Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the superior convicting Defendant, following a jury trial, of first degree murder and sentencing him to death, holding that Defendant failed to demonstrate that alleged errors occurring at the guilt phase of trial cumulated in his not having received a "fair trial on the issue of his mental state at the time of the shooting."Specifically, the Supreme Court held (1) the trial court committed error under state law by ordering that Defendant submit to an examination by the prosecution expert and allowing the jury to learn of Defendant's refusal to be examined, but these errors were not prejudicial; (2) the prosecutor's comments regarding the ethics of forensic psychiatry did not infect the trial with unfairness that rose to the level of prejudicial error; (3) the trial court erred in admitting a law enforcement officer's statement under People v. Sanchez, 63 Cal.4th 665 (2016), but the error did not contribute to the jury's verdict; (4) the guilt phase errors were not cumulatively prejudicial; (5) the trial court did not err in excusing a prospective juror for cause because of her views on the death penalty; and (6) no other prejudicial error occurred during the penalty phase of the trial. View "People v. Camacho" on Justia Law

The Supreme Court reversed the judgment of the court of appeal ruling that Proposition 36, the Three Strikes Reform Act of 2012, stripped sentencing courts of the 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, holding that the lower court erred.At issue was whether the Act abrogated the rule set forth in People v. Hendrix, 16 Cal. 4th 508 (1997), that a trial court retains discretion to impose concurrent terms for felonies that were "committed on the same occasion" or did not "aris[e] from the same set of operative facts" while requiring consecutive sentences for multiple current felonies that were not "committed on the same occasion" or did not "aris[e] from the same set of operative facts." The Court of Appeal concluded that, after passage of the Act, a trial court lacks discretion to impose concurrent terms on multiple serious or violent felonies. The Supreme Court reversed, holding that, following Proposition 36, a trial court retains its Hendrix concurrent sentencing discretion and that the total sentence imposed for multiple current 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. View "People v. Henderson" on Justia Law

The Supreme Court affirmed Defendant's conviction for kidnapping to commit rape, murder, attempted carjacking, assault with intent to commit rape, and receiving stolen property, and Defendant's sentence of death, holding that Defendant was not entitled to reversal of his convictions or sentences.Specifically, the Supreme Court held (1) as to the guilt phase issues raised by Defendant on appeal, the only potential errors, including the possibility that the prosecutor strayed beyond appropriate commentary into personal commentary on defense counsel, were not so egregious that they made the trial unfair; and (2) there was no error in the penalty phase. View "People v. Miranda-Guerrero" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death but struck the enhancement that Defendant committed the murder for the benefit of, at the direction of, or in association with a criminal street gang, holding that there was no basis for reversing Defendant's convictions or sentence.After a jury trial, Defendant was convicted of first-degree murder. The jury found true the gang enhancement and the special circumstances of robbery murder and torture murder. The jury returned a verdict of death, and the trial court denied Defendant's motions for a new trial, for reduced punishment, and to modify the verdict. The Supreme Court struck the gang enhancement and otherwise affirmed, holding (1) there was assumed or either found error regarding certain jury instructions, the failure to bifurcate, and the admission of hearsay and certain evidence, but each assumed or found error was harmless; (2) Defendant's gang enhancement was incorrectly imposed, but this error did not require reversal of the guilty verdicts or death judgment; and (3) there was no other basis for reversing Defendant's convictions or sentence. View "People v. Tran" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming Defendant's convictions and sentences, holding that the gang penalties imposed by the trial court were unsupported by the evidence.Defendant was convicted of two counts of shooting at an inhabited dwelling, an offense that is normally punishable by a maximum of seven years of imprisonment. While there was no evidence Defendant was accompanied by any gang members at the time of the shooting the jury found true that Defendant committed the crimes for the benefit of and with the specific intent to promote criminal conduct by gang members. Defendant challenged the gang penalties as unsupported by the evidence. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant was not subject to additional punishment prescribed for felonies shown to be gang-related under Cal. Penal Code 186.22(b). View "People v. Renteria" on Justia Law

The Supreme Court affirmed Defendant's convictions and life sentences for first-degree murder, robbery, kidnapping, carjacking, and drug-related offenses, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant was not entitled to relief on his claims of error during jury selection; (2) the trial judge was neither biased nor prejudiced against Defendant nor his counsel during voir dire; (3) as to Defendant's claims of error during the guilt phase of his trial, he failed to establish that the trial court committed prejudicial error in its evidentiary rulings; (4) the prosecutor did not commit misconduct rendering Defendant's trial fundamentally unfair; and (5) as to the penalty phase issues raised by Defendant, there was no prejudicial error. View "People v. Ramirez" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction of assault with a deadly weapon other than a firearm and assault by means of force likely to cause great bodily injury, holding that assault with a deadly weapon and force likely assault are different statements of the same offense.Evidence at trial showed that Defendant hit her father with a bicycle chain and lock. That evidence supported each of Defendant's aggravated assault convictions. At issue before the Supreme Court was whether "assault upon the person of another with a deadly weapon or instrument other than a firearm" and "assault upon the person of another by any means of force likely to produce great bodily injury" are separate offenses or whether they constitute different statements of the same offense. The Supreme Court vacated the convictions, holding that a defendant may not be convicted of both types of aggravated assault. View "People v. Aguayo" on Justia Law

The Supreme Court reversed the judgment of the court of appeal concluding that an instructional error in Defendant's criminal trial was not prejudicial and thus did not require reversal, holding that the instructional error was prejudicial and required reversal.Defendant was charged with burglary after the police found him sitting on a bench outside a house in Oxnard after attempting to open the locked door. At issue was a standard mistake of fact instruction given to inform jurors that they should not convict Defendant if they believed he lacked criminal intent because he mistakenly believed that the house belonged to his cousin and not a stranger. The instruction, however, specified that the mistake had to be a reasonable one, which was error. The Supreme Court held that the instructional error required reversal because it effectively precluded the jury from giving full consideration to a mistake of fact claim that was supported by substantial evidence and that there was a reasonable chance that Defendant's jury would have come to a different verdict had it been correctly instructed. View "People v. Hendrix" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal denying Petitioner's petition for a writ of habeas corpus seeking resentencing under People v. Gallardo (2017) 4 Cal.5th 120, holding that the Gallardo rule does not apply retroactively to final judgments.In Gallardo, the Supreme Court held that a defendant's Sixth Amendment right to a jury trial is violated when the trial court makes factual findings about the nature of a defendant's prior conviction in imposing an enhanced sentence based on that prior conviction. In the instant case, the court of appeal denied Petitioner's habeas petition on the ground that Gallardo was not retroactive to Petitioner's judgment, which was final in 2000. The Supreme Court affirmed, holding that the rule announced in Gallardo is a new procedural rule, and it is not retroactive to cases on collateral review under both state and federal tests for retroactivity. View "In re Milton" on Justia Law

The Supreme Court affirmed the determination of the trial court finding Defendant guilty of first-degree murder, except as modified to strike an enhancement under former Cal. Penal Code 667.5, subdivision (b), and affirmed the judgment of death but vacated the prison sentence, holding that remand was required.After a guilt phase of the bench trial held in this case Defendant was convicted of first degree murder. The trial court found true two prior serious felony enhancements and two prior prison term enhancements. After a penalty phase, the trial court returned a verdict of death and imposed a consecutive prison term of fifteen years. The Supreme Court (1) vacated the one-year prior prison term enhancement imposed under former section 667.5, subdivision (b) and remanded for resentencing, holding that the enhancement was unauthorized; and (2) affirmed the judgment in all other respects. View "People v. Morelos" on Justia Law