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defendanttrialvoir diremitigating circumstancescapital punishment
defendantattorneytrialvoir diremitigating circumstancescapital punishment

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People v. Cash, 28 Cal.4th 703, 50 P.3d 332, 122 Cal.Rptr.2d 545, 02 Cal. Daily Op. Serv. 6649, 2002 Daily Journal D.A.R. 8329

Facts

In June 1985, Randall Scott Cash sublet a room from Bud Smith, a cocaine dealer, and began to exhibit erratic behavior due to financial difficulties and substance abuse. After a series of events leading to a confrontation, Cash shot Smith and attempted to murder Smith's girlfriend, Susan Balestri, before stealing money and drugs. Cash was later arrested with evidence linking him to the crime, including cash and cocaine from Smith's residence.

A jury convicted Randall Scott Cash of the first degree murder of Bud Smith (Pen.Code, § 187), and it found true a special circumstance that the murder was committed in the course of a robbery (§ 190.2, subd. (a)(17)(A)). The jury also convicted defendant of the attempted murder of Susan Balestri (§§ 664/187). With respect to both the murder and the attempted murder, the jury found that defendant personally used a firearm (§ 12022.5). It also found that in committing the attempted murder, defendant personally used a deadly and dangerous weapon (§ 12022, subd. (b)), and personally inflicted great bodily injury (§ 12022.7).

Issue

Did the trial court err in restricting voir dire questions regarding prospective jurors' views on the death penalty in relation to the defendant's prior murders?

Did the trial court err in restricting voir dire questions regarding prospective jurors' views on the death penalty in relation to the defendant's prior murders?

Rule

Prospective jurors may be excused for cause if their views on capital punishment would prevent or substantially impair their duties as jurors. The court must allow sufficient inquiry to determine if jurors harbor bias regarding aggravating or mitigating circumstances.

Prospective jurors may be excused for cause when their views on capital punishment would prevent or substantially impair the performance of their duties as jurors. (Wainwright v. Witt (1985) 469 U.S. 412, 424, 105 S.Ct. 844, 83 L.Ed.2d 841.)

Analysis

The Supreme Court found that the trial court's prohibition on questioning jurors about their potential biases related to the defendant's prior murders was a significant error. This restriction prevented the defense from adequately assessing whether jurors could impartially consider the death penalty, given the defendant's history. The court emphasized that such inquiries are essential to ensure an impartial jury.

Here, the trial court's ruling prohibited defendant's trial attorney from inquiring during voir dire whether prospective jurors would automatically vote for the death penalty if the defendant had previously committed another murder. Because in this case defendant's guilt of a prior murder (specifically, the prior murders of his grandparents) was a general fact or circumstance that was present in the case and that could cause some jurors invariably to vote for the death penalty, regardless of the strength of the mitigating circumstances, the defense should have been permitted to probe the prospective jurors' attitudes as to that fact or circumstance.

Conclusion

The court affirmed the conviction for murder and attempted murder but reversed the death penalty due to the trial court's error in jury selection.

Thus, we must reverse defendant's judgment of death.

Who won?

The prevailing party was the defendant, Randall Scott Cash, in that the Supreme Court reversed the death penalty due to prejudicial error in jury selection.

The prevailing party was the defendant, Randall Scott Cash, in that the Supreme Court reversed the death penalty due to prejudicial error in jury selection.

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