Otto Kaus

The case involved Bernard Lee Hamilton, who was convicted of first-degree murder, burglary, robbery, and kidnapping after the victim Eleanore Buchanan was found decapitated and with her hands removed; special circumstance allegations under the 1978 death penalty law were also found true, leading to a death sentence. The California Supreme Court affirmed the convictions on the underlying offenses but set aside the special circumstance findings and reversed the penalty judgment. The core reasoning centered on prejudicial error in the jury instructions regarding the requirement of intent to kill for the special circumstances, which violated standards established in cases like Connecticut v. Johnson, necessitating reversal of the death penalty portion while upholding the guilt phase.

criminal lawprocedure

The case involved the appeal of Steven Clark Silbertson from a judgment of death after his convictions for first-degree murder and robbery, along with a true finding on a robbery-murder special circumstance, for killing Randy Watkins during what began as a planned robbery at a 7-Eleven store. The California Supreme Court affirmed the guilt-phase convictions and related firearm-use findings but set aside the special circumstance allegation. The core reasoning was that, under the precedent of Carlos v. Superior Court, the robbery-murder special circumstance requires a finding of intent to kill, which was not properly established here.

criminal law

The case involved defendant David Rivera, who was convicted of murder on a felony-murder theory and burglary after a jury trial based on his alleged participation in a convenience store burglary during which a customer was stabbed and killed. The trial court admitted evidence of a prior armed robbery committed by the defendant to prove identity, along with his confession and a post-arrest statement to an officer, after finding that he had knowingly waived his Miranda rights. The California Supreme Court reversed the convictions, holding that the prior robbery lacked sufficient shared characteristics with the charged offenses to support an inference of identity under Evidence Code section 1101(b), as the common marks did not set the crimes apart from others of the same type. The court did not reach the Miranda or voluntariness claims in full detail but focused the reversal on the improper admission of the prior offense evidence.

criminal lawprocedure

The case involved defendant Michael Todd Leach, who was convicted of first-degree murder and robbery after he and an accomplice lured victim Michael Messer to a remote location under the pretense of a drug deal, then robbed and stabbed him 48 times, resulting in findings of torture and robbery-murder special circumstances and a death sentence under California's 1978 death penalty law. The California Supreme Court affirmed the judgment of guilt, including the convictions and special circumstance findings, but reversed the penalty phase judgment. The court's reasoning on guilt centered on the sufficiency of the evidence from accomplice testimony and Leach's own statements, the validity of aiding-and-abetting liability despite later-clarified jury instructions from People v. Beeman, and the rejection of claims regarding weapon-use findings and voluntariness standards for witness statements.

criminal lawprocedure

The case involved an agricultural employer, George Arakelian Farms, challenging the certification of the United Farm Workers as the employees' bargaining representative after a 1976 representation election. The employer raised multiple objections to the election process, four of which were summarily dismissed by the ALRB's executive secretary for failing to state a prima facie case, and the fifth was rejected after a hearing; the employer then refused to bargain, leading the board to impose a make-whole remedy for employee losses. On review, the California Supreme Court held that the summary dismissals were not subject to judicial scrutiny because the employer failed to timely exhaust administrative remedies by seeking board review or reconsideration. The court further upheld the make-whole remedy, finding that the board had correctly applied the standards from its prior J.R. Norton decision when reimposing the relief on remand. The ruling focused on procedural exhaustion requirements and the board's authority under the Agricultural Labor Relations Act.

labor & employmentprocedure

The case involved defendant Robert Lee Massie, who was charged with murder with special circumstances and other felonies including robbery and assault, and who sought to plead guilty to the capital charges shortly before trial despite his attorney's opposition. The trial court accepted the guilty plea and imposed a death sentence after a penalty trial. On appeal, the California Supreme Court reversed the judgment of death, holding that Penal Code section 1018 prohibits acceptance of a guilty plea to capital charges without the consent of defense counsel, as previously interpreted in People v. Chadd, and that the attorney's statements here did not constitute the required consent. The court reasoned that the statute's counsel-consent requirement serves as a safeguard against erroneous death sentences and must be strictly followed, regardless of the defendant's wishes. A dissenting justice argued that counsel's statements amounted to valid consent under the circumstances.

criminal lawprocedure