People v. Brown, 59 Cal. 4th 86

Background

Brown was convicted of first degree murder, sodomy, and forcible lewd act on a minor; special circumstances for murder during sexual offenses were found true; the trial concluded with a death verdict; the appeal is automatic under California law.
The victim, 11-year-old April Holley, was found drowned in a trailer bathtub with evidence of sexual assault and multiple injuries suggesting a struggle.
Witnesses placed Brown in the vicinity with the victim around the relevant time frame (evening of December 3–4, 1988), including drug use, an alibi timeline, and a car seen near the Holley trailer.
Forensic evidence showed drowning with signs of struggle and petechiae, and autopsy findings indicated multiple attackers as a possibility; sperm was found in the rectum, with some suspects excluded.
The defense presented alternative witnesses and challenged the credibility of key prosecution witnesses; Brown testified at the penalty phase and expressed a preference for death, but did not present mitigating evidence; the penalty phase proceeded without Brown’s presence, which was later deemed statutorily improper but constitutionally permissible under the waiver doctrine.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Dr. Miller’s ‘in association with sexual assault’ opinion	Brown contends Miller’s conclusion was improper expert opinion on a special circumstance.	Miller was qualified and his opinion aided jurors beyond common knowledge.	Admissible expert testimony, limited to context and causation facets.
Admission of Allen incident evidence via Lynn Farmer	Evidence showed common design linking Allen and the murder/assaults.	Allen incident is dissimilar and should be excluded as other-crimes evidence.	Court properly admitted only the party admission referencing the Allen incident; other details excluded.
Admission of Brown’s confession to Rhonda Schaub	Confession testimony is relevant to credibility and guilt.	Unreliable, untrustworthy hearsay indictment; credibility questions for jury.	Court properly admitted as a credible confession affecting weight, not admissibility per Alcala/Hovarter standards.
Ineffective assistance for foregoing mitigating evidence in penalty phase	Defense counsel’s strategy deprived Brown of mitigating evidence.	Brown knowingly waived mitigation; counsel complied with client’s wishes under Lang/ Bloom.	No ineffective assistance; waiver and strategic choice upheld under Schriro, Lang, and Bloom doctrine.
Defendant’s voluntary absence from penalty trial and constitutional rights	Defendant’s absence potentially violated Sixth Amendment and due process.	Waiver allowed absence; no constitutional violation.	Statutory error found, but no cognizable constitutional violation given valid waiver.

Key Cases Cited

Jones v. United States, 54 Cal.4th 1 (Cal. 2012) (expert qualifications; weight, not admissibility, standard for autopsy testimony)
Mayfield v. Superior Court, 14 Cal.4th 668 (Cal. 1997) (expert may opine on circumstances surrounding death judged from autopsy)
People v. Alcala, 4 Cal.4th 742 (Cal. 1992) (impeachment/credibility considerations for eyewitness testimony)
People v. Hovarter, 44 Cal.4th 983 (Cal. 2008) (limits on admitting unreliable testimony; credibility for jury’s weighing)
People v. Lang, 49 Cal.3d 991 (Cal. 1989) (defense counsel’s duty when client waives mitigation; impact on effectiveness claims)
People v. Bloom, 48 Cal.3d 1194 (Cal. 1989) (reliability of death verdict when mitigation offered or foregone)
People v. Sanders, 51 Cal.3d 471 (Cal. 1990) (effect of defendant’s waiver of mitigation on ineffectiveness claims)
In re Avena, 12 Cal.4th 694 (Cal. 1996) (waiver/competence considerations in death penalty case strategy)
Schriro v. Landrigan, 550 U.S. 465 (U.S. 2007) (defendant’s explicit mitigation waiver forecloses prejudice showing under Strickland)