People v. Andreasen
153 Cal. Rptr. 3d 641
Cal. Ct. App.2013Background
- Eric Russell Andreasen appeals a murder conviction with a special circumstance alleging murder during attempted robbery.
- Defendant challenged guilt-phase evidence: admission of prior misconduct, insufficiency of evidence for attempted robbery, and a vagueness claim.
- During sanity phase, defendant contested the court’s rulings on instructions about refusal to be examined and the use of police statements post-Miranda.
- The record shows the victim, Katherine Parker, was fatally stabbed in a shopping-center parking lot on April 3, 2009.
- Uncharged misconduct evidence included panhandling assaults from 2004 and several incidents in 2009 preceding Parker’s murder.
- The trial court sentenced Andreasen to life without parole for the special circumstance, plus other determinate enhancements; a parole restitution fine was later stricken on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Vagueness of the felony-murder special circumstance | People contends statute provides sufficient notice and standards. | Andreasen argues overbreadth and potential arbitrary application by conflating with felony murder. | Vagueness challenge rejected; independent-felonious-purpose requirement distinguishes the special circumstance. |
| Sanity phase: Miranda and post-invocation statements | Statements from waiting-period conversations were properly admissible to rebut insanity. | Statements obtained after Miranda invocation should be suppressed and cannot rebut insanity. | No error; casual waiting-room conversations were permissible and not custodial interrogation after invocation. |
| Admission of prior misconduct evidence | Prior acts probative of identifying a pattern supporting the murder during attempted robbery. | Unduly prejudicial and improper character evidence. | No abuse of discretion; admissible uncharged misconduct to prove the murder during attempted robbery. |
| Parole revocation restitution fine | Fine should remain part of the judgment. | Fine should be stricken as unauthorized. | Parole revocation restitution fine stricken; amended judgment affirmed. |
Key Cases Cited
- Williams v. Garcetti, 5 Cal.4th 561 (Cal. 1993) (due process notice sufficiency; vagueness considerations)
- Bradway v. Superior Court, 105 Cal.App.4th 297 (Cal. App. 2003) (capital punishment narrowing statutes; arbitrary enforcement)
- People v. Gutierrez, 28 Cal.4th 1083 (Cal. 2002) (felony-murder vs. special circumstance distinctions)
- People v. Earp, 20 Cal.4th 826 (Cal. 1999) (distinction between felony murder and special circumstance; intent)
- People v. Riccardi, 54 Cal.4th 758 (Cal. 2012) (independent felonious-purpose requirement for special circumstance)
- People v. Mendoza, 24 Cal.4th 130 (Cal. 2000) (special circumstances; murder during burglary; independent purpose analysis)