Justia Criminal Law Opinion Summaries

Defendant pleaded no contest to second degree burglary and having served a prior prison term for vehicle theft. Defendant was sentenced to probation on conditions including a year in jail and a condition that he not enter the premises or adjacent parking lot of any Home Depot store in California. The appellate court struck the challenged probation condition, concluding that the condition was unconstitutionally overbroad. The court also suggested that the condition violated Defendant’s constitutional right to travel. The Supreme Court reversed, holding (1) the probation condition at issue was reasonably related to Defendant’s crime and to preventing future criminality, rendering it permissible under state law; and (2) the condition did not implicate Defendant’s right to travel and thus was constitutionally permissible. View "People v. Moran" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, first degree burglary, and first degree robbery. The jury was unable to reach a penalty verdict, and after the penalty phase was retried with a new jury, the trial court sentenced Defendant to death for the murder conviction and to 212 years to life on the remaining counts. The Supreme Court remanded the case to the trial court to recalculate the noncapital portion of Defendant’s sentence but affirmed the judgment in all other respects, holding (1) there was no prejudicial error in the trial court’s pretrial rulings; (2) the trial court erred in imposing consecutive sentences for certain sex crimes because they were committed against a single victim on a single occasion; and (3) no other prejudicial error occurred during the guilt phase and penalty phase of trial. View "People v. Jackson" on Justia Law

Defendant was charged with the unlawful taking of a vehicle and receiving stolen property. The complaint also contained a gang enhancement allegation under Cal. Penal Code 186.22(b) that exposed Defendant to up to an additional four years in prison. Defendant pleaded guilty to the charges, and the trial court accepted the defense invitation to dismiss the gang enhancement allegation under Cal. Penal Code 1385(a). The District Attorney appealed, arguing that, by enacting section 186.22(g), the Legislature intended to eliminate a trial court’s section 1385(a) discretion to dismiss or strike entirely a section 186.22(b) gang enhancement. Because the trial court failed to state its reasons for the gang enhancement dismissal, the Court of Appeal remanded the case to allow the trial court to do so, and otherwise affirmed the trial court’s judgment. The Supreme Court affirmed, holding (1) a trial court has the discretion under section 1385(a) to strike entirely a sentencing enhancement under section 186.22(b)(1) for a gang-related offense; and (2) because the trial court orally statement its reasons for dismissing the gang enhancement on the record, no remand was required. View "People v. Fuentes" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first degree murder and one count of second degree murder with the personal use of a firearm, among other crimes. A mistrial was declared after the first penalty trial. After a second penalty trial, the jury fixed the penalty as death. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding that there was no prejudicial error during the guilt phase of trial or the penalty phase of trial, and Defendant’s challenges to California’s death penalty scheme were unavailing. View "People v. Simon" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and robbery. The jury returned a verdict of death following the penalty phase trial. The Supreme Court reversed the death judgment but otherwise affirmed, holding (1) the evidence was sufficient to support the convictions; (2) the trial court did not err in denying Defendant’s request to subpoena Defendant’s brother, who was originally charged together with Defendant; (3) the trial court did not err in excluding a segment from Defendant’s brother’s videotaped interview; (4) the prosecution did not violate its statutory or constitutional discovery violations; (5) the trial court did not err in instructing the jury, and even if error occurred, the error was not prejudicial; (6) the trial court did not err in failing to suppress Defendant’s statements to police; (7) the trial court did not err by failing to discharge a certain juror at the guilt phase; but (8) there was error in the death-qualification of the jury. View "People v. Zaragoza" on Justia Law

Defendant was charged with a number of criminal violations. Defendant was represented by seven different appointed counsel over the course of approximately two years and made repeated requests for continuances. When his trial finally commenced, Defendant moved to dismiss his public defender and represent himself pursuant to Faretta v. California. The trial court granted the request but did not grant Defendant’s motion for a one-day continuance. Defendant failed to appear in court for the next day of trial. The trial court chose not to revoke Defendant’s status as his own counsel and did not reappoint counsel to represent him. The court then proceeded with the trial in Defendant’s absence. The jury convicted Defendant of some of the charges. The Court of Appeal reversed, concluding that the trial court erred by proceeding with trial in Defendant’s absence and without the reappointment of defense counsel and abused its discretion by denying Defendant’s motion for a one-day continuance. The Supreme Court reversed, holding that the trial court (1) acted within its discretion in proceeding with the trial after Defendant waived his constitutional right to counsel and his constitutional right to be present; and (2) did not abuse its discretion in denying Defendant’s request for a one-day continuance. View "People v. Espinoza" on Justia Law

After a jury trial, Defendant was convicted of several firearm-related and gang-related offenses. Defendant appealed, arguing that the trial court erred by admitting case-specific statements related by the prosecution expert concerning Defendant’s gang membership. Specifically, Defendant argued that the admission of this evidence violated the federal confrontation clause because the declarants were not unavailable and he had not previously cross-examined them. The Supreme Court reversed the jury findings on the street gang enhancements, holding that the admission of the case-specific statements constituted inadmissible hearsay under California law, and the error was not harmless beyond a reasonable doubt. Remanded. View "People v. Sanchez" on Justia Law

Defendant was convicted of driving under the influence of alcohol and related offenses. The trial court sentenced Defendant under the Three Strikes law to an indeterminate term of twenty-five years to life. While Defendant’s appeal was pending, voters enacted the Three Strikes Reform Act of 2012, which amended the law to reduce the punishment prescribed for certain third strike defendants. The court of appeals subsequently affirmed. Defendant petitioned for rehearing, requesting that he be resentenced under the new sentencing provisions of the Three Strikes law. The court denied relief. Defendant appealed, arguing that he was entitled to automatic resentencing under the revised penalty provisions of the Act without a determination by the trial court as to whether that resentencing would pose “an unreasonable risk of danger to public safety.” The Supreme Court affirmed, holding that prisoners presently serving indeterminate life sentences imposed under the prior version of the Three Strikes law, including those with nonfinal judgments, may seek resentencing under the Act, but subject to judicial determination of whether resentencing would pose an unreasonable danger to the public. View "People v. Conley" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first degree murder. The jury found true five special-circumstance allegations, including that Defendant committed murder while engaged in the commission of a burglary and while in the attempted commission of a robbery. At a penalty phase retrial, the jury returned a verdict for death. The trial court sentenced Defendant to death. The Supreme Court vacated the burglary-murder and robbery-murder special-circumstance findings but otherwise affirmed the judgment in its entirety, holding (1) there was no prejudicial error in the selection of the jury; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) prosecutorial misconduct did not occur in this case; (4) the trial court did not err in instructing the jury during the guilt phase; (5) the evidence was insufficient to support the jury’s true findings as to two special-circumstances pertaining to one murder; (6) the evidence was sufficient to support the jury’s true findings as to the remaining special-circumstances allegations; and (7) there was no prejudicial error during the penalty phase of trial. View "People v. Clark" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, first degree burglary with use of a knife, and assault causing great bodily injury. Defendant appealed, arguing that the trial court violated his Sixth and Fourteenth Amendment rights by terminating his right to self-representation. The court’s rationale was that Defendant had been “dilatory” and had been “stalling.” The Supreme Court reversed, holding that the district court’s order was an abuse of discretion where the record was bereft of information to support the trial court’s revocation of Defendant’s pro per status, and thus, Faretta v. California and its progeny required reversal of the judgment. View "People v. Becerra" on Justia Law