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Name: Samia v. United States (2023) __ U.S. __ [143 S.Ct. 2004]
Case #: 22-196
Court: US Supreme Court
Opinion Date: 06/23/2023

Majority opinion: Justice Thomas delivered the opinion of the court, in which Chief Justice Roberts, and Justices Alito, Gorsuch, and Kavanaugh joined.
Concurring opinion: Justice Barrett joined the majority opinion in part and filed a separate opinion concurring in part and concurring in the judgment.
Dissenting opinions: Justice Kagan filed a dissenting opinion, in which Justices Sotomayor and Jackson joined. Justice Jackson also filed a dissenting opinion.

The confrontation clause does not bar the admission of a nontestifying codefendant’s confession where (1) the confession has been modified to avoid directly identifying the codefendant and (2) the court offers a limiting instruction.

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Name: People v. Jones
Case #: B279694
Court: CA Court of Appeal
District 2 DCA
Division: 7
Opinion Date: 08/21/2018

Murder conviction reversed where defendant's waiver of jury trial after bare two-question inquiry was not knowing and voluntary. Jones was convicted of second degree murder and child abuse following the death of her four-month-old daughter. On appeal she argued her waiver of jury trial was involuntary. Held: Reversed. A criminal defendant has a constitutional right to a trial by jury. This right may be waived but the waiver must be knowing and intelligent, that is, made with the awareness of the nature of the right being waived and the consequences of this decision. In determining whether a defendant has made…

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Name: People v. Rodriguez and Barajas
Case #: S239713
Court: CA Supreme Court
District CalSup
Opinion Date: 05/17/2018

Appellant Barajas's convictions for murder and related charges must be reversed because the only evidence connecting him to the crimes was uncorroborated accomplice testimony. Rodriguez and Barajas were convicted of first degree murder and other offenses based on evidence that they were involved in a gang-related, drive-by shooting of a bystander at a park. They were 15 and 16 years old, respectively, at the time of the offense. At trial, an accomplice testified that he was in the car with both defendants when Barajas fired multiple shots and shouted their gang name before speeding off. On appeal, Barajas argued that…

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Name: People v. Almeda
Case #: C077141
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 01/12/2017

Admission of cellmate's testimony relating defendant's incriminating statements did not violate his Sixth Amendment right to counsel because the cellmate was not acting under the government's direction. Villa and Almeda were charged with first degree murder for shooting a man parked in the car next to them at a stoplight. While in custody awaiting trial, Villa discussed details of the crime with his cellmate, Rhodes, who in turn reached out to the district attorney to offer Villa's statements in exchange for leniency for his own sentence. Rhodes, his attorney, and the prosecutor signed an agreement stating that the prosecution would…

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Name: People v. Washington
Case #: B270506
Court: CA Court of Appeal
District 2 DCA
Division: 2
Opinion Date: 09/05/2017

Admission in joint murder trial of codefendants' unredacted jail conversation implicating all defendants in the crime was proper because Crawford v. Washington (2004) 541 U.S. 36 confined the reach of the Aranda/Bruton doctrine to testimonial statements. Defendant and two other Blood gang members confronted a rival Crips gang member; defendant shot and killed the rival. All three defendants were charged with murder. At trial, the court admitted portions of a jailhouse recording between the two codefendants, which implicated defendant in the murder. The court instructed the jury not to consider the recording against defendant. Defendant was convicted of first…

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Name: People v. Smith
Case #: D069445
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 06/09/2017

Murder conviction reversed where trial court erroneously instructed the jury that any testimony from an accomplice requires corroboration before the jury may accept it as true. Smith and Mitchell were convicted of murdering a woman during a burglary. On their first appeal, their convictions were reversed. The California Supreme Court granted the prosecution's petition for review as to reversal of Mitchell's conviction and transferred the case to the Court of Appeal for reconsideration in light of People v. Grimes (2016) 1 Cal.5th 698. Held: Reversed as to Smith; affirmed as to Mitchell. Evidence Code section 1111 places a limitation on…

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Name: People v. Mohamed
Case #: B262627
Court: CA Court of Appeal
District 2 DCA
Division: 1
Opinion Date: 05/03/2016

Doctor charged with involuntary manslaughter for patient's death not entitled to instruction that his medical assistant was an accomplice. Mohamed gave a patient too many opioids to keep her sedated during a liposuction procedure and she died. His assistant, who administered the fatal dose at his direction, testified during his trial, as did experts who opined that his methods constituted "extreme negligence." A jury convicted Mohamed of involuntary manslaughter (Pen. Code, § 192, subd. (b)) and elder abuse. On appeal, Mohamed argued that his assistant was an accomplice, and that without her uncorroborated testimony there was insufficient evidence to support…

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Name: People v. Gonzalez
Case #: B255375
Court: CA Court of Appeal
District 2 DCA
Division: 4
Opinion Date: 03/30/2016
Subsequent History: Review granted 7/13/2016: S234377

Witness' statements to officer shortly after he witnessed a fatal shooting were admissible under the spontaneous statements exception to the hearsay rule. When officer Vasquez arrived at the scene of a robbery-murder about 12 minutes after it occurred, he encountered Ruiz, who witnessed the event and appeared to be in shock because he was pacing back and forth and speaking rapidly in broken sentences. Vasquez elicited statements from Ruiz, which ultimately inculpated appellants in the robbery-murder. Ruiz was unavailable for the trial. Over defense objections, the court permitted Vasquez to relay Ruiz's statements to the jury under the spontaneous statement…

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Name: People v. Huggins
Case #: A139104
Court: CA Court of Appeal
District 1 DCA
Division: 5
Opinion Date: 03/30/2015

An accomplice and an in-custody informant may corroborate each other's testimony. Huggins and Housley were both charged with robberies, one of which resulted in a murder. Housley, originally a codefendant, agreed to testify against Huggins as part of a plea bargain. An in-custody informant, who had been housed next to Huggins, also testified against him in exchange for a reduced sentence. At trial, Huggins requested an instruction that an accomplice and an in-custody informant cannot corroborate each other's testimony. The trial court refused to give the instruction and Huggins was convicted of murder and other offenses. On appeal, Huggins raised…

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Name: Arteaga v. Superior Court (Santa Clara County)
Case #: H040702
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 01/27/2015

Uncorroborated accomplice testimony can be sufficient to support the finding of probable cause necessary for a grand jury indictment. A grand jury indicted Arteaga on street gang and drug offenses. Arteaga moved to dismiss the indictment because the only evidence the grand jury received in support of the charges was uncorroborated accomplice testimony. The trial court denied his motion, and Arteaga petitioned for a writ of mandate and/or prohibition. Held: Petition denied. Penal Code section 1111 provides that a conviction cannot be based on the testimony of an accomplice unless it is corroborated by other evidence…

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