Justia Criminal Law Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeal affirming Defendant's convictions for, among other crimes, first degree murder and two counts of attempted, premeditated murder of a police officer and his sentence of life without the possibility of parole, holding that the trial court's erroneous concurrent intent instruction was prejudicial as to one attempted murder count.At issue was the proper standard of review when a defendant challenges a court's decision to instruct on a concurrent intent - or kill zone - theory as applied to an allegation of attempted murder. The Supreme Court reversed the court of appeals to the extent it affirmed one of Defendant's attempted murder convictions based on the concurrent intent theory, holding (1) the substantial evidence standard applies to giving or reviewing a concurrent intent instruction; (2) a concurrent intent instruction was not supported by substantial evidence; and (3) the error was prejudicial as to one of the attempted murder counts. View "People v. Mumin" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming Defendant's conviction of first-degree murder, holding that when the record contains substantial evidence of imperfect self defense, the trial court's failure to instruct on that theory amounts to constitutional error and is subject to review under the federal Chapman standard. See Chapman v. California, 386 U.S. 18 (1967).On appeal, Defendant argued that the trial court committed harmful error in denying his request for an instruction on imperfect self-defense. The court of appeals affirmed, concluding that the trial court erred but that the error was subject to the "reasonable probability" standard for evaluating prejudice set forth in People v. Watson, 46 Cal.2d 818 (1956) and that Defendant suffered no prejudice. The Supreme Court reversed, holding (1) the form of misconstruction in this case precluded the jury from making a finding on a factual issue necessary to establish the element of malice, thus qualifying as a federal error; and (2) the court of appeal's harmless error analysis did not comport with the standards for evaluating prejudice under Chapman. View "People v. Schuller" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that because certain statements fell within an exception to the hearsay requirement they automatically qualified for admission into evidence, holding that the court of appeals erred in concluding that it was not necessary to balance Defendant's confrontation interests against any countervailing government interests.Defendant was charged with inflicting corporate injury upon a person in a dating relationship and residential burglary. The prosecution moved to revoke Defendant's probation based on the same incident. At the criminal trial, the prosecution sought to admit the complaining witness's (N.S.) statements as recorded on a body-worn camera video, but the trial court ruled that the statements were inadmissible under the Confrontation Clause. The court subsequently dismissed the criminal proceeding. At the subsequent probation revocation the court ruled that statements within the first portion of the video qualified as spontaneous statements under Cal. R. Evid. 1240 and admitted N.S.'s statements without making an express finding of good cause for not securing N.S.'s live testimony. The court of appeal affirmed the order revoking Defendant's probation. The Supreme Court reversed, holding that the court of appeals erred in concluding that the statements automatically satisfied the minimum due process requirements necessary for their admission into evidence. View "People v. Gray" on Justia Law

The Supreme Court affirmed the decision of the court of appeal concluding that the actions of Defendants Lonnie Mitchell and Louis Mitchell were sufficient to demonstrate that each proximately caused the victim's death, regardless of who actually shot the victim, holding that Defendants' deadly actions in this case constituted proximate cause consistent with the holding in People v. Sanchez, 26 Cal. 4th 834.In Sanchez, the Supreme Court upheld the first-degree murder conviction of a defendant who had engaged in a shootout that left an innocent bystander dead. At issue in this case was whether Sanchez's analysis of "substantial concurrent cause" permitted Defendants' convictions. The Supreme Court affirmed, holding that the trial court, consistent with Sanchez, properly instructed the jury on substantial concurrent causation with respect to the victim's death. View "People v. Carney" on Justia Law

The Supreme Court reversed the judgment of the court of appeal with instructions to remand this case to the trial court for further proceedings on Defendant's petition for resentencing, holding that the trial court erred in denying the petition.Defendant was convicted of second-degree murder and street terrorism, as well as gang and firearm enhancements. Two years after Defendant was sentenced, the legislature enacted Senate Bill No. 1437 to amend section 188 to provide that, except in cases of felony murder, "in order to be convicted of murder, a principal in a crime shall act with malice aforethought." Thereafter, Defendant petitioned the trial court for resentencing under what is now Cal. Penal Code1172.6, arguing that his murder conviction was based on the now-invalid natural and probable consequences theory. The trial court denied the petition. The Supreme Court reversed and remanded the case, holding that the trial court erred in sustaining Defendant's second-degree murder conviction, and to the extent the petition was rejected under a direct aiding and abetting theory, the trial court reversibly erred by misunderstanding the legal requirements of direct aiding and abetting implied malice murder. View "People v. Reyes" on Justia Law

The Supreme Court affirmed as modified the judgment of the appellate court reducing the length of Defendant's probation from three years to two, holding that Assembly Bill No. 1950 (2019-2020 Reg. Sess.) applies retroactively to cases not yet final on appeal.On January 1, 2021, Assembly Bill 1950 became effective and reduced the maximum length of probation for most felonies to two years. While Defendant's appeal from his conviction and sentence was pending, the legislature enacted Assembly Bill 1950. The court of appeal agreed with Defendant that the probation limit applied to Defendant retroactively and that the proper remedy was remand to allow the trial court to allow the parties to renegotiate a resolution. The Supreme Court affirmed as modified, holding (1) Assembly Bill 1950 applies retroactively to all nonfinal cases; and (2) the proper remedy in this case is to modify the judgment to reflect a new probationary term of two years. View "People v. Prudholme" on Justia Law

The Supreme Court reversed the court of the court of appeal reversing Defendant's conviction of rape and kidnapping to commit rape, holding that the court of appeals incorrectly found prejudicial instructional error.On appeal, the court of appeal concluded that the trial court erred in instructing the jury that Defendant could be convicted of kidnapping to commit rape based on the theory that he accomplished the kidnapping by deception rather than by force or fear. The Supreme Court reversed, holding that because any rational juror who made the findings reflected in the verdict would necessarily have found that Defendant used some quantum of physical force to move the victim in this case, any error did not contribute to the verdict. View "People v. Lewis" on Justia Law

The Supreme Court affirmed Defendant's sentence of death, following resentencing, in connection with his convictions of first degree murder, two counts of forcible rape, and enhancements for personal use of a firearm, holding that any error in the resentencing was harmless beyond a reasonable doubt.When Defendant was convicted in 2000 the jury found true special circumstances for committing murder during a kidnapping and intentional infliction of torture and set the penalty at death. The Supreme Court upheld the guilt judgment but reversed the penalty verdict on the grounds that the trial court erroneously dismissed a juror during penalty phase deliberations. After a retrial, Defendant was again sentenced to death. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar Defendant's penalty retrial; (2) the penalty retrial did not violate due process; (3) Defendant's challenges to the constitutionality of California's death penalty statute were unavailing; and (4) any error brought about by retroactive application of Senate Bill 1437 was harmless beyond a reasonable doubt. View "People v. Wilson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the trial court's denial of Defendant's request for a pretrial diversion made for the first time after the jury returned its verdict, holding that a defendant must request a pretrial diversion under Cal. Penal Code 1001.36 before attachment of jeopardy at trial or the entry of a guilty or no contest plea, whichever occurs first.After a trial at which Defendant represented himself, a jury found Defendant guilty of resisting an executive officer with force or violence and having two prior qualifying felony convictions under the "Three Strikes" law. Before sentencing, Defendant's newly-appointed counsel moved to have Defendant considered for mental health diversion under section 1001.36. The trial court denied the motion as both untimely and moot, and the appellate court affirmed. The Supreme Court affirmed, holding that the Legislature intended to require that a defendant request pretrial mental health diversion before attachment of jeopardy at trial or the entry of a guilty or not contest plea, whichever occurs first. View "People v. Braden" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming Defendant's gang enhancement and firearm enhancement and remanded this case to the superior court for a retrial, holding that a retrial was required.After a trial, Defendant was convicted of first-degree murder with gang and firearm enhancements and a prior strike conviction. At issue on appeal was whether any of Defendant's sentencing enhancements must be vacated due to the legislature's amendment to the substantive offense of active participation in a criminal street gang as well as the sentencing enhancement available for a felony committed for the benefit of or with specific intent to promote criminal conduct by gang members because the jury in his case was instructed under the prior law. The Supreme Court remanded the case, holding that the failure to instruct that the alleged predicate offenses must have "commonly benefited" the gang in a "more than reputation" manner was not harmless beyond a reasonable doubt. View "People v. Cooper" on Justia Law