Justia Criminal Law Opinion Summaries

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

The defendant was charged in adult criminal court with sex crimes allegedly committed in 2014 and 2015 when he was 14 and 15 years old. The law then in effect permitted the prosecutor to charge the case directly in adult court. After the charges were filed, the electorate passed Proposition 57, the “Public Safety and Rehabilitation Act of 2016,” prohibiting prosecutors from charging juveniles directly in adult court. Such actions must commence in juvenile court. If the prosecution wishes to try the juvenile as an adult, the juvenile court must conduct a “transfer hearing.” Only if the juvenile court transfers the matter to adult court can the juvenile be tried and sentenced as an adult (Welf. & Inst. Code, 707(a)). The Supreme Court of California held that the provision applies retroactively to all juveniles charged directly in adult court whose judgment was not final at the time it was enacted. The possibility of being treated as a juvenile in juvenile court—where rehabilitation is the goal—rather than being tried and sentenced as an adult can result in dramatically different and more lenient treatment, so Proposition 57 reduces the possible punishment for a class of persons, namely juveniles. Nothing in Proposition 57’s text or ballot materials rebuts this inference. View "People v. Superior Court" on Justia Law

During a retrial of a second degree murder charge, after a previous jury failed to reach a verdict on that charge but convicted defendant of gross vehicular manslaughter while intoxicated, the trial court erred if it informed the new jury of such specific convictions that resulted from the previous jury's deliberations. However, the trial court does not err if, pursuant to Penal Code sections 1093 and 1127, it instructs the retrial jury along the following lines: "Sometimes cases are tried in segments. The only question in this segment of the proceedings is whether the prosecution has proved the charge of murder. In deciding this question, you must not let the issue of punishment enter into your deliberations. Nor are you to speculate about whether the defendant may have been, or may be, held criminally responsible for his conduct in some other segment of the proceedings." In this case, the defense requested a specific instruction informing the jury of defendant's gross vehicular manslaughter conviction, and the trial court refused such an instruction. However, the Court of Appeal affirmed the judgment because defendant was not prejudiced by this error where the evidence was overwhelming. View "People v. Hicks" on Justia Law

Proof beyond a reasonable doubt is required to discharge the People of the burden of establishing that a petitioner is ineligible for resentencing under the Three Strikes Reform Act of 2012. The Court of Appeal reasoned that applying a reasonable doubt standard to proof of ineligibility for resentencing preserves the parallel structure between the prospective and retroactive application of the Three Strikes law as contemplated by the Reform Act. Furthermore, placing on the People a burden of proof beyond a reasonable doubt to establish ineligibility for resentencing, while permitting the court to exercise its broader discretion to protect public safety, is an approach that comports with the overall structure and language of the Act and its dual intent. View "People v. Frierson" on Justia Law

The trial court violated Defendant’s Sixth Amendment right to a jury trial when it found a disputed fact about the conduct underlying Defendant’s assault conviction that had not been established by virtue of the conviction itself.Defendant was convicted of second degree robbery and transportation of a controlled substances, among other offenses. The prosecution sought an increased sentence from the maximum term of imprisonment on the ground that Defendant had previously been convicted of a “serious felony” under Cal. Penal Code 667(a) that was also a strike for purposes of the Three Strikes law. That conviction was for assault with a deadly weapon or with force likely to produce great bodily injury. The trial court determined that Defendant did commit the assault with a deadly weapon and sentenced her to a term of eleven years’ imprisonment. On appeal, Defendant argued that her increased sentence rested upon an exercise in judicial fact-finding that violated her Sixth Amendment right to a jury trial. The Supreme Court disapproved of People v. McGee, 38 Cal.4th 682 (Cal. 2006) insofar as it suggested that the trial court’s factfinding was constitutionally permissible and held that Defendant’s increased sentence rested on an exercise in judicial fact-finding that violated her Sixth Amendment right to a jury trial. View "People v. Gallardo" on Justia Law

Defendant was found incompetent to stand trial and was involuntarily committed for three years. Defendant was never made the subject of a conservatorship. Shortly after his release, the district court obtained a superseding indictment with identical charges under a new case number, as permitted by Cal. Penal Code 1387. When Defendant was rearrested under the new indictment, he argued that because he had already been committed for the three years authorized by Cal. Penal Code 1370(c), the trial court lacked the authority to order his rearrest. The Supreme Court held (1) defendants in Defendant’s position can be rearrested on charges that are refiled under 1387; but (2) if the trial court again determines that a defendant is not competent to stand trial, the defendant may be recommitted only for a period not exceeding the remaining balance, if any, of the three years authorized by section 1370(c). View "Jackson v. Superior Court" on Justia Law