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Name: People v. Jennings
Case #: E030778
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 10/02/2003
Subsequent History: None

Appellant, the mother of the five-year-old victim, was convicted along with the victim’s father of first degree murder under circumstances indicating severe abuse and neglect. Admitted at their joint trial were several hearsay statements made by the father during a joint interrogation that implicated appellant in the abuse. During the joint interrogation, there were several occasions during which appellant sat silent when the father said they had both been “overzealous” in their discipline of the victim, that appellant didn’t intend to kill the victim but was involved, that appellant was abusive, and that her conduct might have contributed to the death. On appeal, appellant argued that her trial should have been severed from father’s because of the Aranda/Bruton violation arising from the use of father’s statements implicating her. The appellate court here found that the statements were not admissable as adoptive admissions, and admission of the statements against mother was error under Aranda/Bruton. However, the error was harmless because the father admitted that most of the improperly admitted accusations were lies, and the other statements tended only to minimize mother’s conduct.