Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeal affirming the decision of the trial court to sentence Defendant to three years for robbery with a twenty-five-years-to-life enhancement under Cal. Penal Code 12022.53(d), holding that the the trial court erred in denying Defendant's motion to strike.A jury convicted Defendant of second degree robbery, assault with a semiautomatic firearm, and driving under the influence. The jury found true the firearm use enhancements on the robbery and assault counts. Before sentencing, Defendant moved under Cal. Penal Code 12022.53(h) to strike the firearm enhancement under section 12022.53(d). The court denied Defendant's motion. On appeal, Defendant argued that the trial court abused its discretion because it was unaware that it could strike the enhancement at issue and then impose a lesser enhancement under either section 12022.53(b) or (c). The court of appeal affirmed, concluding that the trial court could not strike the enhancement and substitute a different unalleged enhancement. The Supreme Court reversed, holding that the Legislature has permitted courts to impose a section 12022.53(b) or (c) penalty when only a section 12022.53(d) enhancement is charged and found true. View "People v. Tirado" on Justia Law

The Supreme Court affirmed Defendant's convictions for first degree murder and other crimes and Defendant's death sentence, holding that any found or assumed errors were individually harmless and that there was no cumulation of error that merited reversal.Specifically, the Supreme Court found or assumed errors in the admission of prior crimes evidence, a prosecutorial misconduct claim concerning a jury argument that Defendant signed a parole form advising him of a possible life sentence, a claim that the defense was prevented from responding to the prosecutor's argument, a claim that certain expert testimony usurped the trial court's role to instruct the jury about the law, and four additional prosecutorial misconduct claims. The Court held (1) any assumed or actual error in each of these claims was individually harmless; and (2) there was no cumulative error warranting reversal. View "People v. Johnson" on Justia Law

The Supreme Court held that the Department of Corrections and Rehabilitation acted within the authority provided by Cal. Const. art. I, 32(b) when it adopted regulations prohibiting early parole consideration under the scheme set forth in Proposition 57, The Public Safety and Rehabilitation Act of 2016, for inmates "currently serving a term of incarceration for a 'violent felony.'"After Petitioner was convicted of nine violent felony counts and six nonviolent felony counts voters approved Proposition 57. The Department subsequently adopted regulations implementing early parole considerations, including the regulations at issue here. Consistent with these regulations, the Department determined that Petitioner was ineligible for nonviolent offender early parole consideration because he was serving a term of incarceration for a violent felony. The court of appeal granted relief, concluding that the language of article I, section 32(a) requires early parole consideration for any inmate convicted of a nonviolent felony even when that inmate was also convicted of a violent felony. The Supreme Court reversed, holding that the Department acted within its authority provided by article I, section 32(b) when it adopted the regulation at issue. View "In re Mohammad" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first-degree murder and sentencing him to death, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not commit reversible error when it denied Defendant's request for self-representation under Faretta v. California, 422 U.S. 806 (1975) because the motion was untimely; (2) it was not reasonably probable that the jury would have reached a result more favorable to Defendant but for one improper question posed by the prosecutor to a witness; (3) the trial court did not err when it denied Defendant's motion for a mistrial; (4) admission of certain evidence did not violate Defendant's right to due process or render his trial fundamentally unfair; (5) there was no merit to Defendant's allegations of instructional error; and (6) Defendant's challenges to the death penalty law were unavailing. View "People v. Wright" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and attempted second-degree robbery and sentence of death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) sufficient evidence supported the attempted robbery conviction; (2) the trial court did not err in admitting statements obtained during an undercover operation that law enforcement performed while Defendant was being transported and held in jail; (3) there was no error in the denial of defense counsel's request for a second continuance; (4) a wiretap application at issue in this case was not facially invalid; (5) any violation of Defendant's right to confrontation was harmless; (6) Defendant failed to establish either prosecutorial or judicial misconduct; (7) the trial court did not improperly restrict cross-examination or err in its remaining challenged evidentiary rulings; (8) Defendant failed to establish harmful error as to the admission of his statements at the penalty phase of his statements referencing other crimes; and (9) Defendant's challenges to the death penalty were unavailing. View "People v. Gonzalez" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting Defendant's motion for postconviction discovery under Cal. Penal Code 1054.9 giving Defendant access to the prosecutor's jury selection notes, holding that there was no error.In 1994, Defendant was convicted of capital murder and sentenced to death. Decades later, Defendant filed a habeas corpus petition claiming that the prosecution had used peremptory strikes to discriminate against prospective jurors, in violation of Batson v. Kentucky, 476 U.S. 79 (1986) and People v. Wheeler, 22 Cal.3d 258 (1978). Defendant also filed, in connection with the petition, a motion for postconviction discovery seeking access to the prosecutor's jury selection notes. The trial court granted the motion, and the court of appeal affirmed. The Supreme Court affirmed, holding that the district attorney may not invoke the attorney work product protection to withhold information necessary to the fair adjudication of Defendant's Batson/Wheeler claim. View "People v. Superior Court" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and conspiracy to commit murder, as well as participation in a criminal street gang, and sentencing him to death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) Defendant's convictions were supported by the evidence; (2) Sanchez error did not require reversal of Defendant's gang-related conviction and special circumstance; (3) the trial court did not abuse its discretion in anticipating potentially objectionable assertions in Defendant's opening statement; (4) the trial court's discovery sanction was not prejudicial; (5) the trial court's challenged evidentiary rulings did not prejudice Defendant; (6) Defendant's claims of prosecutorial misconduct lacked merit; and (7) Defendant was not entitled to relief on his penalty phase claims. View "People v. Navarro" on Justia Law

The Supreme Court reversed the decision of the trial court committing Petitioner as a sexually violent predator, holding that hearsay evidence in a psychological evaluation report in finding probable cause to commit a petitioner under the Sexually Violent Predator Act (SVPA), Cal. Well. & Inst. Code, 6600 set seq., is not admissible in expert evaluations.At issue was what kind of evidence a trial court may consider in making its initial SVPA probable cause determination. Petitioner argued that the trial court admitted inadmissible hearsay in two evaluations in finding probable cause, including facts underlying two offenses that he had been charged with but not convicted of and resulted in convictions that did not qualify as predicate offenses for commitment under the SVPA. The Supreme Court agreed, holding that the introduction of this hearsay evidence prejudicially affected Defendant's ability to challenge the basis of the State's petition and the sufficiency of the evidence. View "Walker v. Superior Court" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first degree murder, two counts of attempted murder, and possession of a firearm by a felon, holding that there was no reversible error.Specifically, the Supreme Court held (1) the prosecutor's use of a peremptory strike during jury selection prior to the guilt phase did not violate Batson v. Kentucky, 476 U.S. 79 (1986), or People v. Wheeler, 22 Cal. 3d 258 (1978); (2) the trial court did not err in denying Defendant's motion to suppress the gun discovered during a traffic stop; (3) the trial court did not err in admitting hearsay evidence that was the basis for the gang enhancement; (4) there was sufficient evidence to support Defendant's gang enhancement conviction; and (5) the court erred in admitting evidence of the victim's cancer diagnoses during the penalty phase, but there was no reasonable possibility that the victim impact testimony affected the verdict. View "People v. McDaniel" on Justia Law

The Supreme Court reversed Defendant's convictions of two counts of first-degree murder, holding that the district court erred in failing to initiate the competency procedures set forth in Cal. Penal Code 1368 and 1369.During pretrial proceedings and at the request of the court, a psychologist examined Defendant and issued a report finding Defendant incompetent to stand trial. The trial court rejected the psychologist's opinion without initiating the competency procedures set forth in sections 1368 and 1369. At both the guilt and penalty phases of trial, Defendant represented himself. Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court reversed the judgment in its entirety, holding that the trial court erred by failing to initiate the formal competency procedures set forth in sections 1368 and 1369. View "People v. Wycoff" on Justia Law