Justia Criminal Law Opinion Summaries

Petitioner was charged with robbery. Pursuant to a plea agreement, Petitioner pleaded guilty to grand theft from the person, a felony, and admitted a prior robbery conviction on condition that he receive a six-year prison sentence. The People, in return, dismissed the robbery charge. The electorate later enacted Proposition 47, which reduced the grand theft offense to a misdemeanor. Defendant filed a petition for recall of sentence, asking the trial court to resentence him as a misdemeanant. The trial court denied relief, concluding that reducing the sentence would deprive the People of the benefit of their plea bargain, and thus they should be permitted to rescind the plea and reinstate the original robbery charge. The Court of Appeal affirmed. The Supreme Court reversed, holding that the People were not entitled to set aside the plea agreement when Defendant sought to have his sentence recalled under Proposition 47. View "Harris v. Superior Court of Los Angeles County" on Justia Law

Petitioner, an inmate, filed a petition for writ of habeas corpus, alleging that he received ineffective assistance of counsel in his criminal proceedings. One week later, Petitioner asked the court clerk for the name of the judge assigned to his petition. Superior Court Judge John M. Thompson subsequently summarily denied Petitioner’s habeas corpus petition. Petitioner then filed a new petition for writ of habeas corpus, and, in addition, Petitioner alleged that he was denied his statutory right to peremptorily challenge Judge Thompson. The Court of Appeal issued a writ of mandate directing the superior court to reassign the assessment of Maas’s petition for writ of habeas corpus to a judge other than Judge Thompson. The Supreme Court affirmed, holding that a petitioner who requests the name of the judge assigned to examine his habeas corpus petition is entitled to notice of that assignment and is entitled to peremptorily challenge the assigned judge, so long as all of the procedural requirements of Cal. Civ. Proc. Code 170.6 have been satisfied. View "Maas v. Superior Court" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder and related crimes. After the penalty phase of the trial, the jury returned a verdict of death. The Supreme Court reversed the judgment of death, remanded the matter for a new penalty determination and reconsideration of the question of a restitution fine under the currently applicable statute, and affirmed the judgment in all other respects, holding (1) no prejudicial error occurred during the guilt phase of trial; (2) the trial court erred in excusing a prospective juror for cause under Witt based solely on written questionnaire responses regarding his views on capital punishment, and therefore, the penalty judgment must be reversed for error under Wainwright v. Witt and Witherspoon v. Illinois; and (3) the question of Defendant’s restitution fine must be remanded for reconsideration because Defendant’s restitution fine was imposed pursuant to a statute that was subsequently repealed in its entirety and replaced by a statute lessening punishment. View "People v. Covarrubias" on Justia Law

Defendant was charged with criminal offenses. Defendant filed a renewed motion to suppress pursuant to Cal. Penal Code 1538.5(i). Judge Vincent Chiarello granted the renewed motion, and the case was dismissed at the People’s request. Thereafter, the People filed a new complaint alleging the same offenses. Defendant filed a motion to suppress, asserting that the proper venue for the motion was before Judge Chiarello pursuant to section 1538.5(p). The matter came before Judge Vanessa Zecher after Judge Jerome Nadler concluded that Judge Chiarello was not available. Judge Zecher denied Defendant’s motion. Defendant filed a renewed motion to suppress, arguing that Judge Chiarello should have heard the relitigated motion to suppress. The trial court concluded that a renewed motion to suppress under section 1538.5(i) was not the proper vehicle for setting aside Judge Zecher’s order. Defendant was found guilty of child pornography. The Court of Appeal affirmed. The Supreme Court reversed, holding (1) a trial court’s discretion to make determinations concerning the availability of judges must be exercised in a manner consistent with constraints imposed by section 1538.5(p); and (2) in this case, the trial court abused its discretion by not taking reasonable measures to ensure compliance with section 1538.5(p), and the error was prejudicial. View "People v. Rodriguez" on Justia Law

Defendant was charged by criminal complaint with unpermitted use of a suction dredge. Suction dredging is a technique used by miners to remove matter from the bottom of waterways, extract minerals, and return the residue to the water. Defendant demurred, arguing (1) state law aimed at environmental conservation effectively banned suction dredging in California, thereby preventing him from using the only commercially practicable method of extracting gold from his mining claim; and (2) because federal law promoted mining on federal land, the state’s contrary legislation should be preempted. The trial court overruled the demurrer. The Court of Appeal reversed and remanded for consideration of additional evidence and argument. The Supreme Court reversed, holding that Congress did not guarantee miners a right to mine immunized from exercises of the states’ police powers. View "People v. Rinehart" on Justia Law

After a jury trial, Defendant was convicted of one count each of murder, robbery, burglary, conspiracy to commit robbery, conspiracy to commit burglary, and the unlawful driving or taking of a vehicle. The trial court sentenced Defendant to death for the murder. Defendant appealed, arguing that the trial court erred in excluding certain statements made by the actual killer of the murder victim in which the killer claimed that he acted alone in committing the murder and that Defendant was not involved. Specifically, Defendant asserted that the hearsay statements were admissible as declarations against interest. The Supreme Court reversed the judgment of death, holding that the trial court erred in excluding the testimony and that the error was harmless at the guilt phase but was not harmless at the penalty phase. View "People v. Grimes" on Justia Law

After a jury trial, Defendant was convicted of both larceny and embezzlement based on the same course of conduct. The Court of Appeal struck Defendant’s larceny conviction, holding that a defendant cannot be convicted of both larceny and embezzlement for the same course of conduct because they not “different offenses” within the meaning of Cal. Penal Code 954. The Supreme Court affirmed, holding (1) larceny and embezzlement are different statements of the same offense within the meaning of section 954; and (2) section 954 does not permit multiple convictions for different statements of the same offense. View "People v. Vidana" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The jury also found true the special circumstance allegations that Defendant committed multiple murders and that the murders were committed while lying in wait. The jury was unable to reach a penalty verdict, and a second penalty phase was held. The jury returned a verdict of death, and the trial court entered a judgment of death. The Supreme Court (1) reversed the lying-in-wait special-circumstance, holding that the evidence was insufficient to support the inference that Defendant arrived at the murder scene before the victims arrived; (2) reversed the penalty judgment and remanded for retrial of the penalty phase, holding that the trial court’s investigation into the penalty phase retrial jury’s announce deadlock was so intrusive that it prejudicially invaded the deliberations and created a coercive effect on those deliberations; and (3) otherwise affirmed the convictions. View "People v. Nelson" on Justia Law

In 1981, Appellant was convicted of murder and sentenced to death. The Supreme Court reversed the penalty verdict. At the penalty retrial, the jury again sentenced Appellant to death, but the trial court modified the sentence to life imprisonment without the possibility of parole. The case was again remanded. On remand, the judge denied the motion to modify the verdict. On appeal, the Supreme Court vacated the death judgment and remanded for another hearing on Appellant’s application to modify the verdict. On remand, the trial court granted Appellant’s request to represent himself but denied his application to modify the verdict. The court then reinstated the death judgment. The Supreme Court vacated the judgment and remanded for another hearing on the application for modification of the death penalty verdict. On remand, the judge denied Appellant’s application to modify the verdict. On appeal, the Supreme Court affirmed the death judgment, holding (1) the trial court did not err in granting Appellant’s request to represent himself; and (2) Appellant forfeited his second claim on appeal. View "People v. Burgener" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder, two counts of premeditated attempted murder, and other crimes. The jury returned death verdicts as to all three murders, and the trial court sentenced Defendant to death. During guilt phase deliberations, the trial court discharged a juror for refusing to deliberate. On appeal, Defendant argued that the court erred in dismissing the juror. The Supreme Court reversed the judgment in its entirety, holding (1) because there was not a “demonstrable reality” that there was good cause to discharge the juror, the court abused its discretion in removing the juror; and (2) the error was prejudicial and required reversal of the judgment. View "People v. Armstrong" on Justia Law