Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, attempted murder, and conspiracy to commit murder and sentencing Defendant to death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the trial court properly excluded two prospective jurors for cause; (2) the "substantial impairment" standard used for determining jury bias in capital cases did not violate Defendant's Sixth Amendment right to an impartial jury; (3) there was no constitutional violation in the denial of Defendant's motion to dismiss the charges against him; (4) there was no error in the court's evidentiary rulings; (5) the trial court erred by failing to provide the jury with a cautionary instructions defining confessions, but the error was harmless; (6) Defendant did not demonstrate any basis for the Court to find error in California's death penalty laws; and (7) a limited remand was appropriate for the sole purpose of allowing the trial court to consider whether to exercise its discretion to strike the prior serious felony enhancement and the firearm enhancements. View "People v. Mataele" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two murders and finding true the special circumstances that one murder occurred during the commission of a robbery, that the other murder involved the killing of a witness and that Defendant had been convicted of multiple murders, and sentencing Defendant to death, holding that no errors required reversal of the judgment.Specifically, the Supreme Court held (1) substantial evidence supported the excusal of juror J.W. for cause; (2) assuming that the trial court erred when it allowed the prosecution to introduce "other acts" evidence at the guilt phase of trial, any error was harmless; (3) assuming that the trial court erred in introducing evidence at the penalty phase regarding Defendant's participation in mutual combat was harmless; and (4) there was no cumulative error requiring reversal of the judgment below. View "People v. Pineda" on Justia Law

The Supreme Court affirmed the order of the trial court entering judgment upon the jury's verdict that Defendant committed first degree murder, robbery, burglary, and firearm possession by a felon and sentencing him to death, holding that while the court committed statutory error, there were no additional errors or rulings that caused Defendant undue prejudice.On appeal, Defendant asserted that several errors in the guilt and penalty phases occurred, resulting in cumulative prejudice warranting reversal of his convictions. The Supreme Court disagreed and affirmed, holding (1) the trial court erred by allowing Defendant to be absent from trial without a written waiver, but the error was not prejudicial; and (2) Defendant failed to identify any other reversible error on appeal. View "People v. Poore" on Justia Law

The Supreme Court held that Proposition 57, a measure that amended the law governing the punishment of juvenile offenses in adult criminal court by requiring hearings to determine whether the offenses should instead by hearing in juvenile court, applied during resentencing where the criminal court sentence imposed on Defendant, a juvenile offender, was issued before the initiative's passage but was since vacated.Defendant was originally sentenced before Proposition 57 was enacted, but his sentence was later vacated on habeas corpus, and the case was returned to the trial court for imposition of a new sentence. At issue was whether Proposition 57 applied to Defendant's resentencing. The Supreme Court affirmed the judgment of the court of appeal, holding that Proposition 57 applied to Defendant's resentencing because the judgment in his case became nonfinal when his sentence was vacated on habeas corpus. View "People v. Padilla" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of first degree murder and the jury's findings of the lying-in-wait special circumstance and the special circumstance allegations that Defendant intentionally killed the victim for financial gain while engaged in the commission or attempted commission of rape, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion by failing to initiate competency proceedings; (2) there was no error in the trial court's evidentiary rulings; (3) sufficient evidence supported the jury's true findings of the special circumstances, and the special circumstances, as applied, are not unconstitutional; (4) there was no instructional error; (5) Defendant's claims of prosecutorial misconduct were without merit; and (6) Defendant's remaining claims of error were unavailing. View "People v. Parker" on Justia Law

In this case regarding conservatorships authorized by the Lanterman-Petris-Short (LPS) Act for persons gravely disabled by a mental disorder or chronic alcoholism the Supreme Court held that, for purposes of the right against compelled testimony, those facing an LPS conservatorship due to an inability to care for themselves are sufficiently similar to persons found not guilty of crimes by reason of insanity (NGIs) that equal protection principles require the government to justify its disparate treatment of these proposed conservatees.The Contra Costa County Public Guardian petitioned for an LPS conservatorship on the ground that Appellant was gravely disabled. Appellant requested a jury trial and objected to giving compelled testimony.The court overruled the petition. Appellant was called to testify during trial. The jury found Appellant gravely disabled, and the court appointed the Public Guardian as conservator. On appeal, Appellant challenged the order compelling his testimony. The court of appeals held that LPS conservatives and similarly situated with NGIs for the purposes of NGI extension proceedings but that the error in compelling Appellant's testimony was harmless. The Supreme Court affirmed, holding (1) traditional LPS conservatees are similarly situated with NGI’s for purposes of the right against compelled testimony; but (2) a remand was not appropriate in this case. View "In re Conservatorship of Eric B." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of the first-degree murder of his father and the second-degree murders of his stepmother and stepsister and sentencing him to death, holding that Defendant's second-degree murder convictions must be reversed.A federal court vacated Defendant's initial conviction and sentence. After a retrial, Defendant was convicted of first- and second-degree murder, and the jury found true a multiple-murder special-circumstance finding and various firearm- and weapon-use findings. Defendant was sentenced to death. At trial, Defendant's counsel conceded his responsibility for the deaths of all three victims, but Defendant was willing to accept responsibility only for the killing of his father and objected to admitting responsibility for the other two deaths. The Supreme Court held (1) defense counsel violated Defendant's Sixth Amendment rights to choose the fundamental objectives of his defense; and (2) while the error did not affect Defendant's first-degree murder conviction or the associated firearm-use finding, the error requires reversal of the remainder of the judgment and the judgment of death. View "People v. Bloom" on Justia Law