Justia Criminal Law Opinion Summaries

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

As modified in this opinion, the Supreme Court affirmed Defendant’s conviction for murdering two people during the commission of a robbery and his sentence of death.On appeal, the Supreme Court found only one error during the guilt and penalty phases of Defendant’s trial - the admission of Defendant’s pretrial statement in violation of Miranda v. Arizona, 384 U.S. 436. Specifically, the Court held that detectives violated Miranda by continuing to question Defendant after he invoked his right to remain silent, but the statements were not coerced. The Court then determined that this sole error was harmless. The Court modified the judgment of the trial court by reducing the $10,000 restitution fine to $6,000 and, as modified, affirmed the trial court’s judgment. View "People v. Case" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder, rape, and other crimes and sentencing Defendant to death.On appeal, the Court held (1) the trial court did not commit prejudicial error during jury selection; (2) no prejudicial error occurred during the guilt phase of trial; (3) none of the errors identified by the Court during the penalty phase of trial was prejudicial individually, and they did not have any cumulative effect; and (4) Defendant’s challenges to California’s death penalty law were unavailing. View "People v. Hardy" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of three counts of first degree murder, conspiracy to commit murder, second degree robbery, and assault with a firearm and sentencing Defendant to death for the three murders.On appeal, the Supreme Court held (1) no prejudicial error occurred during jury selection; (2) during the guilt phase, the Confrontation Clause was violated through the admission of certain out-of-court statements, but the errors were not prejudicial; and (3) several errors were committed during the penalty phase, including the erroneous admission of certain statements and the erroneous admission of testimony by victim family members about the appropriate penalty, but the errors did not affect the penalty phase verdict. View "People v. Penunuri" on Justia Law

The Supreme Court granted Petitioner’s petition for a writ of habeas corpus insofar as one of Petitioner’s claims alleged that he was ineligible for execution because he was intellectually disabled. The Court further vacated the judgment of the superior court in Petitioner’s criminal case to the extent it imposed a sentence of death.Petitioner was convicted of first degree murder and robbery. The jury returned a death verdict, which the court imposed. On remand from the Supreme Court, the trial court reinstated the judgment of death. The Supreme Court affirmed. Petitioner then filed this petition for writ of habeas corpus, arguing that he was ineligible for execution because he was intellectually disabled. The Supreme Court issued an order to show cause and ordered a reference hearing in the superior court. A referee found that Petitioner was intellectually disabled. The Supreme Court adopted the referee’s findings regarding intellectual functioning and adaptive behavior, holding that the findings were were substantially supported. Because Petitioner was intellectually disabled, he was entitled to relief from the death judgment under Atkins v. Virginia, 536 U.S. 304, 321 (2002), and In re Hawthorne, 35 Cal. 4th 40 (2005). View "In re Lewis" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of first degree murder, attempted voluntary manslaughter, and other offenses and sentencing Defendant to death, holding that no prejudicial error occurred during the proceedings.Specifically, the Court held (1) there was no error in the selection of the jury; (2) the trial court properly instructed the jury; (3) the trial court did not err in its evidentiary rulings; (4) the arguments raised by Defendant regarding special circumstances issues were unavailing; and (5) no prejudicial occurred during the penalty phase proceedings. View "People v. Smith" on Justia Law