People v. Navarette

Summary

The Supreme Court of California reviewed Martin Anthony Navarette's automatic appeal from a judgment of death following convictions for two first degree murders and related offenses. The court addressed pretrial issues including change of venue, voir dire limitations, and alleged juror bias, and affirmed the judgment.

Holdings

1. The trial court properly denied the motion for a change of venue or intracounty transfer because defendant did not show a reasonable likelihood of an unfair trial or actual prejudice.
2. The trial court did not abuse its discretion in limiting the juror questionnaire, conducting voir dire, excusing one juror for cause, retaining another juror with a hearing concern, or addressing jurors' safety concerns.
3. The trial court did not abuse its discretion or violate the Fourth Amendment by admitting the challenged photographs, forensic evidence, testimony, and carport items, or by excluding inadequately founded lay opinions concerning cocaine intoxication.
4. Substantial evidence supported the convictions, special-circumstance findings, and required mental states despite evidence that defendant had consumed alcohol and smoked cocaine.
5. The trial court correctly instructed the jury on mental state, flight, robbery, voluntary intoxication, unconsciousness, and the burglary- and robbery-murder special circumstances.
6. The alleged prosecutorial misconduct did not require reversal because many claims were forfeited, the remaining conduct was not misconduct or was nonprejudicial, and the trial court gave appropriate admonitions where necessary.
7. The penalty-phase instructions and California's death-penalty scheme were not unconstitutional, and the penalty verdict was not affected by prejudicial prosecutorial misconduct.

Questions Presented

1. Whether the trial court erred by denying a change of venue or intracounty transfer.
2. Whether the trial court improperly limited voir dire, excused or retained prospective jurors, or handled juror-safety concerns in a manner that denied defendant an impartial jury.
3. Whether the trial court improperly admitted or excluded evidence, including photographs, forensic evidence, and lay opinions concerning intoxication.
4. Whether defendant's absence from in-chambers conferences violated his statutory or constitutional rights.
5. Whether substantial evidence supported the convictions, special-circumstance findings, and required mental states despite defendant's intoxication claims.
6. Whether the jury instructions concerning mental state, flight, robbery, intoxication, unconsciousness, and felony-murder special circumstances were erroneous.
7. Whether prosecutorial misconduct or cumulative error required reversal.
8. Whether the penalty-phase proceedings, instructions, and California's death-penalty scheme violated state or federal law.

Disposition

affirmed