People v. Harris

Summary

The California Supreme Court reviews the automatic appeal of Maurice Lydell Harris's convictions for attempted murder, multiple murders, robbery, and burglary, including a death sentence for the murder of Alicia Allen. Harris challenged jury selection and the admission of a videotape depicting the victim before her death. The court affirmed the judgment.

Holdings

1. A trial court may excuse a prospective juror whose views on the death penalty would prevent or substantially impair the performance of the juror's duties, and its determination is entitled to deference when supported by the record, particularly where the juror's responses are conflicting or equivocal.
2. When a witness is unavailable and the defendant had a prior opportunity and similar motive to cross-examine the witness at a prior proceeding, the prior testimony may be admitted consistently with the confrontation clause and Evidence Code section 1291.
3. Evidence of another person's motive or opportunity to commit a crime, without direct or circumstantial evidence linking that person to the actual perpetration, is insufficient to require admission as third-party culpability evidence.
4. The prosecutor did not commit reversible misconduct by seeking pretrial clarification of a possible defense-counsel conflict, contacting potential witnesses or their attorneys, litigating evidentiary issues, or making closing arguments supported by the evidence.
5. A trial judge's control of examination, evidentiary interventions, and questioning of a testifying defendant do not establish judicial bias absent conduct so prejudicial that it denies a fair trial or improperly allies the judge with the prosecution.
6. The trial court properly admitted relevant victim-impact evidence and properly limited arguments and evidence that were irrelevant, speculative, misleading, or invited consideration of improper emotional or societal-protection factors.
7. A trial court may direct a capital sentencing jury to continue deliberating when the record supports a reasonable probability that the jury can reach a verdict, provided the court does not coerce jurors to abandon independent judgment.

Questions Presented

1. Whether the trial court improperly excused prospective jurors whose views on the death penalty substantially impaired their ability to perform their duties.
2. Whether the trial court abused its discretion by admitting or excluding challenged guilt-phase and penalty-phase evidence.
3. Whether the admission of Canto's preliminary-hearing testimony violated the confrontation clause or hearsay rules.
4. Whether the prosecutor committed misconduct by seeking a conflict-of-interest hearing, allegedly interfering with defense witnesses, presenting or opposing evidence, and making arguments concerning motive and future dangerousness.
5. Whether the trial judge's comments, evidentiary interventions, and questioning of Harris demonstrated judicial bias or deprived Harris of a fair trial.
6. Whether the jury instructions concerning circumstantial evidence, victim impact, lingering doubt, prior criminal activity, remorse, and penalty factors were constitutionally adequate.
7. Whether the trial court improperly limited penalty-phase argument concerning juror responsibility, societal protection, and the manner of execution.
8. Whether the trial court abused its discretion by requiring further penalty deliberations rather than declaring a mistrial after reports of deadlock.

Disposition

affirmed