Justia Criminal Law Opinion Summaries

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

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