his privilege against self-incrimination or his rights to a jury trial and confrontation.The Supreme Court reversed the court of appeal’s judgment affirming Defendant’s conviction of misdemeanor driving when his driver’s license was suspended or revoked. The Court held (1) the test set forth in People v. Howard, 1 Cal.4th 1132 (1992), that a plea is valid notwithstanding the lack of express advisements and waivers if the record affirmatively shows that it is voluntary and intelligent under the totality of the circumstances applies in cases where there is a total absence of advisements and waivers; and (2) applying that test, the record failed affirmatively to show that Defendant understood his counsel’s stipulation had the effect of waiving Defendant’s constitutional rights. View "People v. Farwell" on Justia Law

At issue was how to assess the validity of a stipulation entered into by Defendant, through counsel, that admitted all of the elements of a charged crime, making it tantamount to a guilty plea, when Defendant was neither advised of, nor expressly waived, his privilege against self-incrimination or his rights to a jury trial and confrontation.The Supreme Court reversed the court of appeal’s judgment affirming Defendant’s conviction of misdemeanor driving when his driver’s license was suspended or revoked. The Court held (1) the test set forth in People v. Howard, 1 Cal.4th 1132 (1992), that a plea is valid notwithstanding the lack of express advisements and waivers if the record affirmatively shows that it is voluntary and intelligent under the totality of the circumstances applies in cases where there is a total absence of advisements and waivers; and (2) applying that test, the record failed affirmatively to show that Defendant understood his counsel’s stipulation had the effect of waiving Defendant’s constitutional rights. View "People v. Farwell" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of the first degree murder of a twelve-year-old boy, finding true the special circumstance that the murder was committed while Defendant was engaged in the commission of a lewd and lascivious act on the child, and sentencing Defendant to death.Specifically, the Court held (1) there was not substantial evidence of Defendant’s present incompetence that required the trial court, on its own motion, to declare a doubt and conduct a competence hearing during the penalty phase of trial; (2) Defendant’s constitutional challenge to the death penalty for mentally ill defendants was unavailing; (3) there was sufficient evidence of first degree murder and sufficient evidence to support a true finding on the special circumstance allegation; (4) Defendant’s argument that the trial court erred in excluding testimony regarding the victim’s relationships lacked merit; (5) the challenged jury instructions were not improper; (6) there was no reasonable possibility that the prosecutor’s comments during the penalty phase affected the jury’s verdict; and (7) Defendant’s challenges to California’s death penalty scheme failed. View "People v. Ghobrial" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of the first degree murder of a twelve-year-old boy, finding true the special circumstance that the murder was committed while Defendant was engaged in the commission of a lewd and lascivious act on the child, and sentencing Defendant to death.Specifically, the Court held (1) there was not substantial evidence of Defendant’s present incompetence that required the trial court, on its own motion, to declare a doubt and conduct a competence hearing during the penalty phase of trial; (2) Defendant’s constitutional challenge to the death penalty for mentally ill defendants was unavailing; (3) there was sufficient evidence of first degree murder and sufficient evidence to support a true finding on the special circumstance allegation; (4) Defendant’s argument that the trial court erred in excluding testimony regarding the victim’s relationships lacked merit; (5) the challenged jury instructions were not improper; (6) there was no reasonable possibility that the prosecutor’s comments during the penalty phase affected the jury’s verdict; and (7) Defendant’s challenges to California’s death penalty scheme failed. View "People v. Ghobrial" on Justia Law

In this habeas case, the Supreme Court held that Juror No. 045882, who, during Petitioner’s criminal proceedings, intentionally concealed that he had previously been convicted of public fighting and was then on probation, was not actually biased against Petitioner and that no prejudicial misconduct occurred.Petitioner was convicted of two counts of first degree murder and was sentenced to death. While his appeal was pending, Petitioner filed this habeas petition, alleging that Juror No. 045882 committed misconduct. This Court issued an order instructing the Secretary of the Department of Corrections and Rehabilitation (CDCR) to show cause why the Court should not grant Petitioner relief based on juror misconduct. A referee appointed by the Court concluded that the juror at issue was not actually biased. The Supreme Judicial Court agreed and discharged the order to show cause, holding that there was no substantial likelihood that the juror harbored actual bias against Petitioner. View "In re Cowan" on Justia Law

At issue was whether the trial court’s failure to instruct the jury on murder with malice aforethought or lesser included offenses of murder with malice aforethought, or defenses applicable to murder with malice aforethought, was harmless due to the jury’s finding true a robbery-murder special circumstance allegation.Defendants were convicted of first degree felony murder. The jury found true a special circumstance allegation that the murder was committed during a robbery. The amended information had accused Defendants of murder with malice aforethought, a term encompassing two kinds of offenses. This accusation triggered the trial court’s duty to instruct the jury on lesser included offenses of murder with malice aforethought if substantial evidence had been presented to support a jury finding of the lesser included offense rather than first degree murder. The trial court instructed the jury only on first degree felony murder and failed to instruct the jury on murder with malice aforethought, lesser included offenses of murder with malice aforethought, or on defenses applicable to murder with malice aforethought, as requested by Defendants. The Supreme Court held that the jury’s finding on the robbery-murder special circumstance rendered harmless the trial court’s instructional errors. View "People v. Gonzalez" on Justia Law