Justia Criminal Law Opinion Summaries

The Supreme Court remanded this case to the circuit court after the court found that Defendant inflicted "great bodily injury," holding that the sentencing court's finding of great bodily injury violated Defendant's Sixth Amendment jury trial rights under Apprendi v. New Jersey, 530 U.S. 466 (2000).Defendant was charged with assault by means of force likely to produce great bodily injury and other related crimes. The jury found Defendant guilty of assault, battery, and participating in a street gang and deadlocked on the remaining counts. During sentencing, the court imposed a five-year enhancement, concluding that Defendant's charges were serious felonies because there was "great bodily injury." After he appealed, Defendant sought a writ of habeas corpus, arguing that appellate counsel provided ineffective assistance by failing to challenge the great bodily injury finding. The Supreme Court reversed, holding that the sentencing court's finding of great bodily injury did not violate Defendant's Sixth Amendment right to a jury trial under Apprendi in light of the jury's failure to reach a verdict on great bodily injury allegations. View "In re Cabrera" on Justia Law

The Supreme Court reversed the judgment of the court of appeal in this criminal case, holding that the evidence a law enforcement officer found after his illegal detention of Defendant was not admissible.The officer in this case was responding to a report of suspicious activity in the area when he unlawfully detained Defendant, who was "hanging out" in his car reclining in the passenger seat. The officer ran a records check and learned that Defendant was on active and searchable parole. The officer proceeded to search Defendant and his vehicle, finding firearm- and drug-related evidence. Defendant moved to suppress the ensuing charges against him, arguing that his detention violated the Fourth Amendment. The trial court denied the motion, and the court of appeal affirmed. The Supreme Court reversed, holding that the officer's discretionary decision to conduct the parole search of Defendant did not sufficiently attenuate the connection between the officer's initial unlawful decision to detain Defendant and the later discovery of contraband. View "People v. McWilliams" on Justia Law

The Supreme Court held that Proposition 36, the Three Strikes Reform Act of 2012, did not change the law and strip sentencing courts or their discretion to impose concurrent terms for felonies that were committed on the same occasion or arose from the same set of operative facts, even if the felonies qualified as serious or violent.At issue was whether the Reform Act abrogated the rule in People v. Hendrix, 16 Cal.4th 508, 512 (Hendrix), that a court may impose concurrent sentences in cases falling under the "Three Strike" sentencing scheme. The Supreme Court held (1) following Proposition 36, the court retained its Hendrix concurrent sentencing discretion; and (2) the total sentence imposed for multiple counts of serious or violent felonies "must be ordered to run consecutively to the term imposed for offenses that do not qualify as serious or violent felonies." The Court therefore reversed the judgment of the court of appeals concluding that it lacked discretion to impose concurrent terms on multiple serious or violent felonies after passage of the Reform Act. View "People v. Henderson" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the decision of the trial court denying Defendant's motion to vacate his conviction, holding that holding that the court of appeals erred in ruling that Defendant failed adequately to corroborate his claim that immigration consequences were a paramount concern and thus that Defendant could not demonstrate prejudice within the meaning of Cal. Penal Code 1473.7.In 2004, Defendant, a native of Mexico, accepted a plea bargain and served one year in jail. In 2015, Defendant was detained by federal immigration authorities after a return flight to the United States, and his permanent residence card was seized. In his his third motion to vacate his conviction, Defendant argued that he had not been aware of the immigration consequences of his plea and that, had he been aware, he would have sought a plea with lesser consequences or gone to trial. The trial court denied the motion without holding an evidentiary hearing. The Supreme Court reversed, holding that, under the totality of the circumstances, there was a reasonable probability that Defendant would have rejected the plea had he understood its immigration consequences. View "People v. Espinoza" on Justia Law

The Supreme Court affirmed Defendant's conviction for the first degree murder of Rafael Noriega and his sentence of death, holding that there was no reversible error in the proceedings below.A jury convicted Defendant of first degree murder and found true the special circumstance allegation that the murder was committed while Defendant was engaged in the commission of a robbery. The jury also found true the special circumstance allegation that Defendant was previously convicted of murder. The jury returned a verdict of death, and the trial court denied Defendant's ensuing motion for modification of his sentence. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant's right to self-representation in its rulings regarding Defendant's funding requests; (2) there was no error or abuse of discretion in the district court's evidentiary rulings; (3) Defendant's challenges to the special service allegations were unavailing; (4) there was no error in the jury instructions; (5) there was no error or abuse of discretion during the penalty phase; and (6) Defendant's challenges to the constitutionality of California's death penalty law failed. View "People v. Thomas" on Justia Law

The Supreme Court reversed Defendant's conviction for three counts of first degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request.Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless. View "People v. Waldon" on Justia Law

The Supreme Court held that a law enforcement officer's act of shining a spotlight for illumination does not ipso facto constitute a detention under the Fourth Amendment, but rather, the proper inquiry requires consideration of the totality of the circumstances, including the use of the spotlight.Defendant was charged with drug offenses after a law enforcement officer conducted a search of the car he was driving. At issue was whether the officer engaged in a consensual encounter when he pulled behind Defendant's car and turned on his spotlight. The court of appeal concluded that spotlight illumination and approach on foot did not "manifest a sufficient show of police authority to constitute a detention." The Supreme Court agreed, holding (1) under the totality of the circumstances, Defendant was not detained by the officer's use of a spotlight; and (2) remand was appropriate for a new factual finding as to whether the officer's detention of the vehicle's female passenger effectuated a detention of Defendant. View "People v. Tacardon" on Justia Law

The Supreme Court affirmed the decision of the court of appeal finding that it had no duty to independently review an order denying a petition for postconviction relief under Cal. Penal Code former section 1170.95, which Defendant filed in this case, when appointed counsel submits notice that the appeal lacks arguable merit, holding that Defendant was not entitled to relief.The court of appeal in this case provided notice to Defendant that counsel was unable to find any arguable issues, but the notice was "suboptimal" because it indicated that the procedures set forth in People v. Wende, 25 Cal.3d 436 (Cal. 1979), would apply when they actually did not. The court further failed to inform Defendant that the appeal would be dismissed as abandoned if he did not file a supplemental brief or letter. The Supreme Court nevertheless affirmed the denial of Defendant's petition for postconviction relief, holding that, based on an independent review of the record, Defendant was not entitled to relief under Cal. Penal Code 1172.6. View "People v. Delgadillo" on Justia Law

The Supreme Court affirmed the decision of the court of appeal upholding the trial court's finding that trial may continue in Defendant's absence under Cal. Penal Code 1043(b)(2) because the absence was voluntary, holding that the trial court did not violate Defendant's constitutional rights by finding him to be voluntarily absent without conducting an evidentiary hearing regarding the circumstances of his absence.On appeal, the court of appeal concluded that substantial evidence supported the trial court's finding that Defendant voluntarily absented himself from trial and that the court's decision to proceed with trial rather than grant defense counsel's motion for a one-day continuance constituted harmless error. The Supreme Court affirmed, holding that substantial evidence supported the trial court's finding of voluntary absence under the circumstances of this case. View "People v. Ramirez" on Justia Law

The Supreme Court reversed Defendant's conviction for conspiracy to commit murder, holding that there was insufficient evidence to support the conviction.After a jury trial, Defendant and his codefendants were found guilty of conspiracy to commit murder and other offenses. As to all three defendants, the jury found that the conspiracy was for the benefit of a criminal street gang. Defendant appealed, challenging the sufficiency of the evidence. The court of appeal affirmed. The Supreme Court reversed, holding that, after considering the record in its entirety, the evidence presented at trial was insufficient to show that Defendant had the requisite intent to enter into an agreement to commit murder. View "People v. Ware" on Justia Law