Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of California
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The Supreme Court overturned the death penalty for Scott Peterson, who, in 2002, was convicted of killing his wife, Laci Peterson, and the couple's unborn son, holding that the trial court made a series of clear and significant errors in jury selection that undermined Peterson's right to an impartial jury at the penalty phase.The Supreme Court affirmed the judgment as to guilt but reversed the judgment as to the sentence of death, holding (1) Defendant received a fair trial as to guilt; (2) the trial court erred by dismissing many prospective jurors because of written questionnaire responses expressing opposition to the death penalty, even though the jurors gave no indication that their views would prevent them from following the law; and (3) under United States Supreme Court precedent, these errors required reversal of the death sentence in this case. View "People v. Peterson" on Justia Law

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The Supreme Court affirmed the judgments of the of the trial court convicting Defendants of first degree murder and other crimes and sentencing both defendants to death, holding that no prejudice resulted from any error of the trial court.Separate juries convicted Daniel Silveria and John Travis of first degree murder, second degree robbery, and second degree burglary. After retrials, a single penalty jury returned death verdicts. The Supreme Court affirmed, holding (1) during the guilt phase, the trial court did not err in denying Travis's motion to suppress or in instructing the jury on first degree murder; and (2) during the joint penalty retrial, there was no abuse of discretion in denying Defendants' severance motions, the trial court did not wrongfully excuse for cause prospective jurors, the trial court did not err in admitting portions of Silveria's first penalty phase testimony, any error in placing conditions on proffered testimony by Travis's trial counsel was harmless, and any other assumed or actual error was not prejudicial. View "People v. Silveria" on Justia Law

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The Supreme Court affirmed Defendant's convictions for four counts of first degree murder and other crimes and sentence of death, holding that, considering any actual or assumed errors altogether, their cumulative effect did not warrant reversal of Defendant's convictions or sentence.Specifically, the Supreme Court held (1) assuming that the trial court erred by using an unsworn, uncertified interpreter during the preliminary hearing and to interpret a victim's outburst, there was no prejudice; (2) sufficient evidence supported the theory of felony murder for two murders, and even assuming there was no sufficient evidence, the first degree murder verdicts would still be upheld; (3) there was assumed or found error during trial regarding difficulties that made it difficult to hearing the court proceedings, the accuracy of interpreters, and other issues, but there was no prejudice; and (4) none of the assumed or actual errors, considered either individually or collectively, warranted reversal of Defendant's convictions or sentence. View "People v. Suarez" on Justia Law

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The Supreme Court affirmed Defendant's conviction of three counts of first degree murder and one count of second degree murder with a multiple murder special circumstance and various gun use enhancements, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion for a venue change; (2) the trial court did not err in denying Defendant's motion to suppress items discovered during a warrantless search of his vehicle; (3) Defendant's decision not to testify was knowing, intelligent, and voluntary; (4) the trial court did not improperly exclude a defense expert; (5) the trial court did not err by denying Defendant's pretrial motion to exclude evidence of his gang membership; (6) there was no instructional error; (7) the prosecutor did not commit misconduct during penalty phase argument; and (8) Defendant's challenges to the victim impact testimony were unavailing. View "People v. Duong" on Justia Law

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The Supreme Court affirmed Defendant's conviction of four counts of first degree murder and other crimes, holding that there was no error or abuse of discretion during the guilt phase or penalty phase of trial.Specifically, the Supreme Court held (1) the evidence was sufficient to show that Defendant committed the murders with premeditation and deliberation; (2) the trial court did not err in admitting testimony of the People's crime scene reconstruction expert; (3) the trial court did not abuse its discretion by admitting certain crime scene and autopsy photographs of the victims; and (4) during the penalty phase, the trial court did not err by admitting victim impact testimony or in instructing the jury. View "People v. Morales" on Justia Law

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The Supreme Court reversed the judgment of the trial court convicting Defendant of first degree murder, attempted deliberate and premeditated murder, and other crimes, holding that Defendant's statements were improperly admitted in violation of Miranda v. Arizona, 384 U.S. 436 (1966) and Edwards v. Arizona, 451 U.S. 477 (1981), and the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued that his statements to police were taken in violation of his Fifth Amendment right to counsel. Specifically, Defendant argued that his unequivocal request for counsel was not honored. The Supreme Court agreed, holding (1) under Edwards, the officers were required to stop the interrogation once Defendant unequivocally requested counsel, but because the officers did not do so Defendant's statements were inadmissible as substantive evidence at trial; and (2) the erroneous admission of Defendant's statements was not harmless beyond a reasonable doubt as to any of the jury's findings. View "People v. Henderson" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first degree murder and other crimes and sentence of death, holding that there was no prejudicial error in the trial proceedings.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized during a warrantless probation search of his home; (2) the trial court did not abuse its discretion in denying Defendant's motion to sever the capital charges from his remaining charges; (3) the evidence was sufficient to support the convictions; (4) Defendant's challenges to the trial court's guilt phase instructions lacked merit; (5) a failure of consular notification under the Vienna Convention occurred in this case, but no prejudice resulted from it; (6) the trial court did not err in denying Defendant's motion to modify the verdict; and (7) Defendant's challenges to California's death penalty law were unavailing. View "People v. Vargas" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to modify the jury's verdicts of burglary and first degree murder, first degree forcible rape, second degree robbery and false imprisonment by violence and sentencing Defendant to death, holding that considering assumed errors altogether, reversal was not warranted.Defendant, an African-American, was charged with raping and murdering a White woman. On appeal, Defendant argued, among other things, that the prosecutor improperly exercise peremptory challenges to excuse two prospective jurors, who were African-American, in violation of Batson v. Kentucky, 476 U.S. 79, and People v. Wheeler, 22 Cal.3d 258, 276-277. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) substantial evidence supported the trial court's conclusion that the prosecutor struck the potential jurors for reasons other than his race; (2) there was no error in the trial court's decision to excuse two jurors for cause; (3) there was no merit to Defendant's allegations of error during the guilt phase; and (4) any assumed errors during the competency phase and penalty phase were not prejudicial and, considered cumulatively, did not require reversal. View "People v. Miles" on Justia Law

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The Supreme Court affirmed Defendant's conviction of three counts of first degree murder and his sentence of death, holding that the three or four minor errors at Defendant's trial were harmless and did not interfere with his due process right to a fair trial.Specifically, the Supreme Court held (1) no error occurred during jury selection; (2) Defendant was not prejudiced by any misstatements by the prosecutor; (3) assuming certain evidence was inadmissible, the court's admonition to the jury and the court's instruction cured the resultant harm; (4) the trial court erred in admitting testimony that the victim was afraid of Defendant, but the error was harmless; and (5) Defendant's remaining allegations of error were without merit. View "People v. Flores" on Justia Law

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The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first degree murder and of conspiracy to commit murder and sentencing Defendant to death, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the admission of Defendant's surreptitiously recorded jailhouse statement did not violate Defendant's Sixth Amendment right to counsel, his Fifth Amendment right to counsel and privilege against self-incrimination, his Fourth Amendment right to be free from unreasonable detention, his rights under the Sixth Amendment's confrontation clause, or attendant protections under Evidence Code sections 352 and 1101; (2) one instance of prosecutorial misconduct committed at the guilt phase was not prejudicial; and (3) Defendant was not entitled to relief on his remaining claims of guilt phase and penalty phase error. View "People v. Fayed" on Justia Law