Justia Criminal Law Opinion Summaries

In May 2019, police officers detained Marlon Flores in a Los Angeles neighborhood known for narcotics and gang activity. The officers observed Flores standing alone near a parked car, ducking behind it as they approached. The officers suspected Flores was involved in narcotics activity due to his behavior and the area's reputation. During a pat-down search, the officers found a drug pipe in Flores's car and methamphetamine in his wallet. Flores was subsequently charged with carrying a loaded firearm and armed possession of methamphetamine.The trial court denied Flores's motion to suppress the evidence, reasoning that his behavior was suspicious enough to warrant detention and subsequent questioning. Flores pleaded no contest to the firearm charge, and the methamphetamine charge was dismissed. He was sentenced to three years' probation. The Court of Appeal affirmed the judgment, concluding that Flores was not detained until he was ordered to stand and put his hands behind his head, and that reasonable suspicion justified the detention.The Supreme Court of California reversed the lower courts' decisions. The court held that the officers' observations of Flores's behavior, combined with his presence in a high crime area at night, did not provide a particularized and objective basis for suspecting that Flores was engaged in illegal activity. The court emphasized that a person's mere presence in a high crime area cannot transform them into a suspect. The court concluded that the officers lacked reasonable suspicion to detain Flores, and thus, the evidence obtained during the pat-down search should have been suppressed. The case was remanded to the trial court to allow Flores to withdraw his no contest plea and for the court to grant Flores's suppression motion. View "P. v. Flores" on Justia Law

The case involves Weldon K. McDavid, Jr., who was convicted of conspiracy to commit murder and attempted premeditated murder. McDavid, a shooting instructor, had a romantic relationship with Diana Lovejoy, who was going through a contentious divorce. The two hatched a plan to kill Lovejoy's husband, Greg Mulvihill. McDavid shot Mulvihill, causing severe injuries but not killing him. The jury found true allegations that McDavid intentionally discharged a firearm, causing great bodily injury, and personally inflicted great bodily injury on the victim.McDavid appealed his sentence, arguing that the trial court was unaware of its full sentencing discretion under Senate Bill No. 620, which grants trial courts the discretion to strike formerly mandatory enhancements. The Court of Appeal agreed, vacated his sentence, and remanded the case for resentencing. However, the trial court declined to strike the enhancements. McDavid appealed again, and while the appeal was pending, the Court of Appeal held that a trial court has the authority to impose a lesser enhancement not only under section 12022.53 but also under other statutes if the facts supporting the lesser enhancement were alleged and found true by a jury. The Attorney General filed a petition for rehearing, which the Court of Appeal granted. On rehearing, the Court of Appeal reversed course and held that a trial court’s discretion to impose a lesser included, uncharged enhancement is confined to the enhancements in section 12022.53 and does not include enhancements specified in other statutes.The Supreme Court of California reversed the judgment of the Court of Appeal. The court held that when a court has exercised its discretion under subdivision (h) to strike a section 12022.53 enhancement and finds that no other section 12022.53 enhancement is appropriate, the second sentence of subdivision (j) is inapplicable and does not bar the court from imposing a lesser included, uncharged enhancement under a law other than section 12022.53. The court thus has discretion to impose such an enhancement if it is supported by facts that have been alleged and found true. The case was remanded for further proceedings consistent with this opinion. View "People v. McDavid" on Justia Law

The Supreme Court of California was asked to interpret a witness dissuasion statute, Penal Code section 136.1, subdivision (b)(2), in a case involving defendant Raymond Gregory Reynoza. Reynoza was found guilty of violating this statute based on actions that occurred after the complaint in the underlying criminal case had been filed. The court had to determine whether the statute applies where a defendant dissuades a witness from “assisting in the prosecution” of a case after the charging document has already been filed, or whether a conjunctive interpretation precludes a conviction under such circumstances.The lower courts had disagreed on the interpretation of the statute. The Court of Appeal held that section 136.1(b)(2) requires proof that the defendant attempted to prevent or dissuade another person from causing an accusatory pleading to be filed. If the defendant was aware the relevant charging document had already been filed, and the defendant did not attempt to prevent or dissuade the filing of any amended or subsequent charging document, the defendant has not violated section 136.1(b)(2).The Supreme Court of California found that the statute is equally susceptible to both the conjunctive and disjunctive constructions. Therefore, the rule of lenity counsels in favor of adopting the “interpretation more favorable to the defendant.” Here, that is the conjunctive construction, which does not permit a conviction to be based solely on proof of dissuasion from “assisting in the prosecution” of an already-filed charging document. Because there is no dispute that Reynoza’s conduct amounted to, at most, dissuasion after a complaint was filed, the court affirmed the judgment of the Court of Appeal reversing his conviction. View "P. v. Reynoza" on Justia Law

In California, the People v. Hardin case involves the defendant, Tony Hardin, who is serving a life sentence without parole for a special circumstance murder he committed at age 25. Hardin challenged the constitutionality of a California statute that provides parole hearings for most young adult offenders but excludes those serving life sentences without parole for crimes committed after turning 18.The Supreme Court of California found that the legislature acted rationally in distinguishing between young adults serving life sentences without parole and those serving parole-eligible sentences for crimes committed when they were young. The court reasoned that the legislature's decision to exclude certain offenders from parole hearings reflected a balance of multiple considerations, including the seriousness of the offender's crimes and the capacity of all young adults for growth.The court stated that while the primary purpose of the statute was to provide opportunities for early release to certain young adults, the legislature also considered other factors. It could rationally balance the seriousness of the offender's crimes against the capacity of all young adults for growth, and determine that young adults who have committed certain very serious crimes should remain ineligible for release from prison.The court also noted that it is the legislature's prerogative and duty to define degrees of culpability and punishment and to distinguish between crimes. Therefore, Hardin's argument that the statute violates the Fourteenth Amendment’s equal protection guarantee by irrationally discriminating against young adult offenders sentenced to life without parole was dismissed, and the judgment of the Court of Appeal was reversed. View "P. v. Hardin" on Justia Law

In this case, the Supreme Court of California was asked to interpret the "collective engagement" requirement under the California Penal Code section 186.22(f) and its application to the proof of predicate offenses. This requirement was introduced through Assembly Bill 333, which amended gang sentencing provisions. The defendant, Kejuan Darcell Clark, a member of the Northside Parkland street gang, was charged with several offenses related to a home invasion and assault. The prosecution sought to apply gang enhancements under section 186.22, subdivision (b).The court held that the term "collective engagement" in section 186.22(f) does not require that each predicate offense must have been committed by at least two gang members acting in concert. Rather, the court interpreted the term to require a showing that links the two predicate offenses to the gang as an organized, collective enterprise. This can be demonstrated by evidence linking the predicate offenses to the gang's organizational structure, its primary activities, or its common goals and principles.The court reversed the judgment of the Court of Appeal as to Clark's gang enhancement and remanded the case for further proceedings to apply this interpretation of the collective engagement requirement. View "P. v. Clark" on Justia Law

In 2019, the California Supreme Court ruled that the defendant, Oscar Manuel Vaquera, did not receive fair notice of the sentence that the prosecution was seeking in his case, which violated his right to due process. Vaquera was charged with two counts of a sex offense covered by California's "One Strike" law and was convicted on both counts. In the habeas corpus proceeding, Vaquera challenged the 25-year-to-life sentence the trial court imposed for the second count.The prosecution had initially requested a sentence of 15 years to life for the second count, but later argued for a 25-year-to-life sentence under a different provision of the One Strike law. Vaquera contended that the imposition of the 25-year-to-life sentence violated due process because he did not receive fair notice that the prosecution intended to seek that sentence. The California Supreme Court agreed with Vaquera and ordered the trial court to resentence him to 15 years to life for the second count.The Court ruled that the One Strike allegation in Vaquera's case did not provide him with fair notice that the prosecution was seeking a 25-year-to-life sentence under the specific provision of the law based on the victim's age. The Court held that due process requires an accusatory pleading to inform the defendant of the particular One Strike sentence the prosecution is seeking and of the factual basis it intends to prove to support that sentence. In this case, the prosecution did not provide fair notice of its intent to seek the longer One Strike sentence, which violated Vaquera's due process rights. View "In re Vaquera" on Justia Law

In the Supreme Court of California, the defendant, Glen Taylor Helzer, pleaded guilty to five counts of murder and multiple other charges, including robbery, kidnapping, and conspiracy. After a penalty trial, the jury sentenced him to death for the five counts of murder. The murders were particularly gruesome, involving kidnapping, robbery, and dismemberment of the bodies. The defendant argued that he was under the influence of methamphetamine and suffering from a mental or emotional disturbance at the time of the crimes. On appeal, the defendant raised several issues, including the exclusion of a potential juror due to their views on the death penalty, the denial of a proposed question during jury selection, and the admission of graphic evidence including photographs of the dismembered bodies and the sound of a power saw used in the dismemberment during the prosecution's closing argument. The court affirmed the judgment, finding that the trial court did not abuse its discretion in its rulings and that any error was harmless. The court held that the photographs and the sound of the saw were relevant to the circumstances of the crimes and did not unduly prejudice the jury. The court also held that the removal of a potential juror due to their views on the death penalty did not violate the defendant's right to a representative jury. View "People v. Helzer" on Justia Law

In the case of The People v. Fernando Rojas, the Supreme Court of California addressed the issue of whether the application of Assembly Bill 333 to the gang-murder special circumstance in section 190.2(a)(22) of the California Penal Code constituted an unlawful amendment of Proposition 21, which had previously defined the term "criminal street gang".The defendant, Fernando Rojas, was convicted of first degree murder and was found to have committed the crime while being an active participant in a criminal street gang, which made him subject to life imprisonment without the possibility of parole under section 190.2(a)(22). While Rojas's appeal was pending, the state legislature passed Assembly Bill 333, which substantially narrowed the definition of "criminal street gang" for the purposes of section 190.2(a)(22).The lower courts disagreed on whether the application of Assembly Bill 333 would constitute an unlawful amendment of Proposition 21, which had been passed by the voters and was therefore protected from legislative amendment without a two-thirds majority vote of each house of the legislature or approval by the voters.The Supreme Court of California concluded that the application of Assembly Bill 333 to the gang-murder special circumstance did not violate the limitation on legislative amendment in Proposition 21. The Court reasoned that the voters who enacted Proposition 21 intended to impose a specific punishment for gang-related murder while relying on an existing statutory provision to define "criminal street gang". The Court found no indication that the voters intended to adopt a fixed definition of "criminal street gang" and held that applying Assembly Bill 333's narrower definition did not change the punishment for those convicted of the gang-murder special circumstance. Therefore, the Court reversed the judgment of the Court of Appeal and remanded the case for further proceedings. View "P. v. Rojas" on Justia Law

In the case, a defendant, Mario Rodriguez, was charged with several felonies, each carrying a maximum sentence exceeding two years. In 2018, Rodriguez was found mentally incompetent to stand trial and committed to a state hospital. After a certificate indicating his restoration to competency was filed within the two-year time limit, Rodriguez was returned to court. However, due to COVID-19 restrictions, his hearing to confirm his competency did not take place within the two-year period. Rodriguez sought to dismiss the charges against him, claiming the time for commitment had run out.The Supreme Court of California held that under the relevant statutes, the time between the filing of a certificate of restoration of mental competency and the court's ruling on that certificate counts towards the two-year maximum commitment period mandated by section 1370(c)(1) of the California Penal Code. Therefore, the filing of a certificate of restoration does not end the period of mental incompetency commitment.The court sent the case back to the Court of Appeal to decide whether the two-year limit was exceeded in this case, and if so, what remedy Rodriguez might be entitled to. The court did not decide whether Rodriguez was entitled to the remedy of dismissal he sought, or whether and how the issue of tolling may affect Rodriguez's entitlement to any relief. View "Rodriguez v. Super. Ct." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Petitioner's petition for relief and resentencing under the new procedure set forth in Senate Bill No. 1437 (former Cal. Penal Code 1170.95, subd. (a); now Cal. Penal Code 1172.6, subd. (a)), holding that the trial court erred.Petitioner was convicted of first degree murder and sentenced to life imprisonment without the possibility of parole. Twelve years later, the Legislature enacted Senate Bill 1437 narrowing or eliminating certain forms of accomplice liability for murder. Petitioner petitioned for relief and resentencing under the new procedure, but the trial court denied the petition for failure to state a prima facie case. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court erred in rejecting Petitioner's prima facie showing and should have proceeded to an evidence hearing on Petitioner's resentencing petition. View "People v. Curiel" on Justia Law