Justia Criminal Law Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeal affirming the judgment of the trial court denying Appellant's petition for resentencing under Senate Bill No. 1437, holding that certain special circumstance findings did not preclude him from making out a prima facie case for resentencing.In 2014, Appellant was convicted of felony murder. The jury found true felony-murder special-circumstance allegations that Appellant was a "major participant" who acted with "reckless indifference to human life" under Cal. Penal Code 190.2, subdivision (d). Thereafter, the Supreme Court decided People v. Banks, 61 Cal. 4th 788 (2015) and People v. Clark, 63 Cal.4th 522 (2016), which provided guidance on the meaning of the statutory phrases "major participant" and "with reckless indifference to human life." In 2018, the Legislature adopted Senate Bill 1437. Appellant then petitioned for resentencing. The trial court denied the petition. The Supreme Court reversed, holding (1) findings issued by a jury before Banks and Clark do not preclude a defendant from making out a prima facie case for relief under Senate Bill 1437; and (2) because Appellant's case was tried before both Banks and Clerk, the special circumstance findings did not preclude him from making out a prima facie case for resentencing under section 1172.6. View "People v. Strong" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal reversing the trial court's order dismissing counts one through four of the combined information in this criminal case, holding that Cal. Penal Code 954's joinder clause permits a district attorney to file a single information in the circumstances presented in this case.At issue before the Supreme Court was whether, and under which circumstances, a trial court may consider more than one preliminary hearing record in its ruling on a motion brought under Cal. Penal Code 995 to set aside the information for lack of probable cause. Specifically at issue was the correct interpretation of section 954. The court of appeals ruled that section 954's consolidation clause provided the district court with the authority to file a single information combining related offenses that were the subject of separate preliminary injunctions. The Supreme Court affirmed, holding (1) the statute permits a history attorney to file a single information when the applicable time constraints are satisfied; and (2) when related offenses are properly joined by the district attorney and in ruling on a section 995 motion, a trial court is permitted to consider more than one preliminary hearing record. View "People v. Henson" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant, following a jury trial, of eleven counts of first-degree murder and sentencing him to death, holding that Defendant was not entitled to reversal of his convictions.Specifically, the Supreme Court held (1) Defendant was not entitled to reversal on his claims regarding his right to representation; (2) the trial court did not err on engage in misconduct during venue-related proceedings in both Calaveras County and Orange County, and the trial court did not err in failing to transfer six counts from Orange County to the City and County of San Francisco; (3) the trial court did not deprive Defendant of due process by its adjudication of competency proceedings or by subjecting him to physical constraints; (4) even if there was error in the admission of certain evidence, the error was harmless; (5) the trial court did not abuse its discretion in denying Defendant's motion for a mistrial based on lack of evidence; and (6) there was no prejudicial error during the penalty phase. View "People v. Ng" on Justia Law