7 Cal. 5th 1054
Cal.2019Background
- Petitioner Jarvis J. Masters was convicted of first‑degree murder and conspiracy for the 1985 killing of San Quentin correctional sergeant Dean Burchfield; jury found special circumstance (killing a peace officer) and returned a death sentence. Masters’s convictions and sentence were affirmed on direct appeal (People v. Masters).
- Key prosecution witnesses were fellow Black Guerilla Family (BGF) inmates Rufus Willis (principal eyewitness) and Bobby Evans (corroborating witness); both received benefits or assistance tied to their cooperation and had extensive criminal histories.
- At trial, handwritten notes in Masters’s handwriting and other testimonial evidence tied him to planning/sharpening the weapon and passing messages; defense attacked witnesses’ credibility and presented alternative theories implicating other inmates (e.g., Harold Richardson).
- Masters filed a habeas petition alleging (inter alia) admission of false evidence, recantations/newly discovered evidence undermining guilt and penalty phases, prosecutorial coercion/Brady violations concerning promises to witnesses (Willis and Evans), and false penalty‑phase testimony about another killing.
- The Supreme Court appointed a referee, held an evidentiary reference hearing (witness depositions, experts, correctional and law‑enforcement testimony), accepted most referee factual findings, and discharged the order to show cause — denying habeas relief.
Issues
| Issue | Plaintiff's Argument (Masters) | Defendant's Argument (State) | Held |
|---|---|---|---|
| False evidence at trial (guilt phase) | Willis’s and Evans’s trial testimony was false; recantations and other posttrial statements show evidence was unreliable and material. | Referee and state: witnesses are chronic liars; recantations are not credible; jury saw witnesses and could assess credibility; any falsehoods were not materially likely to change outcome. | Court accepted referee’s credibility findings and held Masters did not prove materially false evidence that would probably alter verdict. |
| Newly discovered evidence (notes, weapon fabrication, other witnesses) | New linguistic analysis (Dr. Leonard) and inmate testimony show Masters did not author notes nor fabricate weapon; Richardson or others likely masterminds. | State: new testimony was largely incredible or speculative; even if notes not authored by Masters, that doesn’t exonerate him; evidence not decisive to change outcome. | Court held newly discovered evidence lacked the necessary credibility/decisiveness to more likely than not change result. |
| Brady / prosecutorial misconduct (undisclosed promises/coercion) | Prosecutors or investigators promised/ threatened Willis and Evans (or concealed Evans’s ties to investigator Hahn and his suspect status in unrelated homicide), undermining fairness and requiring disclosure. | State: material information about benefits/contacts was disclosed or known to defense; no credible proof of undisclosed coercive promises; impeachment value not sufficiently material under Brady. | Court found no Brady violation or prosecutorial misconduct sufficient to undermine confidence in verdict. |
| Standard of review / referee deference | Masters urged referee errors and urged crediting recantations/new evidence. | State argued referee’s findings supported by substantial evidence and entitled to deference; legal conclusions reviewed independently. | Court applied independent review to legal questions, gave great weight to referee’s factual findings supported by substantial evidence, and denied relief. |
Key Cases Cited
- People v. Masters, 62 Cal.4th 1019 (review of direct appeal and discussion of trial record)
- In re Cowan, 5 Cal.5th 235 (2018) (referee findings entitled to great weight when supported by substantial evidence; legal conclusions reviewed independently)
- In re Figueroa, 4 Cal.5th 576 (2018) (false‑evidence materiality standard: reasonable probability the result would differ)
- In re Roberts, 29 Cal.4th 726 (2003) (recantations viewed with suspicion; caution in overturning jury verdict on recantation)
- In re Richards, 63 Cal.4th 291 (new evidence materiality assessed by totality of circumstances)
- People v. Badgett, 10 Cal.4th 330 (1995) (limits on the permissibility of inducements and coercion for witness testimony)
- People v. Letner & Tobin, 50 Cal.4th 99 (2010) (prosecutor may present conflicting evidence; impeachment material must not be concealed)