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Name: People v. Catlin
Case #: S016718
Court: CA Supreme Court
District CalSup
Opinion Date: 07/16/2001
Subsequent History: Modif. on 9/26/01; rehg. den. on 9/26/01
Summary

Appellant was not denied due process of law because there was a nine-year delay between the murder of his fourth wife and the prosecution. The delay was justified because there was insufficient evidence that appellant had poisoned his wife with paraquat until the similar poisoning of his mother occurred. Further, the justification for the delay far outweighed the weak showing of prejudice caused to appellant. Counsel was not ineffective for failing to suppress evidence seized during a warrantless search. Since the search in question was consensual, the motion would have been meritless. Counsel was not ineffective for failing to renew his motion for separate juries, since the motion would have been denied. Counsel’s failure to object to testimony concerning prior hearings did not constitute ineffective assistance of counsel, since there may have been tactical reasons not to object. Appellant was not denied his right to a public trial because the courtroom was cleared of spectators on 15 occasions. Failure to object to the procedure waived the issue on appeal. The failure of the prosecution to preserve a letter and a jar of tissue did not violate appellant’s right to due process of law. The evidence in question had minimal value to the defense, and there was no evidence of bad faith in connection with the loss. Penal Code section 190.2, subdivision (a)(19), the murder-by-poison special circumstance, does not violate the Eighth Amendment of the Constitution. The jury instructions on proximate cause were not erroneous because they allowed the jury to convict even if it found that a concurrent cause of death was circulatory disease. A defendant can be criminally liable for a result caused by his act, even though there is another contributing cause. The instructions did not relieve the prosecution of any of its burden of proof. The jury was adequately instructed on the definition of murder-by-poison. Even if the instruction was missing an element, any error was harmless. The trial court did not abuse its discretion when it overruled appellant’s objection to the pathologist’s testimony, based on an inadequate chain of custody regarding tissue removed from the body of appellant’s fourth wife. The chain of custody was adequately shown, and the medical opinions were not based solely on the tissue samples. Appellant was convicted of the murders of both his fourth wife and his mother. Special circumstances were also found true that the murder of his mother was for financial gain, that the murders were intentionally committed by the administration of poison, and that appellant was convicted of more than one murder. Appellant also admitted a special circumstance allegation which alleged the prior conviction for the murder of his fifth wife. Appellant was sentenced to death, and, in this opinion, the California Supreme Court affirmed the judgment in its entirety. The jury was properly instructed that they could consider evidence of the uncharged murder for the purpose of determining the cause of death of the victims in the charged offenses. The instruction did not permit the jury to rely on evidence of appellant’s criminal propensity, and did not direct them to determine the cause of death based solely on evidence of the uncharged murder. Appellant was convicted of the murders of both his fourth wife and his mother. Special circumstances were also found true that the murder of his mother was for financial gain, that the murders were intentionally committed by the administration of poison, and that appellant was convicted of more than one murder. The trial court did not err when it permitted expert opinion testimony regarding the causes of death of the victims. Both doctors had sufficient specialized training and expertise. Appellant was convicted of the murders of both his fourth wife and his mother. Admission of testimony by appellant’s third wife, Edith Ballew, was properly admitted. The testimony was not a confidential marital communication pursuant to the marital privilege because appellant and Ballew were not legally married, since appellant’s divorce from his second wife was not final when he and Ballew went through a marriage ceremony. Appellant was convicted of the murders of both his fourth wife and his mother. Special circumstances were also found true that the murder of his mother was for financial gain, that the murders were intentionally committed by the administration of poison, and that appellant was convicted of more than one murder. The doctrine of collateral estoppel did not bar the admission of evidence that appellant had received insurance proceeds following the death of his fifth wife. The evidence was admitted to establish facts regarding the murders of the fourth wife and mother, not to relitigate appellant’s responsibility for murdering his fifth wife. Appellant was convicted of the murders of both his fourth wife and his mother. The doctrine of collateral estoppel did not bar the admission of evidence that appellant had received insurance proceeds following the death of his fifth wife. The evidence was admitted to establish facts regarding the murders of the fourth wife and mother, not to relitigate appellant’s responsibility for murdering his fifth wife. Substantial evidence supported the trial court’s conclusion that the prosecutor had race-neutral reasons for excusing two African-American jurors, where the jurors expressed strong beliefs that only God had the right to take someone’s life. Appellant was convicted of the murders of both his fourth wife and his mother. Special circumstances were also found true that the murder of his mother was for financial gain, that the murders were intentionally committed by the administration of poison, and that appellant was convicted of more than one murder. Appellant was not prejudiced by the trial court’s error in directing that his motion for separate juries to hear the guilt and penalty phases of the trial be entertained only after the guilt verdict. The fact that counsel was forced to make a tactical decision regarding voir dire on the issue of the prior murder conviction, which would only be introduced at the penalty phase, did not constitute “good cause” for deviating from the clear legislative mandate that both phases of the trial be tried by the same jury. The trial court did not err when it denied a motion to sever two murder counts. There were strong similarities between the offenses, and neither crime was more inflammatory than the other. Further, the evidence would have been cross-admissible even in separate trials.