Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of kidnapping, committing two counts of lewd and lascivious acts on, and murdering a five-year-old girl. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding that the trial court (1) did not err in refusing to change venue from Orange County, as the record presented no reason to find a reasonable likelihood that Defendant did not receive a fair trial before impartial jurors; (2) did not err in denying Defendant’s request for additional peremptory challenges after he exhausted his statutory allotment of challenges because Defendant did not demonstrate that additional peremptory challenges were necessary to secure his right to a fair trial; (3) did not abuse its discretion in admitting evidence that Defendant had sexually molested three girls where Defendant had been charged with and acquitted of crimes concerning two of the girls; and (4) did not abuse its discretion in admitting photographs of the crime scene, evidence regarding the child pornography found on the computer to which Defendant had access, and victim impact evidence. View "People v. Avila" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder with a multiple-murder special circumstance, one count of attempted murder, and firearm enhancements for the shootings and attempted shootings of staff members at a hospital. After two penalty trials that resulted in hung juries, the third penalty jury returned a verdict of death. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial court’s denial of Defendant’s motion to recuse the district attorney’s office was not an abuse of discretion; (2) the trial court erred in its instructions to the jury, but the error was harmless; (3) retrial did not violate Defendant’s rights to due process and equal protection and the prohibition against cruel and unusual punishment; (4) Defendant was not deprived of the right to equal protection and trial by a representative jury because the jury included no Vietnamese-Americans; (5) although the prosecutor engaged in misconduct during the penalty phase, the improper questions did not influence the verdict; and (6) Defendant’s allegations of error in post-trial issues were without merit. View "People v. Trinh" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted premeditated murder, two counts of second degree robbery and arson causing great bodily injury. The jury returned a verdict of death. The Supreme Court vacated Defendant’s arson-murder special-circumstance finding but otherwise affirmed the judgment in its entirety, holding (1) the trial court did not err in restricting Defendant’s counsel’s questioning of prospective jurors during voir dire; (2) the evidence was insufficient to support the arson-murder special circumstance because the arson did not involve an inhabited structure or property; (3) the trial court did not abuse its discretion in dismissing a juror during the trial; (4) the trial court did not prejudicially err in its instructions to the jury; (5) the trial court did not err in refusing to declare a mistrial after the penalty jury initially declared it was deadlocked; and (6) Defendant’s challenges to the constitutionality of California’s death penalty scheme were without merit. View "People v. Debose" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, sodomy, and forcible lewd act on a minor. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in failing to exclude expert testimony that the victim died by drowning in association with sexual assault; (2) the trial court did not err in the remainder of its evidentiary rulings; (3) the evidence was sufficient to support the convictions; (4) defense counsel provided constitutionally effective assistance; (5) the trial court did not err by accepting Defendant’s waiver of his right to present mitigating evidence; (6) Defendant’s voluntary absence during trial did not violate the federal Constitution; and (7) Defendant’s constitutional challenges to the death penalty law and related jury instructions were without merit. View "People v. Brown" on Justia Law

Defendants, Stephen Edward Hajek and Loi Tan Vo, were convicted of, among other crimes, the murder of Su Hung. The jury found true lying-in-wait and torture-murder special circumstances as to both defendants. The jury also found true firearm use allegations as to Hajek and deadly or dangerous weapon use as to Vo, in Defendants’ commission of the murder, attempted murder, kidnapping, and false imprisonment counts. The jury returned verdict of death as to each defendant. The Supreme Court affirmed the death judgments, reversed the lying-in-wait special circumstances findings as to both defendants, and ordered that the firearm use enhancements found true as to Hajek be struck and replaced with deadly or dangerous weapon use enhancements, holding (1) there was insufficient evidence to show that Defendants intentionally killed the victim while lying in wait, but the reversal of the lying-in-wait special-circumstance findings did not require reversal of Defendants’ death sentences; and (2) a change in the law excluding pellet guns from the definition of a firearm required that Hajek’s firearm use enhancements involving the use of a pellet gun be struck, but the jury’s true findings on the firearm use enhancements necessarily included true findings on deadly or dangerous weapon use enhancements. View "People v. Hajek" on Justia Law

Defendants in these cases were both seventeen-year-old offenders who were convicted of special circumstance murder and sentenced to life imprisonment without the possibility of parole under Cal. Penal Code 190.5(b). After Defendants were sentenced, the U.S. Supreme Court decided Miller v. Alabama. On review, the California Supreme Court held (1) section 190.5(b), properly construed, confers discretion upon a trial court to sentence a juvenile convicted of special circumstance murder to life without parole, with no presumption in favor of life without parole; (2) Miller requires a trial court, in exercising its sentencing discretion, to consider the distinctive attributes of youth before imposing life without parole on a juvenile offender; (3) section 190.5(b) does not violate the Eighth Amendment to the U.S. Constitution because it authorizes and requires consideration of the distinctive attributes of youth highlighted in Miller, once the statute is understood not to impose a presumption in favor of life without parole; and (4) because the trial courts in these cases sentenced Defendants without awareness of the full scope of their discretion conferred by section 190.5(b) and without the guidance set forth in Miller, the cases must be remanded for resentencing. View "People v. Gutierrez" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, attempted robbery, and second degree robbery. Following a retrial of the penalty phase trial, the jury sentenced Defendant to death for the murder conviction. The Supreme Court affirmed the judgment, including the death sentence, but ordered the clerk of the superior court to modify the abstract of judgment to reflect ninety-six days of conduct credit, holding that there was no reversible error in the jury selection and that the trial court did not err in its rulings during the guilt phase and the penalty phase, with the exception of denying Defendant presentence conduct credits. View "People v. Chism" on Justia Law

After a jury trial in 1995, Defendant was convicted of twelve counts of first degree murder and one count of attempted murder. Defendant’s victims abused drugs and worked as prostitutes. The trial court sentenced Defendant to death with respect to each of the twelve murder convictions. The Supreme Court affirmed, holding (1) the trial court’s denial of Defendant’s motion for a change of venue based on the public’s knowledge of his case did not deprive Defendant of due process of law or a fair trial; (2) the trial court did not err in denying Defendant’s motion to suppress evidence obtained as a result of a traffic stop; (3) the trial court did not err in denying discovery concerning murders of prostitutes with which Defendant was not charged; (4) the trial court did not err in failing to exclude evidence obtained during police questioning of Defendant and in making its other evidentiary rulings; (5) the extent and nature of the victim impact evidence did not deprive Defendant of his rights to due process, a fair trial, and a reliable penalty determination; and (6) California’s death penalty scheme, jury instructions, and procedures are constitutional. View "People v. Suff" on Justia Law

After a jury trial, Petitioner and his codefendant were convicted of burglarizing the home of Bobby Hassan and of robbing and murdering Bobby and his son, Eric. Petitioner and his codefendant were sentenced to death in 1982. The Supreme Court affirmed on appeal. Petitioner later filed a petition for writ of habeas corpus, alleging that his trial attorney ineffectively represented him at the penalty phase of trial. In 2002, the Supreme Court issued an order to show cause based on Petitioner’s claim of ineffective assistance of counsel. The Court appointed a referee and directed him to take evidence and make findings of fact. In 2014, based on the referee’s findings, the Supreme Court denied relief, holding that Petitioner’s counsel did not provide incompetent representation at trial. View "In re Champion" on Justia Law

After a jury trial, Defendant was convicted of two counts of animal cruelty. During voir dire, the trial court denied Defendant’s challenges to two prospective jurors on incompetence grounds, after which Defendant used two of his allotted peremptory challenges to remove the same jurors. Defendant subsequently exhausted his peremptory challenges and unsuccessfully requested that the trial court grant him extra peremptory challenges to remove other prospective jurors he deemed to be objectionable. On appeal, Defendant claimed he was entitled to reversal of the trial court’s judgment because one of the jurors he objected to sat on his case. The Supreme Court affirmed Defendant’s conviction, holding (1) Defendant cured any error that occurred when the trial court denied his for-cause challenges because those jurors were removed with Defendant’s peremptory challenges; (2) the trial court was under no obligation to grant Defendant extra peremptory challenges to remove additional, otherwise competent, jurors; and (3) because no incompetent juror who should have been dismissed for cause sat on Defendant’s case as a result of Defendant exhausting his peremptory challenges, Defendant was not entitled to reversal. View "People v. Black" on Justia Law