People v. Taylor

Summary

The California Supreme Court reviewed Robert Clarence Taylor's automatic appeal from a death judgment following convictions for first degree murder, attempted murder, burglary, and robbery. The court addressed claims involving prosecutorial misconduct, crime-scene photographs and videotape, jury composition, victim-impact evidence, penalty-phase evidence, and severance, and affirmed the judgment in its entirety.

Holdings

1. The prosecutor's rape-victim hypothetical was responsive to defense questioning and did not cause prejudice, and the references to defense counsel's tricks or moves did not constitute an improper personal attack or prejudicial misconduct.
2. The trial court did not abuse its discretion by admitting the crime-scene photographs and videotape because they were relevant and their prejudicial effect did not clearly outweigh their probative value.
3. A new penalty-phase jury was not required because Taylor failed to show good cause as a demonstrable reality or that the existing jury was unable to perform its function; the trial court did not abuse its discretion.
4. The guilt-phase evidence concerning Kazumi's injuries and the penalty-phase evidence concerning the effects of Ryoko's death and Kazumi's injuries were admissible and did not render the trial fundamentally unfair.
5. Taylor was not entitled to severance or a separate penalty jury because he showed neither identifiable prejudice nor gross unfairness, and the instructions adequately required individualized consideration of each defendant's penalty.
6. The challenged penalty-phase instructions did not improperly omit burdens of proof, unanimity requirements, a presumption of life, mitigation principles, written findings, or instructions concerning life without parole, and the challenged sentencing procedures did not violate the state or federal Constitutions.
7. Because the court found no individual guilt-phase or penalty-phase error, there was no cumulative prejudice requiring reversal.

Questions Presented

1. Whether the prosecutor committed prejudicial misconduct during the guilt phase by posing a rape-victim hypothetical and by referring to defense counsel's alleged tricks or moves.
2. Whether the trial court abused its discretion by admitting crime-scene photographs and a videotape, and whether it adequately performed the Evidence Code section 352 balancing.
3. Whether the trial court improperly denied a motion for a new penalty-phase jury.
4. Whether victim-impact evidence was improperly admitted during the guilt or penalty phases.
5. Whether the trial court improperly admitted testimony concerning Taylor's earlier plan to commit a Corvette-related robbery and murder.
6. Whether Taylor was entitled to separate penalty trials or separate juries from codefendant DeWitt.
7. Whether the trial court improperly denied Taylor's motion to modify the death verdict.
8. Whether the penalty-phase instructions and procedures violated constitutional or statutory requirements concerning sympathy, delay, execution method, proportionality, burdens of proof, unanimity, mitigating evidence, aggravating factors, notice, written findings, and life-without-parole instructions.
9. Whether the cumulative effect of alleged errors required reversal.

Disposition

affirmed