Justia Criminal Law Opinion Summaries

The Supreme Court granted Petitioner’s petition for writ of habeas corpus and vacated the judgment of conviction because false evidence was introduced at trial.Petitioner, Vincente Benavides Figueroa, was convicted of murder - committed with the special circumstances of felony-murder rape sodomy, and lewd conduct - and rape, sodomy, and lewd conduct. Petitioner was sentenced to death. Petitioner later filed a petition or habeas corpus relief, asserting that false evidence, now repudiated or undermined, resulted in his convictions and the special circumstances findings. The Supreme Court issued an order to show cause on Petitioner's claims that his convictions were based on false evidence and that he received ineffective assistance of counsel. Respondent, the Secretary of the Department of Corrections and Rehabilitation, conceded that Petitioner was entitled to relief based upon the introduction of false evidence and argued that the murder conviction should be revised from first to second degree. The Supreme Court disagreed and vacated the judgment in its entirety, holding that a reduction to second degree murder was not warranted. View "In re Figueroa" on Justia Law

The Supreme Court granted Petitioner’s petition for writ of habeas corpus and vacated the judgment of conviction because false evidence was introduced at trial.Petitioner, Vincente Benavides Figueroa, was convicted of murder - committed with the special circumstances of felony-murder rape sodomy, and lewd conduct - and rape, sodomy, and lewd conduct. Petitioner was sentenced to death. Petitioner later filed a petition or habeas corpus relief, asserting that false evidence, now repudiated or undermined, resulted in his convictions and the special circumstances findings. The Supreme Court issued an order to show cause on Petitioner's claims that his convictions were based on false evidence and that he received ineffective assistance of counsel. Respondent, the Secretary of the Department of Corrections and Rehabilitation, conceded that Petitioner was entitled to relief based upon the introduction of false evidence and argued that the murder conviction should be revised from first to second degree. The Supreme Court disagreed and vacated the judgment in its entirety, holding that a reduction to second degree murder was not warranted. View "In re Figueroa" on Justia Law

Resentencing is available to defendants who were serving felony sentences on Proposition 47’s effective date but whose judgments were on appeal and thus not yet final only in accordance with the statutory resentencing procedure in Cal. Penal Code 1170.18.Approved by voters in 2014, Proposition 47 reduces many theft- and drug-related offenses from felonies to misdemeanors for offender who do not have prior convictions for specified violent or serious offenses. Proposition 47 also permits eligible defendants who were serving felony sentences as of Proposition 47’s effective date to obtain the benefit of these changes by petition for resentencing. The resentencing petition must be granted unless the court determines that resentencing a defendant would pose an unreasonable risk of danger to public safety. At issue was whether defendants whose judgments were not yet final were entitled to automatic resentencing under Proposition 47 or whether these defendants must seek resentencing through the statutory resentencing procedure. The Supreme Court held the latter. View "People v. DeHoyos" on Justia Law

Resentencing is available to defendants who were serving felony sentences on Proposition 47’s effective date but whose judgments were on appeal and thus not yet final only in accordance with the statutory resentencing procedure in Cal. Penal Code 1170.18.Approved by voters in 2014, Proposition 47 reduces many theft- and drug-related offenses from felonies to misdemeanors for offender who do not have prior convictions for specified violent or serious offenses. Proposition 47 also permits eligible defendants who were serving felony sentences as of Proposition 47’s effective date to obtain the benefit of these changes by petition for resentencing. The resentencing petition must be granted unless the court determines that resentencing a defendant would pose an unreasonable risk of danger to public safety. At issue was whether defendants whose judgments were not yet final were entitled to automatic resentencing under Proposition 47 or whether these defendants must seek resentencing through the statutory resentencing procedure. The Supreme Court held the latter. View "People v. DeHoyos" on Justia Law

The Supreme Court reversed Defendant’s conviction for conspiracy to murder Dean Noyes for lack of territorial jurisdiction and affirmed in all other respects the judgment convicting Defendant of first degree murder and conspiracy to murder his wife, Carole Garton, and her fetus. The Supreme Court held (1) any error in the trial court’s ruling prohibiting Defendant from wearing his wedding ring during trial was harmless; (2) the trial court did not err by allowing the prosecution’s investigating officers to bypass metal detectors while entering the courthouse; (3) Defendant was not prejudiced by the introduction of hearsay statements by the county coroner concerning the state of Carole’s body and her cause of death; (4) the trial court erred in finding that it had jurisdiction over the charge that Defendant conspired to murder Dean in Oregon; (5) any error in the trial court’s instructions to the jury was harmless; (6) the trial court did not err in denying Defendant’s motion for entry of judgment of acquittal; and (7) there was no cumulative error requiring reversal of Defendant’s convictions. View "People v. Garton" on Justia Law

The Supreme Court reversed Defendant’s conviction for conspiracy to murder Dean Noyes for lack of territorial jurisdiction and affirmed in all other respects the judgment convicting Defendant of first degree murder and conspiracy to murder his wife, Carole Garton, and her fetus. The Supreme Court held (1) any error in the trial court’s ruling prohibiting Defendant from wearing his wedding ring during trial was harmless; (2) the trial court did not err by allowing the prosecution’s investigating officers to bypass metal detectors while entering the courthouse; (3) Defendant was not prejudiced by the introduction of hearsay statements by the county coroner concerning the state of Carole’s body and her cause of death; (4) the trial court erred in finding that it had jurisdiction over the charge that Defendant conspired to murder Dean in Oregon; (5) any error in the trial court’s instructions to the jury was harmless; (6) the trial court did not err in denying Defendant’s motion for entry of judgment of acquittal; and (7) there was no cumulative error requiring reversal of Defendant’s convictions. View "People v. Garton" on Justia Law

The Supreme Court affirmed Defendant’s convictions for murder, residential robbery, residential burglary, and vehicle theft and Defendant’s sentence of death for the murder, holding that any potential error was harmless and that none of the potential errors were cumulatively prejudicial.On appeal, the Supreme Court held (1) Defendant failed to establish that any conflict of interest adversely affected his counsel’s performance; (2) any error resulting from Defendant’s absence from two discussions about counsel’s supposed conflict of interest was harmless beyond a reasonable doubt; (3) any challenged comments made by the judge did not disqualify the judge from presiding over the trial; (4) the trial judge’s choice to limit counsel’s time to question jurors during voir dire was not an abuse of discretion; (5) the trial court did not abuse its discretion in choosing to remove a seated juror during the guilt phase proceedings; (6) the prosecutor did not engage in impermissible misconduct; (7) any error in the trial court’s evidentiary rulings was harmless beyond a reasonable doubt; (8) any error in the trial court’s instructions to the jury was harmless; and (8) Defendant’s sentence did not violate the Eighth Amendment’s requirement of proportionate sentencing. View "People v. Perez" on Justia Law

The sentences imposed on Defendants, two juvenile nohomicide offenders, violated the Eighth Amendment as interpreted in People v. Caballero, 55 Cal.4th 262, 268 (2012) and Graham v. Florida, 460 U.S. 48 (2010).Defendants, Leonel Contreras and William Rodriguez, were convicted in a joint trial of kidnapping and sexual offenses that they committed when they were sixteen years old. Contreras was sentenced to a term of fifty-eight years to life, and Rodriguez was sentenced to a term of fifty years to life. The Court of Appeal affirmed Defendants’ convictions but reversed their sentences and remanded for resentencing, holding that Defendants’ sentences fell short of giving them a realistic chance for release, as contemplated by Graham. The Supreme Court affirmed, holding that Defendants’ sentences violated the Eighth Amendment under the standards articulated in Graham. The court directed the sentencing court, upon resentencing, any mitigating circumstances of Defendants’ lives and crimes and the impact of any new legislation and regulations on appropriate sentencing. View "People v. Contreras" on Justia Law

The sentences imposed on Defendants, two juvenile nohomicide offenders, violated the Eighth Amendment as interpreted in People v. Caballero, 55 Cal.4th 262, 268 (2012) and Graham v. Florida, 460 U.S. 48 (2010).Defendants, Leonel Contreras and William Rodriguez, were convicted in a joint trial of kidnapping and sexual offenses that they committed when they were sixteen years old. Contreras was sentenced to a term of fifty-eight years to life, and Rodriguez was sentenced to a term of fifty years to life. The Court of Appeal affirmed Defendants’ convictions but reversed their sentences and remanded for resentencing, holding that Defendants’ sentences fell short of giving them a realistic chance for release, as contemplated by Graham. The Supreme Court affirmed, holding that Defendants’ sentences violated the Eighth Amendment under the standards articulated in Graham. The court directed the sentencing court, upon resentencing, any mitigating circumstances of Defendants’ lives and crimes and the impact of any new legislation and regulations on appropriate sentencing. View "People v. Contreras" on Justia Law

Chatman, convicted of robbery in 2001, was sentenced to five years of felony probation plus 180 days in jail. Two years later, Chatman was convicted of misdemeanor reckless driving with alcohol. In 2006-2007 both convictions were dismissed under Penal Code section 1203.4. In 2008, Chatman was convicted of misdemeanor driving under the influence and was sentenced to three years of probation plus 10 days of imprisonment. In 2014, Chatman was offered a job that required a community care license from the Department of Social Services. Although Chatman’s robbery conviction bars him from obtaining that license, the Department may grant an exemption if a prospective employee has a Section 4852.01 certificate of rehabilitation (Health & Saf. Code 1522(g)(1)(A)(ii)). Once former probationers have their convictions dismissed under section 1203.4, section 4852.01 renders them ineligible for a certificate of rehabilitation if they are subsequently incarcerated. Former prisoners –– whether subsequently incarcerated or not –– face no such restriction. Chatman claimed that the unequal treatment was unconstitutional. The Supreme Court of California rejected that argument. Section 4852.01’s eligibility criteria survive rational basis review. Former probationers, as opposed to former prisoners, can seek some relief from the effects of their convictions through section 1203.4, and so have less relative need for certificate of rehabilitation relief. Instead of choosing an arbitrary means of limiting access to certificates, legislators used subsequent incarceration as a means of determining which former probationers show the most promise for rehabilitation. View "People v. Chatman" on Justia Law