Justia Criminal Law Opinion Summaries

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

In deciding whether a defendant is guilty of murder, the jury is permitted to consider evidence of voluntary invocation on the question of whether the defendant intended to kill but not on the question of whether he believed he needed to act in self-defense.Defendant was charged with first degree murder and first degree burglary. Defendant claimed he was guilty of, at most, voluntary manslaughter because he killed in “unreasonable self-defense” - that is, he actually believed he needed to act in self-defense even if that belief was unreasonable. The jury acquitted Defendant of first degree murder but found him guilty of second degree murder and first degree burglary. On appeal, the court of appeal concluded that the trial court erred in prohibiting the jury from considering evidence of voluntary intoxication on the question of whether Defendant believe he needed to act in self-defense, but the error was harmless. The Supreme Court disagreed, holding that the trial court correctly instructed the jury on how it could consider Defendant’s evidence of voluntary intoxication. View "People v. Soto" on Justia Law

In 2005, Chavez pleaded no contest to charges that he offered to sell a controlled substance and failed to appear after being released on his own recognizance. The trial court suspended imposition of sentence and placed Chavez on probation for four years, a term he successfully completed in 2009. In 2013, Chavez, claiming that he received ineffective assistance of counsel, asked the court to exercise its authority under Penal Code section 1385 to dismiss his previous convictions in the interests of justice. He did not seek relief under section 1203.4, which permits eligible defendants to obtain dismissal of accusations after completing probation. The trial court, court of appeal, and California Supreme Court denied him relief. A trial court would exceed the authority conferred by section 1385 if it dismissed an action after the probation period expires; a court may exercise that dismissal power before judgment is pronounced but not after judgment is final. In the case of a successful probationer, final judgment is never pronounced, and after the expiration of probation, may never be pronounced; section 1385’s power may be exercised until a judgment is pronounced or when the power to pronounce judgment runs out. View "People v. Chavez" on Justia Law

Daveggio and Michaud were each convicted of one count of first-degree murder (Pen. Code 187(a)), two counts of oral copulation in concert by force (section 288a(d)), and one count of oral copulation on a person under 18 years of age (288a(b)(1)). The jury also found true two special circumstances, kidnapping, and rape by instrument (190.2(a)(17)(B), (K)), and returned verdicts of death. The trial court denied the automatic motions to modify the verdicts and sentenced defendants to death. On automatic appeal (section1239(b)), the Supreme Court of California affirmed after recounting numerous uncharged crimes. The court upheld the denial of the defendants’ severance motions, the admission of the evidence of uncharged incidents, and evidentiary rulings concerning fingerprint evidence, carpeting in Michaud’s van, and certain weaponry. View "People v. Daveggio & Michaud" on Justia Law