Catlin v. Superior Court
51 Cal. 4th 300
| Cal. | 2011Background
- Catlin was sentenced to death for Martha Catlin and life without parole for Joyce Catlin; earlier murder convictions include ex-wife Glenna Catlin and another murder conviction.
- Legislature enacted Penal Code section 1054.9 in 2002, effective 2003, allowing postconviction discovery for death or LWOP inmates upon showing good faith efforts were unsuccessful.
- Catlin filed a 1054.9 discovery motion in August 2007, seeking materials the defendant would have been entitled to at trial.
- Trial court denied the motion as untimely due to four-and-one-half-year delay post-enactment; Court of Appeal denied mandamus challenging the denial.
- Issue presented: whether a trial court may deny a 1054.9 motion as untimely, given 1054.9 contains no timeliness provision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May a 1054.9 motion be denied as untimely? | Catlin (Petitioner) argues no timeliness limit exists. | People/Attorney General argue Steele implies a reasonable-time limit by context. | No; statute lacks timeliness bar; no reasonable-time limitation implied. |
| Does legislative history support a timeliness limitation? | Legislature intended broad discovery without time limits. | History shows concern about burden; amendment retained lack of time limits. | Legislative history supports no timeliness restriction. |
| How does Steele affect timeliness interpretation? | Footnote 2 may suggest a 'reasonable time' concept. | Footnote 2 merely relates to habeas timing, not a denial of discovery due to untimeliness. | Steele does not authorize untimeliness denial; it concerns timing of related petitions. |
| What are the policy implications of denying untimely discovery? | Delay risks loss of evidence; ensures potential relief if miscarriage found. | No special rule against delay; concerns about delay aiding obstructions to timely relief. | Postconviction discovery should not be denied as untimely; delay considerations belong to habeas petition evaluation. |
Key Cases Cited
- In re Steele, 32 Cal.4th 682 (Cal. 2004) (discovery timing and timeliness in capital postconviction)
- In re Robbins, 18 Cal.4th 770 (Cal. 1998) (timeliness of habeas petitions)
- In re Clark, 5 Cal.4th 750 (Cal. 1993) (timeliness and miscarriage of justice standards)
- Hill v. McDonough, 547 U.S. 573 (U.S. 2006) (equitable stays in death penalty cases)