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In re Harris, 5 Cal.4th 813, 855 P.2d 391, 21 Cal.Rptr.2d 373

Facts

Charles Harris was born on October 21, 1968, and committed the homicide-related crimes on October 20, 1984, just before his 16th birthday. Initially, the prosecution sought to try him in juvenile court but later requested a fitness hearing to certify him for adult court. The juvenile court found him unfit for juvenile trial and certified him to adult court, rejecting his argument regarding his age. Harris was subsequently convicted and sentenced in superior court, where he raised the issue of his age on appeal, which was partially successful.

Petitioner was born on October 21, 1968. The homicide-related crimes for which he was convicted occurred on October 20, 1984, the day before his 16th birthday.

Issue

Did the superior court lack subject matter jurisdiction over Harris because he was only 15 years old at the time of the offenses, and can he raise this issue in a habeas corpus petition after it was rejected on direct appeal?

Petitioner contends the trial court that convicted him lacked subject matter jurisdiction over him because he was only 15 years old when the offenses were committed.

Rule

Habeas corpus will not serve as a second appeal unless the claimed constitutional error is both clear and fundamental, striking at the heart of the trial process. The issue of whether a case should proceed in juvenile or adult court does not involve subject matter jurisdiction.

Habeas corpus will not serve as a second appeal unless the claimed constitutional error is both clear and fundamental, striking at the heart of the trial process.

Analysis

The court analyzed whether Harris could raise the issue of his age in a habeas corpus petition despite having previously raised it on direct appeal. It concluded that while the superior court had subject matter jurisdiction, the question of Harris's age at the time of the offenses could be considered under the 'excess of jurisdiction' exception to the general rule against using habeas corpus as a second appeal. The court determined that Harris was indeed only 15 years old when the crimes occurred, which could divest the superior court of jurisdiction.

The court analyzed whether Harris could raise the issue of his age in a habeas corpus petition despite having previously raised it on direct appeal.

Conclusion

The petition for a writ of habeas corpus was granted, and the case was remanded for a determination of a new disposition consistent with Harris's status as a juvenile at the time of the crimes.

Petition granted; remanded for determination of new disposition.

Who won?

Charles Harris prevailed in the case because the court recognized that he was improperly tried as an adult due to his age, which could have affected the jurisdiction of the superior court.

Charles Harris was convicted of second degree murder (Pen.Code, §§ 187, 189; all further statutory references are to the Penal Code unless otherwise indicated), seven counts of attempted murder (§§ 664, 187), and two counts of robbery (§ 211).

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