People v. Baldwin, 189 Cal. App. 4th 991

Baldwin was convicted of murder and conspiracy to commit murder with gun and gang enhancements; a 25-to-life sentence on the murder plus a consecutive 25-to-life on the gun enhancement, with conspiracy and gang enhancements stayed.
Evidence included jail-cell recordings where Baldwin and Thurton discussed the case and implied involvement in the shooting; a key witness identified Baldwin as the shooter.
Prosecution presented witness identifications and physical evidence linking Baldwin to the crime; the defense claimed Thurton did the shooting and Baldwin was present but not involved.
The defense challenged four jurors for cause during voir dire and pursued peremptory challenges; the court denied those challenges and Baldwin expressed dissatisfaction with the empanelled jury.
The trial court admitted some jail-cell recordings of Thurton’s statements; it excluded inconsistent statements Baldwin made unless Baldwin testified.
On appeal, the court held there were no prejudicial errors requiring reversal and addressed the admissibility of inconsistent statements under Evidence Code 1202, ultimately affirming the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of challenges for cause to sitting jurors.	Bittaker/Yeanian framework requires reversal if cause challenges were denied.	Yeoman controls; defendant exhausted peremptories and was prejudiced.	No reversible error; Yeoman controls; no prejudice shown.
Admissibility of Thurton’s out-of-court statement implicating Baldwin.	Statement against Baldwin’s interest admissible as party admission.	Should be excluded as improper hearsay.	Admissible under rules governing party admissions; no reversible error.
Failure to instruct that Thurton was an accomplice whose statements should be viewed with caution.	Accomplice status warrants cautionary instruction.	No instruction needed or accurate under the record.	Not preserved or prejudicial; no error.
Exclusion of Baldwin’s inconsistent statements under Evidence Code 1202 absent his testimony.	1202 allows impeaching inconsistent statements even if declarant is available.	Cannot introduce inconsistent statements without Baldwin testifying.	Error deemed harmless beyond a reasonable doubt; judgment affirmed.

People v. Yeoman, 31 Cal.4th 93 (Cal. 2003) (limits on for-cause challenges and prejudice showing)
People v. Bittaker, 48 Cal.3d 1046 (Cal. 1989) (prejudice from denial of for-cause challenges; peremptories caveat)
People v. Crittenden, 9 Cal.4th 83 (Cal. 1994) (implications of challenge-for-cause and peremptory challenges)
People v. Avila, 38 Cal.4th 491 (Cal. 2006) (preservation of challenge for cause when sitting juror involved)
Chapman v. California, 386 U.S. 18 (U.S. 1967) (harmless-error standard for constitutional claims)
People v. Corella, 122 Cal.App.4th 461 (Cal. Ct. App. 2004) (Evidence Code 1202 impeachment of hearsay declarant)