People v. Curl

Summary

The California Supreme Court affirmed Robert Zane Curl’s first degree murder conviction and death sentence. The court held that Apprendi v. New Jersey and Ring v. Arizona did not supersede its prior ruling allocating determination of the constitutional validity of a prior guilty plea to the trial court and placing the burden on the defendant to prove invalidity by a preponderance of the evidence. The opinion also addresses claims concerning alleged prosecutorial misconduct, discovery, Brady material, and impeachment evidence related to a witness.

Holdings

1. Apprendi and Ring did not supersede the court's prior decision in Curl v. Superior Court. A defendant challenging the constitutional validity of a prior conviction must litigate that issue before the trial court and prove constitutional invalidity by a preponderance of the evidence; the issue need not be submitted to a jury or proved beyond a reasonable doubt.
2. The record did not establish that DeSoto committed perjury or that the prosecutor suborned perjury, and the prosecutor's notes did not contain discoverable or exculpatory material requiring disclosure. The trial court did not commit misconduct or abuse its discretion in declining to disclose the notes.
3. The trial court did not abuse its discretion by excluding Raymond Stevens's proposed testimony because testimony offered to assess DeSoto's credibility was inadmissible, and the proposed testimony concerning methods by which inmate informants might obtain information lacked an adequate factual foundation.
4. The trial court erred in admitting Detective Chavez's testimony under Evidence Code section 1235 and section 1202 did not provide a basis for admission. The error was harmless because the testimony was weak rebuttal and the evidence of Curl's guilt was powerful.
5. The court reaffirmed that California Penal Code sections 190.2 and 190.3 do not violate the Eighth, Fifth, Sixth, or Fourteenth Amendments by being overbroad, permitting arbitrary sentencing, lacking specified burdens of proof for all penalty determinations, failing to require intercase proportionality, or conflicting with international norms.

Questions Presented

1. Whether Apprendi v. New Jersey and Ring v. Arizona required the constitutional validity of Curl's prior murder conviction to be relitigated before a jury and proved beyond a reasonable doubt.
2. Whether the prosecutor committed misconduct or violated due process by failing to disclose notes concerning communications with and about inmate witness David DeSoto.
3. Whether the trial court abused its discretion by excluding proposed expert testimony concerning how inmate informants might obtain information and fabricate confessions.
4. Whether the trial court improperly excluded newspaper articles and limited cross-examination concerning DeSoto's possible motives.
5. Whether the trial court improperly admitted testimony concerning Steven Farmer's prior statement under Evidence Code section 1235 or section 1202, and whether any error was prejudicial.
6. Whether California's death-penalty statutes violated constitutional requirements concerning aggravating circumstances, proportionality, burden of proof, or international norms.

Disposition

affirmed