People v. Casares, 62 Cal. 4th 808

Background

Defendant Jose Lupercio Casares was convicted by a Tulare County jury of the attempted premeditated murder of Alvaro Lopez and the first-degree murder of Guadalupe Sanchez, with the lying-in-wait special circumstance found true; jury returned a death sentence after penalty phase.
Facts: Casares recruited Lopez to obtain cocaine; during a meeting in a car Casares (back seat) produced a gun, ordered the drugs, shot Sanchez in the head at close range, and Lopez was stabbed and shot but survived. Fingerprints and the murder weapon linked Casares to the crime; he was arrested with the gun and cocaine.
Defense presented an alibi and third-party culpability theory implicating Gilbert Galaviz and Ruben Contreras; also argued some witnesses were untrustworthy and that certain testimony indicated a struggle rather than premeditation.
Penalty-phase aggravation included multiple prior violent incidents (shooting at an occupied vehicle, robberies, prior illegal gun possessions) and unadjudicated juvenile sexual misconduct (kidnapping/rapes of Rosa B.); mitigation focused on severe childhood abuse and psychological impairments.
The Supreme Court of California reviewed sufficiency of evidence for premeditation and lying-in-wait, evidentiary rulings (cross-examination limits, Fourth Amendment suppression), penalty-phase admissibility of prior acts, and multiple constitutional challenges to the death penalty scheme; it affirmed the conviction and death sentence.

Issues

Issue	Plaintiff's Argument (People)	Defendant's Argument (Casares)	Held
Sufficiency of evidence of premeditation / first-degree murder	Evidence of planning (cleaning gun, arming, ruse, ambush) and execution-style killing support premeditation	Killing was impulsive/occurred in a struggle; evidence insufficient to prove premeditation	Affirmed: substantial evidence supports premeditation and first-degree murder.
Sufficiency of lying-in-wait special-circumstance	Concealment of murderous purpose, watchful waiting, surprise attack shown by arming, ruse, back-seat position, immediate killing	Insufficient concealment and only fleeting watch/wait; victim not surprised; instruction error	Affirmed: evidence and CALJIC instruction adequate; issue for jury.
Cross-examination limitation re: witness' prior knife murder	Impeachment of witness bias/motive is proper and admissible; prior conviction facts not necessary	Needed to show third-party culpability because victim was stabbed; exclusion violated confrontation/presentation rights	No reversible error: trial court properly limited inquiry into conviction facts; other testimony established witness’ knife murder; no prejudice.
Fourth Amendment suppression of guns (Strawberry St. & Circle K)	Searches/detentions lawful/permissible; evidence admissible at penalty phase	Searches exceeded warrant scope or lacked reasonable suspicion; evidence should be excluded	Court found both searches violated Fourth Amendment but ruled errors harmless beyond any standard as to penalty-phase outcome.

Key Cases Cited

People v. Koontz, 27 Cal.4th 1041 (Cal. 2002) (Anderson factors and discussion of premeditation/deliberation)
People v. Anderson, 70 Cal.2d 15 (Cal. 1968) (framework for assessing planning, motive, and manner of killing for premeditation)
People v. Clark, 52 Cal.4th 856 (Cal. 2011) (standard of review for sufficiency of evidence)
People v. Streeter, 54 Cal.4th 205 (Cal. 2012) (upholding CALJIC lying-in-wait instruction and related reasonable-doubt/inference issues)
Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (Confrontation Clause—trial courts have latitude to impose limits on cross-examination for bias)
People v. Morales, 48 Cal.3d 527 (Cal. 1989) (elements of lying-in-wait special circumstance)
People v. Bacon, 50 Cal.4th 1082 (Cal. 2010) (analysis of firearm possession as factor (b) aggravation)
People v. Michaels, 28 Cal.4th 486 (Cal. 2002) (distinguishing lying-in-wait special circumstance from lying-in-wait murder theory)