Justia Civil Rights Opinion Summaries
Articles Posted in Supreme Court of California
People v. Turner
The Supreme Court reversed Defendant's conviction of fetal murder and affirmed his convictions of ten counts of murder, holding that hearsay was improperly admitted on the question of fetal viability.Defendant was convicted of murdering ten women and one viable fetus and sentenced to death. The primary issues on appeal were whether the trial court erred in admitting statistical evidence about the significance of DNA matches and in admitting hearsay testimony about the fetus's viability. The Supreme Court reversed the fetal murder conviction and otherwise affirmed, holding (1) the challenged testimony admitted in this case was hearsay, and the error in admitting the testimony was prejudicial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Turner" on Justia Law
People v. Flinner
The Supreme Court affirmed Defendant's conviction of first degree murder, conspiracy to commit murder and grand theft, mingling a harmful substance with food or drink, and solicitation to commit murder, and sentence of death, holding that any error was not prejudicial.Specifically, the Supreme Court held (1) Defendant's judicial bias claim failed; (2) the erroneous admission of certain statements and the possibly erroneous admission of a certain letter were cumulatively harmless; (3) there was sufficient evidence for the lying-in-wait special circumstance finding and the lying-in-wait first degree murder conviction; (4) any asserted juror misconduct did not, singly or in combination, substantially prejudice the trial's fairness; (5) the trial court did not err in finding that Defendant was competent to stand trial; and (6) Defendant's challenges to the constitutionality of California's Death Penalty Law were unavailing. View "People v. Flinner" on Justia Law
People v. Schultz
The Supreme Court affirmed the judgment of the trial court convicting Defendant of first degree murder and finding true the special circumstance allegations that the murder was committed while Defendant was engaged in the commission of rape and burglary and sentencing Defendant to death, holding that the errors committed during the trial proceedings were not prejudicial.Specifically, the Supreme Court held (1) assuming for the purposes of argument that a recording of the victim's last telephone call and testimony regarding DNA extraction should not have been admitted, any error was harmless; (2) assuming that portions of correspondence to Defendant were inadmissible hearsay, Defendant was not prejudiced by any error in the admission; (3) the prosecution committed misconduct by eliciting statements from a rebuttal witness during the penalty phase regarding the contents of one of those pieces of correspondence, but the trial court did not abuse its discretion in denying Defendant's related motion for a mistrial; and (4) the cumulative effect of those asserted errors was harmless. View "People v. Schultz" on Justia Law
People v. Peterson
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
People v. Silveria
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
People v. Suarez
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
People v. Duong
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
People v. Morales
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
People v. Henderson
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
People v. Vargas
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