Justia Civil Rights Opinion Summaries

Three trials were held on the State’s petition to commit Defendant for secure confinement and treatment as a sexually violent predatory (SVP) under the Sexually Violent Predators Act. After a third jury trial and a second SVP finding, the Court of Appeal overturned the trial court’s judgment, concluding that multiple incidents of prosecutorial misconduct prejudiced Defendant and created a fundamentally unfair trial. The Supreme Court reversed after identifying one clear instance of misconduct and one other instance of arguable misconduct, holding that there was no reasonable probability that these incidents affected the outcome of the third trial, nor did they render the trial fundamentally unfair. Remanded to the Court of Appeal to address several additional claims raised by Defendant. View "People v. Shazier" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, among other crimes. The jury found true the special circumstance allegations that the murder was committed while Defendant was engaged in the commission of rape and oral copulation and the allegation that Defendant personally used a deadly weapon. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) juror misconduct occurred during the guilt phase, but Defendant was not prejudiced by that misconduct, and any error in the trial court’s evidentiary rulings was harmless; (2) there was no cumulative effect of error during the guilt phase; (2) there was no error at the penalty phase; and (3) Defendant’s challenges to the constitutionality of California’s death penalty law were without merit. View "People v. Merriman" on Justia Law

Defendant broadsided at high speed a vehicle driving by Loraine Wong. Wong’s younger daughter, Sydney, was killed, and her older daughter, Kendall, sustained serious injuries. A jury convicted Defendant of vehicular manslaughter with gross negligence and found true the allegation that he personally inflicted great bodily injury on Kendall. At issue on appeal was whether the trial court violated Defendant’s Fifth Amendment privilege against self-incrimination by admitting evidence that Defendant, following his arrest but before receipt of Miranda warnings, failed to inquire about the other people involved in the collision. The court of appeal reversed, holding that the trial court violated the Fifth Amendment privilege against self-crimination by admitting evidence of Defendant’s post-arrest, pre-Miranda failure to inquire about the welfare of the occupants of the other vehicle. The Supreme Court reversed, holding that Defendant needed to make a timely and unambiguous assertion of his Fifth Amendment privilege against self-incrimination in order to benefit from it. Remanded. View "People v. Tom" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and kidnapping with the purpose to commit a lewd act on a child under fourteen years old. The jury found true the special circumstance allegation of kidnapping murder and returned a verdict of death. The trial court sentenced Defendant to death on the murder count. The Supreme Court affirmed, holding (1) any error in the trial court’s rulings during the pretrial stage of the proceedings did not influence the verdict; (2) no prejudicial error occurred during the guilt phase; (3) the trial court did not abuse its discretion excluding certain statements from the penalty phase; and (4) Defendant’s challenges to California’s death penalty were without merit. View "People v. McCurdy" on Justia Law

After a jury trial in 1998 Defendant was convicted of two counts of first degree murder and one count of attempted murder, among other crimes. The jury found true the allegation that the attempted murder was committed willfully, deliberately and with premeditation. After a penalty phase retrial, the trial court imposed a sentence of death. The Supreme Court reduced the conviction of willful, deliberate, and premeditated attempted murder to attempted murder and, in all other respects, affirmed the judgment, holding (1) the trial court did not err in overruling Defendant’s objection to the prosecutor’s use of peremptory challenges against three black prospective jurors; (2) the jury was not properly instructed on the meaning of the terms “willful,” “deliberate,” and “premeditated,” and therefore, a reduction of Defendant’s conviction on count two to a conviction for regular attempted murder was warranted; (3) the trial court did not commit prejudicial error in its evidentiary rulings; (4) Defendant failed to establish that his attorney rendered ineffective assistance or that he was denied his right to a fair trial before an unbiased judge; and (5) during the penalty phase, the trial court erred by excluding evidence of institutional failure, evidence regarding Defendant’s antisocial personality disorder, and evidence about lingering doubt, but the errors were harmless. View "People v. Banks" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. After the penalty phase, the trial court declared a mistrial because the jury was unable to reach a penalty verdict. After a second penalty phase, the jury returned a verdict of death. The Supreme Court reversed the death sentence due to prejudicial juror misconduct and affirmed in all other respects, holding (1) the trial court did not commit prejudicial error during the guilt phase; but (2) there was a substantial likelihood that one juror was influenced or biased against Defendant by an improper conversation he had with his pastor during penalty deliberations and that the juror’s vote to impose the death penalty was not based solely on the evidence and instructions. Remanded for retrial of the penalty phase and resentencing on all counts. View "People v. Hensley" on Justia Law

Defendant, while acting as manager for a motorcycle dealership, arranged for the fraudulent sale of twenty vehicles to fictitious buyers. After a jury trial, Defendant was convicted of twenty counts of grand theft, one count for each of the vehicles fraudulently sold. On appeal, Defendant argued that he could be convicted of one count of grand theft only because all of the sales were part of a single scheme. The court of appeal affirmed the judgment of conviction for the twenty counts of grand theft. At issue before the Supreme Court was the correct interpretation of the language in People v. Bailey, which some courts of appeal have interpreted as permitting only one conviction of grand theft in circumstances such as those presented in this case. The Supreme Court reversed, holding (1) a defendant may be convicted of multiple counts of grand theft based on separate and distinct acts of theft, even if committed pursuant to a single overarching scheme; but (2) the Court cannot not retroactively apply this new rule to Defendant, and therefore, under the law that has existed for decades, Defendant could only have been convicted of a single count of grand theft. View "People v. Whitmer" on Justia Law

During the course of one evening, Defendant and another man burglarized two businesses, robbing several people inside, and killing off-duty peace officer Shayne York. After a jury trial, Defendant was convicted of first degree murder with the special circumstances of killing a peace officer in retaliation for the performance of his duties and of murder during the commission of robbery and burglary. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed Defendant’s convictions, holding (1) the trial court did not err in its evidentiary rulings or in instructing the jury during the guilt phase; (2) sufficient evidence supported the finding that Defendant intentionally killed York in retaliation for the lawful performance of his duties, and the special circumstance allegation was constitutional; (3) Defendant’s challenges to the robbery-murder and burglary-murder special circumstances were unavailing; (4) Defendant’s Sixth Amendment right to self-representation was not violated at the penalty phase; (5) any error in the instructions during the penalty phase was harmless; and (6) Defendant’s death sentence was proportional and constitutional. View "People v. Boyce" on Justia Law

One of the jurors in Defendant’s criminal case prematurely decided to vote guilty, repeatedly talked about the case outside deliberations, prematurely reached a conclusion regarding the veracity of certain testimony, and adopted the mantle of an advocate, repeatedly telling the other jurors that Defendant was guilty. The trial court found that the juror engaged in serious misconduct but that Defendant did not suffer prejudice. Defendant appealed his conviction of two counts of first degree murder and death sentence on the basis of juror misconduct. The Supreme Court reversed, holding that, under the facts of this case, the People did not discharge their burden of establishing that there was no substantial likelihood that the juror was actually biased against Defendant. View "People v. Weatherton" on Justia Law

After a jury trial, Defendant was convicted of murder, rape, and kidnapping and sentenced to death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court did not abuse its discretion in finding that Defendant was competent to stand trial; (2) the prosecutor did not improperly exercise a peremptory challenge to a prospective juror based on race; (3) during the guilt phase of trial, the trial court did not abuse its discretion in admitting crime scene and autopsy photographs and in instructing the jury; (4) no prejudicial error occurred during the penalty phase of trial; (5) the trial court did not err in denying Defendant’s motion for a new trial; and (6) Defendant’s challenges to California’s death penalty statute failed. View "People v. Sattiewhite" on Justia Law