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Name: People v. Eddy
Case #: C085091
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 03/26/2019
Summary

A defendant has a Sixth Amendment right to maintain innocence as the objective of his defense and to insist that his counsel refrain from admitting guilt, even when trial counsel’s experience-based opinion is that confessing guilt might yield the best outcome at trial. Eddy and the victim got into an argument outside a friend’s apartment. A neighbor saw Eddy make stabbing motions towards the victim, who yelled “You stabbed me!” However, the neighbor did not see a weapon. Eddy quickly reentered the apartment to grab a bag before fleeing the scene and a witness did not see him discard anything. After police arrived, the knife used to stab the victim was found inside the apartment. Eddy was charged with first degree murder. In his opening statement, trial counsel maintained his client’s innocence. In closing argument, however, counsel conceded that Eddy committed voluntary manslaughter, but not first or second degree murder. The jury’s verdict was first degree murder. At a post-verdict Marsden hearing, Eddy asserted his attorney conceded guilt over his objection. Counsel acknowledged as much. Held: Reversed. A defendant has a Sixth Amendment right to assert the objective of his defense is to maintain his innocence, even in the face of trial counsel’s better judgment and experience. (McCoy v. Louisiana (2018) 584 U.S. __ [138 S.Ct. 1500].) The fact that Eddy did not consistently maintain his right to an innocence defense, or object to his counsel’s argument until after conviction, or testify in his own defense, is irrelevant when the record shows (1) the defendant’s objective to maintain his factual innocence, and (2) trial counsel disregards that objective and overrides his client by conceding guilt. The Marsden hearing transcript reflects that trial counsel knew Eddy did not agree with his strategy of conceding manslaughter, yet he overrode his client’s defense objective. Error of this kind is structural and not subject to harmless error review because it blocks the defendant’s right to make fundamental choices regarding his own defense. Reversal was required.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/archive/C085091M.PDF