Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of murder and attempted premeditated murder, among other crimes. After a penalty phase, the jury returned a death verdict. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) as to issues arising during the guilt phase, (i) there was sufficient evidence to support the first degree murder conviction and the lying-in-wait special circumstance, (ii) the trial court did not err in its evidentiary rulings, and (iii) the instructions to the jury were proper; (2) as to issues arising during the penalty phase, (i) the trial court erred in admitting certain evidence, but the error was harmless, (ii) the admission of evidence of Defendant’s juvenile misconduct in aggravation was not error, (iii) the imposition of the death penalty based on a sole lying-in-wait special circumstance renders a defendant eligible for the death penalty, and (iv) California’s death penalty law is not unconstitutional. View "People v. Casares" on Justia Law

Elshaddai Bent was charged with felony drunk driving. His bail was set at $25,000, and the bail bond was executed by Safety National Casualty Company. When Bent failed to appear at a pretrial hearing the trial court ordered that his bail be forfeited. Safety National moved to vacate the bail forfeiture on the grounds that Bent was not ordered to appear at the hearing, nor was his presence at the hearing required by law. The trial court denied the motion. The Court of Appeal reversed, holding that Cal. Pen. Code 977(b)(1) did not provide a basis for Bent's mandatory appearance that the hearing. The Supreme Court reversed, holding that, unless a defendant fails to execute a written waiver of personal presence, or has a sufficient excuse for his or her absence at a scheduled pretrial proceeding, the trial court must declare any bail forfeited under section Cal. Pen. Code 1305(a). View "People v. Safety Nat’l Cas. Corp." on Justia Law

After a jury trial, Defendant was convicted of first degree murder, conspiracy to commit murder, and as an accessory after the fact. After a penalty phase trial, the jury returned a verdict of death. The Supreme Court affirmed the judgment, holding (1) sufficient evidence supported the first degree murder verdict based on the theory of lying in wait; (2) the lying-in-wait special circumstances satisfies the requirements of the Eighth Amendment; (3) the trial court did not err in instructing the jury; (4) the trial court did not err in allowing the prosecutor to present victim impact evidence relating to noncapital crimes; (5) Defendant forfeited his claim that the prosecutor committed misconduct during closing remarks at the penalty phase by addressing his argument to jurors individually; and (6) Defendant’s challenges to the constitutionality of California’s death penalty law were without merit. View "People v. Johnson" on Justia Law

A grand jury returned an indictment against Defendant on charges of conspiracy to commit murder and active participation in a criminal street gang. The grand jury found reasonable cause to believe that Defendant came within the provisions of Cal. Welf. & Inst. Code 707(d)(4). Defendant initially pleaded not guilty but later demurred to the indictment, arguing that section 707(d)(4) requires a determination that a juvenile qualifies for prosecution in adult court, and because he was a juvenile at the time of the alleged offenses, the grand jury had no legal authority to inquire into the charged offenses. The trial court agreed with Defendant, allowed him to withdraw his plea, and sustained his demurrer. The court of appeal reversed. The Supreme Court affirmed, holding that section 707(d) allows prosecutors the option of filing charges against certain juveniles accused of specified offenses in criminal court by grand jury indictment. View "People v. Arroyo" on Justia Law

After a jury trial, Defendant was convicted of premeditated murder and attempted murder. The jury found that the murder was committed with the special circumstance that the victim was a peace officer engaged in the lawful performance of his duties and that it was committed by means of lying in wait for the purpose of preventing a lawful arrest. Defendant was sentenced to death. The Supreme Court reversed the special circumstance finding that Defendant committed the murder by means of lying in wait but otherwise affirmed, holding (1) Defendant was prejudiced by the trial court’s failure to sua sponte instruct on circumstantial evidence as it relates to the lying-in-wait special circumstance; and (2) no other prejudicial error occurred. View "People v. Sandoval" on Justia Law

A private citizen called a 911 operator to report an incident of suspected child abuse during the child’s visit with his father. A deputy sheriff, who was dispatched to investigate the report, determined that the child was not a victim of child abuse. Neither the officer nor the Sheriff’s Department cross-reported the initial 911 report to the child welfare agency. Less than four weeks later, the child suffered extensive head injuries during a visit with his father. The child, through a guardian ad litem, sued the county and the deputy sheriff for failing to cross-report the initial child abuse allegations to the county child welfare agency, in violation of the Child Abuse and Neglect Reporting Act. The trial court granted summary judgment for Defendants. The Court of Appeal affirmed. The Supreme Court reversed in part and affirmed in part, holding (1) the Sheriff’s Department had a mandatory and ministerial duty to cross-report the child abuse allegations made to the 911 operator to the child welfare agency, and the failure to cross-report can support a finding of breach of a mandatory duty; but (2) the officer had no duty to report the child abuse allegations and her investigative findings to the child welfare agency. View "B.H. v. County of San Bernardino" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the delay in bringing charges against Defendant did not violate his due process rights; (2) the trial court did not commit prejudicial error in its evidentiary rulings during the guilt phase of trial; (3) the prosecutor did not commit misconduct during the guilt phase closing argument; (4) the trial court did not commit prejudicial error in its evidentiary rulings during the penalty phase of trial; (5) the trial court properly instructed the jury during the penalty phase; and (6) the remainder of Defendant’s claims have already been rejected by the Court. View "People v. Cordova" on Justia Law

After a jury trial, Defendant was convicted of violating Cal. Penal Code 451(b), which forbids arson of “an inhabited structure or inhabited property.” Specifically, the jury found Defendant guilty of “arson of an inhabited structure as charged.” The prosecution did not charge Defendant with arson of property, but the court instructed the jury on it. In accordance with the trial court’s instructions, the jury did not return a verdict on the lesser crimes, including arson of property. The Court of Appeal reversed, finding the evidence insufficient to sustain the conviction, which precludes retrial of that charge. The Supreme Court reversed, holding that, under the circumstances, the lesser offense of arson of property was prosecuted in a single proceeding along with the section 451(b) charge, and therefore, Cal. Penal Code 654, as interpreted in Kellett v. Superior Court, does not prohibit retrying Defendant for that lesser offense. View "People v. Goolsby" on Justia Law