People v. Capers
251 Cal. Rptr. 3d 80
Cal.2019Background
- In 1998 Lee Samuel Capers was tried and convicted by a San Bernardino jury of two counts of first-degree murder with multiple special circumstances (robbery-murder, burglary-murder, multiple murder) and related offenses; the jury returned a death verdict and the trial court imposed the death sentence. The appeal is automatic.
- Facts: victims Nathaniel and Consuelo Young were beaten, shot or bludgeoned, burned on-site, and their store was ransacked; .45-caliber bullets and other crime-scene evidence were recovered. Autopsies showed gunshot deaths for Nathaniel and blunt-force head trauma for Consuelo.
- Capers gave multiple extrajudicial statements and recorded interviews in which he variously denied involvement, minimized his role, and at times admitted shooting and burning the victims; he reenacted the crime scene for detectives. DNA from the scene matched the victims only; no eyewitness testimony placed Capers as the shooter.
- Defense sought to call Amber Renteria-Kelsey to testify that others (Loomis and Romero) had admitted responsibility; Renteria had earlier given statements and later recanted. The court found she had a valid Fifth Amendment privilege because she faced possible exposure under § 32 and dismissed her as a defense witness; the prosecutor declined to grant immunity.
- On appeal Capers raised challenges including (1) insufficiency/corroboration of his confessions (corpus delicti vs. federal corroboration), (2) denial of compulsory-process/Brady-type rights from excluding Renteria, (3) erroneous granting of Renteria’s Fifth Amendment claim, and (4) multiple constitutional challenges to California’s capital sentencing scheme. The California Supreme Court affirmed in full.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Capers) | Held |
|---|---|---|---|
| Adequacy of independent evidence to admit and rely on extrajudicial statements | Physical and circumstantial evidence (burned bodies, .45 bullets/casing, evidence of beating, stolen car found at Motel 6, corroboration of nonpublic details) satisfied corpus delicti and permitted jury to weigh confessions | Multiple inconsistent statements, substance abuse, medication, and alleged coercion rendered confessions unreliable and insufficient without independent corroboration (urges federal corroboration rule) | Affirmed: California applies corpus delicti rule (post-Prop 8) and independent evidence here was sufficient; credibility and inconsistencies are for jury to resolve. |
| Exclusion of defense witness (Renteria) / compulsory process violation | Prosecutor: Renteria’s testimony lacked credibility and immunity was inappropriate; court correctly permitted her to invoke Fifth Amendment | Renteria’s refusal to testify (after prosecutor’s statements) deprived Capers of compulsory process and materially prejudiced his defense | Affirmed: No prosecutorial intimidation; Renteria’s testimony would not have materially exonerated Capers; exclusion did not violate compulsory process. |
| Validity of Renteria’s Fifth Amendment assertion | Fifth Amendment & Evid. Code protect witness where testimony might tend to incriminate; court correctly applied Hoffman/Seijas standard | Statute of limitations had run on earlier false-report exposure, so privilege should not have been allowed | Affirmed: Court properly found reasonable fear of prosecution under § 32 based on recantations; the privilege was justified and trial fairness not compromised. |
| Constitutional challenges to California’s capital sentencing scheme (burdens, unanimity, instructions, Hurst/Ring implications) | State defends long-standing sentencing scheme and instructions as constitutional and consistent with precedent; Hurst/Ring do not mandate change here | Scheme is unconstitutionally broad/arbitrary; jury must have unanimous, beyond-a-reasonable-doubt findings for aggravating factors; Hurst/Ring require reconsideration | Affirmed: Court declines to revisit precedents; California scheme and instructions upheld and Hurst/Ring/Hurst-based claims rejected as inapplicable to California procedures. |
Key Cases Cited
- Opper v. United States, 348 U.S. 84 (federal rule requiring corroboration of accomplice/confession evidence discussed)
- Hoffman v. United States, 341 U.S. 479 (1951) (standards for assessing witness’s Fifth Amendment privilege)
- Washington v. Texas, 388 U.S. 14 (1967) (compulsory process right fundamentals)
- Kastigar v. United States, 406 U.S. 441 (1972) (use and derivative-use immunity principles referenced)
- People v. Alvarez, 27 Cal.4th 1161 (2002) (California corpus delicti doctrine and effect of Prop 8)
- People v. Martin, 44 Cal.3d 1 (1987) (compulsory process and prosecutorial interference analysis)
- People v. Prieto, 30 Cal.4th 226 (2003) (Ring/Apprendi line and capital sentencing jurisprudence)
- Ring v. Arizona, 536 U.S. 584 (2002) (jury factfinding on facts that increase punishment discussed)
- Hurst v. Florida, 136 S. Ct. 616 (2016) (distinguishing Florida scheme from California’s capital sentencing practice)