Justia Criminal Law Opinion Summaries

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

The Supreme Court reversed the convictions of Defendants Edgar Octavio Barajas and Jesus Manuel Rodriguez for murder, conspiracy to commit murder, and participation in a criminal street gang, rendered by a jury after a joint trial. Each defendant was sentenced to mandatory terms amounting to fifty years to life.As to Barajas, the Supreme Court remanded with an order to enter a judgment of acquittal, holding that accomplice testimony was not sufficiently corroborated in light of People v. Romero and Self, 62 Cal.4th 1, 36 (2015).As to Rodriguez, the Court held that Rodriguez was not provided an adequate opportunity to make a record of information relevant to a future youth offender parole hearing and that he was entitled to a remand under People v. Franklin, 63 Cal.4th 261, 283-284, 286 (2016). The Court’s directive that Rodriguez receive a remand in this proceeding made it unnecessary to address his constitutional challenge to his sentence. View "People v. Rodriguez" on Justia Law

Imposing a criminal laboratory analysis fee and a drug program fee is appropriate for a conviction of conspiracy to transport a controlled substance, in violation of Cal. Health & Safety Code 11379(a).Defendant pleaded no contest to conspiracy to transport a controlled substance. As part of Defendant’s sentence, the trial court imposed a criminal laboratory analysis fee, pursuant to Cal. Health & Safety Code 11372.5(a), and a drug program fee pursuant to Cal. Health & Safety Code 11372.7(a). Defendant appealed, arguing that these fees were unauthorized because the fees were not “punishment” for purposes of the conspiracy sentencing statute - Cal. Penal Code 182(a). The court of appeal affirmed. The Supreme Court affirmed, holding that the fees at issue in this case constitute “punishment” for purposes of Penal Code section 182. View "People v. Ruiz" on Justia Law

A defendant, who has been placed on probation in one county but permanently resides in another and whose whose probation case has been transferred, must file a petition for resentencing under Proposition 47 in the original sentencing court. See Cal. Penal Code 1170.18.Defendant was placed on felony probation by the San Diego County Superior Court. Defendant lived in Riverside County, and the court transferred his case there. Defendant later filed a petition in Riverside County to recall his felony sentence and impose a misdemeanor term under Proposition 47. The Riverside court granted Defendant’s petition. The Court of Appeal affirmed. The Supreme Court reversed, holding that, even in the case of a probationary transfer, the original sentencing court is the proper venue for a resentencing petition under section 1170.18. View "People v. Adelmann" on Justia Law

The Three Strikes Reform Act of 2012 (Proposition 36), under which an inmate sentenced under the Three Strikes law for a nonferrous, nonviolent felony may petition the trial court for resentencing, permits a trial court to find a defendant was armed with a deadly weapon and is therefore ineligible for resentencing only if the prosecutor proves this basis for ineligibility beyond a reasonable doubt. Further, the trial court’s eligibility determination may rely on facts not found by a jury.One of the criteria for resentencing eligibility under Proposition 36 is that the inmate must not have been armed with a deadly weapon during the commission of the current offense. The trial court determined that Defendant was eligible for resentencing. The court of appeal reversed on the grounds that Defendant was armed with a deadly weapon during the commission of his current offense. The Supreme Court affirmed, holding that the evidence in support of Defendant’s conviction did not reasonably support any inference but that Defendant was armed with a deadly weapon during the commission of his current offense. View "People v. Perez" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of murder, two counts of attempted murder, the special circumstance of multiple murder, and various enhancements. The Court held (1) the prosecutor did not violate Defendant’s constitutional rights to equal protection and a jury drawn from a fair cross-section of the community by peremptorily excusing five black prospective jurors at the guilt phase; (2) the trial court did not violate Defendant’s constitutional rights under the Sixth Amendment and his right to due process under the Fourteenth Amendment by denying his motion for a continuance; (3) there was sufficient evidence to support Defendant’s convictions; (4) any error in the jury instructions related to eyewitness identification was harmless; (5) the trial court did not err in refusing to instruct the penalty phase retrial jury on lingering doubt; (6) the trial court did not err in not offering supplemental instructions when it was clear that the jury’s verdict was not unanimous; (7) Defendant’s challenges to the penalty phase jury instructions were unavailing; and (8) Defendant’s remaining allegations of error were without merit. View "People v. Reed" on Justia Law