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People v. Cox, 53 Cal.3d 618, 809 P.2d 351, 280 Cal.Rptr. 692

Facts

On August 31, 1984, Tiequon Aundray Cox and an accomplice entered the home of Ebora Alexander and shot her along with three others, including two young children. The events leading to the murders involved a group of individuals who drove to the Alexander residence, where they planned to commit the killings. Witnesses observed the men entering the house and heard gunfire shortly after. The police later found the victims' bodies and linked the crime to Cox through ballistic evidence and a palm print.

A jury adjudged defendant Tiequon Aundray Cox guilty of the first degree murders of Ebora Alexander, Dietria Alexander, Damon Bonner, and Damani Garner (Pen.Code, § 187), and found a true special circumstance allegation that he committed multiple murders (Pen.Code, § 190.2, subd. (a)(3)). The murders occurred August 31, 1984, in the home of Ebora Alexander, preceded by the following events: About 5:30 or 6:00 that morning, Darren Williams and Horace Burns arrived at the residence of Ida Moore, where Lisa Brown was also present.

Issue

Did the trial court err in excusing jurors during the death penalty voir dire, deny the defendant a fair trial by shackling him during the proceedings, and fail to hold an evidentiary hearing regarding alleged juror misconduct?

The trial court did not erroneously excuse any prospective jurors on death penalty voir dire; defendant was not denied fair trial by being shackled or handcuffed during trial; and trial court was not required to hold evidentiary hearing as to alleged juror misconduct during death penalty deliberations where trial court was confronted not with conflicting evidence but with refusal of juror to aver under penalty of perjury statements she allegedly made to defense investigator.

Rule

The court applied the standards set forth in Witherspoon v. Illinois and Wainwright v. Witt regarding juror qualifications for capital cases, as well as the principle that a defendant should not be physically restrained in the jury's presence without a manifest need.

In Witherspoon, the United States Supreme Court approved a state's authority to exclude for cause all prospective jurors 'who made unmistakably clear (1) that they would automatically vote against the imposition of capital punishment without regard to any evidence that might be developed at the trial of the case before them, or (2) that their attitude toward the death penalty would prevent them from making an impartial decision as to the defendant's guilt.'

Analysis

The court found that the trial court properly excused jurors who expressed an inability to impose the death penalty, adhering to the standards established in prior case law. The court also determined that the shackling of the defendant, while not ideal, did not impair his right to a fair trial since the jury was not aware of the restraints and the defendant did not testify. Furthermore, the court concluded that the alleged juror misconduct did not warrant an evidentiary hearing as there was no conflicting evidence presented.

Viewing the voir dire in its entirety, we find the record sufficient to support the trial court's rulings. Defendant either bases his criticisms on excerpted portions of the voir dire, isolating particular answers out of context, or fails to accord due deference to the court's fact-finding role.

Conclusion

The Supreme Court affirmed the conviction and death sentence, concluding that the trial court's decisions were supported by the record and did not violate the defendant's rights.

Affirmed.

Who won?

The State prevailed in the case, as the Supreme Court upheld the conviction and death sentence, finding no reversible errors in the trial court's proceedings.

The Supreme Court, Arabian, J., held that: (1) trial court did not erroneously excuse any prospective jurors on death penalty voir dire; (2) defendant was not denied fair trial by being shackled or handcuffed during trial; and (3) trial court was not required to hold evidentiary hearing as to alleged juror misconduct during death penalty deliberations where trial court was confronted not with conflicting evidence but with refusal of juror to aver under penalty of perjury statements she allegedly made to defense investigator.

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