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People v. Ratliff, 41 Cal.3d 675, 715 P.2d 665, 224 Cal.Rptr. 705

Facts

On November 3, 1980, Los Angeles police responded to a robbery and murder at a gas station where the attendant was killed and another victim was wounded. The investigation led to defendant James Ratliff, whose car matched a license plate noted at the scene. Officers obtained consent to search his car, uncovering incriminating evidence including cash and stolen lamps. Victim Castro identified Ratliff as the assailant, and the jury found that Ratliff had used a firearm during the commission of the crimes.

In the early morning on Monday, November 3, 1980, Los Angeles police officers were summoned to a San Pedro gas station to investigate a robbery and murder. Attendant Estrada had been shot to death and his associate Castro wounded. Someone had managed to scribble a license plate number on the counter inside the cashier's booth, evidently in accordance with station manager Gomez' earlier directions to jot down the number of any “suspicious” vehicles.

Issue

Did the trial court err in its jury instructions regarding the necessity of intent to kill for the attempted murder conviction and the felony-murder special circumstance?

The Supreme Court held that: (1) fact that officers originally drew their guns when confronting defendant did not render defendant's consent to search invalid; (2) opportunity to demonstrate that photo lineup was unduly suggestive, rather than suppression of all identification testimony by victim, was proper remedy for officers' negligent failure to preserve photo lineup photographs; (3) failure of trial counsel to move to sever burglary count from remaining counts did not constitute prejudicial incompetence; but (4) implied malice instructions, in absence of instruction to jury that specific intent to kill was required for attempted murder, required reversal of attempted murder conviction; and (5) failure to instruct jury that felony-murder special circumstance permitting imposition of death penalty could not be found unless defendant intended to kill his victim required that death penalty be set aside.

Rule

The court held that implied malice instructions were inappropriate for attempted murder and that specific intent to kill must be established for a felony-murder special circumstance to apply.

In all other respects, we will affirm the judgment.

Analysis

The court determined that the jury was not properly instructed on the requirement of specific intent to kill for the attempted murder charge, which warranted a reversal of that conviction. Furthermore, the failure to instruct the jury that the felony-murder special circumstance could not be found without proof of intent to kill necessitated the vacating of the death penalty.

As will appear, we have concluded that the attempted murder conviction must be reversed, the special circumstances finding set aside, and the penalty of death vacated, due to instructional errors including the failure of the trial court to instruct regarding the necessity of finding an intent to kill.

Conclusion

The Supreme Court reversed the attempted murder conviction and set aside the death penalty, affirming the judgment in all other respects.

Reversed in part; affirmed in part.

Who won?

Defendant James Ratliff prevailed in part, as the court found significant instructional errors that affected the validity of his attempted murder conviction and the imposition of the death penalty.

Defendant first contends that the warrantless car search conducted by the officers immediately following defendant's arrest was illegal and that the fruits of that search should have been ordered suppressed.

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