People v. Doolin

Summary

The California Supreme Court reviewed Keith Zon Doolin's convictions and death sentence for two murders and four attempted murders. The court rejected his claims, including an alleged conflict of interest arising from appointed counsel's compensation agreement, and affirmed the judgment in full.

Holdings

1. A lump-sum compensation agreement covering appointed counsel's fees and investigative and expert costs does not, by itself, create the inherent and irreconcilable conflict recognized in People v. Barboza where counsel represents a single defendant rather than multiple defendants with potentially conflicting interests.
2. California conflict-of-interest claims under the state Constitution are governed by the federal standard articulated in Mickens v. Taylor and Strickland v. Washington: the defendant must show deficient performance resulting from an actual conflict that adversely affected counsel's performance and a reasonable probability that, absent the deficiency, the result would have been different.
3. A presumption of prejudice is not appropriate for an asserted conflict arising from counsel's self-interest in a fee arrangement when the conflict does not involve multiple concurrent representation.
4. Appointment of second counsel in a capital case is statutory and discretionary, not constitutionally required; any assumed error in denying the request was harmless because defendant failed to show a reasonable probability or possibility of a more favorable guilt or penalty result.
5. The challenged cross-examination and rebuttal evidence was properly admitted to test the basis, weight, and credibility of the defense expert's character opinion and to impeach defendant's own testimony; the trial court did not abuse its discretion under the applicable Evidence Code provisions.

Questions Presented

1. Whether Fresno County's lump-sum compensation agreement for appointed capital counsel created an inherent or actual conflict of interest requiring reversal.
2. What standard governs conflict-of-interest claims under the California Constitution and whether the asserted fee-related conflict adversely affected counsel's performance and prejudiced defendant.
3. Whether the trial court abused its discretion or committed reversible error by denying defendant's request for appointment of second counsel in the capital case.
4. Whether the trial court improperly admitted character and rebuttal evidence, including cross-examination of a defense psychiatrist and evidence impeaching defendant and his mother.
5. Whether the admission of DNA evidence violated California's Kelly standard or was otherwise reversible error.

Disposition

affirmed