Justia Constitutional Law Opinion Summaries

Defendant was charged with a number of criminal violations. Defendant was represented by seven different appointed counsel over the course of approximately two years and made repeated requests for continuances. When his trial finally commenced, Defendant moved to dismiss his public defender and represent himself pursuant to Faretta v. California. The trial court granted the request but did not grant Defendant’s motion for a one-day continuance. Defendant failed to appear in court for the next day of trial. The trial court chose not to revoke Defendant’s status as his own counsel and did not reappoint counsel to represent him. The court then proceeded with the trial in Defendant’s absence. The jury convicted Defendant of some of the charges. The Court of Appeal reversed, concluding that the trial court erred by proceeding with trial in Defendant’s absence and without the reappointment of defense counsel and abused its discretion by denying Defendant’s motion for a one-day continuance. The Supreme Court reversed, holding that the trial court (1) acted within its discretion in proceeding with the trial after Defendant waived his constitutional right to counsel and his constitutional right to be present; and (2) did not abuse its discretion in denying Defendant’s request for a one-day continuance. View "People v. Espinoza" on Justia Law

After a jury trial, Defendant was convicted of several firearm-related and gang-related offenses. Defendant appealed, arguing that the trial court erred by admitting case-specific statements related by the prosecution expert concerning Defendant’s gang membership. Specifically, Defendant argued that the admission of this evidence violated the federal confrontation clause because the declarants were not unavailable and he had not previously cross-examined them. The Supreme Court reversed the jury findings on the street gang enhancements, holding that the admission of the case-specific statements constituted inadmissible hearsay under California law, and the error was not harmless beyond a reasonable doubt. Remanded. View "People v. Sanchez" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first degree murder. The jury found true five special-circumstance allegations, including that Defendant committed murder while engaged in the commission of a burglary and while in the attempted commission of a robbery. At a penalty phase retrial, the jury returned a verdict for death. The trial court sentenced Defendant to death. The Supreme Court vacated the burglary-murder and robbery-murder special-circumstance findings but otherwise affirmed the judgment in its entirety, holding (1) there was no prejudicial error in the selection of the jury; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) prosecutorial misconduct did not occur in this case; (4) the trial court did not err in instructing the jury during the guilt phase; (5) the evidence was insufficient to support the jury’s true findings as to two special-circumstances pertaining to one murder; (6) the evidence was sufficient to support the jury’s true findings as to the remaining special-circumstances allegations; and (7) there was no prejudicial error during the penalty phase of trial. View "People v. Clark" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, first degree burglary with use of a knife, and assault causing great bodily injury. Defendant appealed, arguing that the trial court violated his Sixth and Fourteenth Amendment rights by terminating his right to self-representation. The court’s rationale was that Defendant had been “dilatory” and had been “stalling.” The Supreme Court reversed, holding that the district court’s order was an abuse of discretion where the record was bereft of information to support the trial court’s revocation of Defendant’s pro per status, and thus, Faretta v. California and its progeny required reversal of the judgment. View "People v. Becerra" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder, attempted murder, twenty-six counts of robbery, two counts of attempted robbery, five counts of assault with a deadly weapon, and two counts of assaults with a stun gun. The jury returned a verdict of death, and the trial court imposed a judgment of death. The Supreme Court reversed one robbery count, modified the determinate prison sentence accordingly, and otherwise affirmed, holding (1) no reversible error occurred in the selection of the jury; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) the evidence was insufficient as to one of the robberies; (4) the evidence was sufficient to support the attempted murder conviction; (5) Defendant’s claims of instructional error failed; (6) no prejudicial error occurred during the penalty phase of trial; and (7) Defendant’s challenges to California’s death penalty law failed. View "People v. Sanchez" on Justia Law

In a joint trial with her codefendant, Defendant was convicted of premeditated murder and attempted premeditated murder. The court of appeal reversed Defendant’s convictions, concluding (1) the trial court erred in instructing the jury regarding a testifying defendant’s failure to explain or deny incriminating trial evidence; (2) the trial court erred in admitting Defendant’s codefendant’s out-of-court statement that he and Defendant went to shoot some gang members; and (3) the prosecution committed misconduct during closing argument in commenting about the reasonable doubt standard. The Supreme Court reversed, holding (1) the trial court properly gave the instruction at issue; (2) the trial court properly admitted the codefendant’s out-of-court statement; and (3) the prosecution’s comments on reasonable doubt did not constitute misconduct. View "People v. Cortez" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and of attempting to dissuade a witness from testifying. At issue during trial was Defendant’s intellectual ability. Following a penalty phase, the jury returned a verdict of death. The trial court sentenced Defendant accordingly. The Supreme Court reversed the conviction for dissuading a witness, vacated the witness-killing special-circumstance finding, and otherwise affirmed, holding (1) the trial court did not err in failing to reinstate competency proceedings based on certain testimony; (2) the admission of a psychiatrist’s testimony did not violate state law or Defendant’s federal constitutional rights; (3) the trial court did not prejudicially err in permitting three lay witnesses to testify that they did not categorize Defendant as intellectually disabled; (4) the trial court did not err in overruling defense objections to questions the prosecutor posed to a witness as to whether it was possible Defendant had received information on how to “fake” psychological tests while in jail; (5) the trial court committed prejudicial error in instructing the jury in regard to Defendant’s intellectual disability evidence, requiring reversal of the dissuading count and the witness-killing special-circumstance finding; and (6) no prejudicial error occurred during the penalty phase, and the death penalty is both lawful and constitutional. View "People v. Townsel" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment on appeal, holding (1) no prejudicial error occurred in the jury selection process; (2) substantial evidence supported Defendant’s convictions; (3) the trial court did not err in its evidentiary rulings; (4) the prosecutor did not engage in impermissible misconduct during closing argument; (5) the trial court did not commit prejudicial error in its instructions to the jury; and (6) Defendant’s challenges to California’s death penalty statute were without merit. View "People v. Rangel" on Justia Law

After a jury trial, Defendant was convicted of the first degree murder of a correctional officer and conspiracy to commit murder and to commit assault on correctional staff. The jury found true the special circumstance allegation that the murder involved the knowing and intentional killing of a peace officer engaged in the performance of his duties. The trial court sentenced Defendant to death on the murder count and to life with the possibility of parole on the conspiracy count. The Supreme Court affirmed, holding that no prejudicial error occurred during either the guilt or penalty phases and that any alleged error regarding pretrial issues was harmless. View "People v. Masters" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder, one count of conspiracy to commit murder, and one count of robbery. After a penalty trial, the jury returned a verdict of death. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to sever the three murder counts; (2) Defendant’s claims of error regarding jury issues were unavailing; (3) no prejudicial error occurred during the guilt phase of trial; (4) no prejudicial error occurred during the penalty phase of trial; (5) the trial court did not err in denying Defendant’s motion for new trial; and (6) any actual or assumed errors did not, considered altogether, deprive Defendant of a fair trial. View "People v. O'Malley" on Justia Law