People v. Charles
61 Cal. 4th 308
Cal.2015Background
- Defendant Edward Charles III was convicted of three murders (father, mother, brother) and multiple-murder special circumstances; after four penalty trials, a jury returned a death verdict and the trial court denied modification under Penal Code §190.4(e).
- Prosecution evidence: bodies burned in family car; forensic evidence (wrench with defendant’s engraved symbol, blood, autopsies) tied defendant to the killings; defendant made jailhouse statements and a detailed letter (obtained from inmate Pincock) describing cleanup and disposal of bodies.
- Reporter Tony Saavedra visited defendant in jail, confronted him with portions of the letter behind a glass partition; defendant answered questions and explained passages but did not explicitly deny authorship at that time.
- Defense theory: defendant lacked motive/character to commit the murders and argued the jailhouse letter was not authored by him (forgery by Pincock); handwriting expert for defense disputed authorship; some defense witnesses offered alibi and character evidence.
- Procedural/ evidentiary disputes included admissibility of the jailhouse letter (adoptive admission and chain-of-custody), invoking California’s newsperson’s shield law by the reporter, claims of prosecutorial misconduct, multiple penalty retrials (court granted a fourth), and limits on family testimony at penalty.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of jailhouse letter (adoptive admission/chain of custody) | Letter is admissible: Saavedra confronted defendant, defendant responded to passages (adoptive admission); handwriting and corroboration (Speare, Hyatt/Hyatt testimony) support authorship. | Letter is forged by informant (Pincock); chain-of-custody and Saavedra’s partial showing of pages mean no adoptive admission; shield law invocation impeded cross-examination. | Court upheld admission: substantial evidence supported adoptive-admission finding; chain-of-custody objection fails; independent authentication (handwriting witness) also makes it admissible. |
| Newsperson’s shield law and confrontation rights | Shield law assertions did not prevent adequate inquiry; court applied Delaney balancing and permitted relevant questioning; no Sixth Amendment violation. | Reporter’s invocation of shield law prevented effective cross-examination of Saavedra, impairing confrontation and ability to impeach. | Court rejected the claim: trial court applied Delaney factors, no shown restriction that prejudiced defendant’s ability to challenge Saavedra. |
| Prosecutorial misconduct (presentation of false evidence; improper argument; denigrating defense counsel) | Prosecution did not knowingly present false evidence; letter corroborated; closing remarks were within bounds or were cured/sustained by rulings. | Prosecutor failed to investigate possible forgery, suggested unsupported motive (inheritance), and denigrated defense counsel. | Claims forfeited where no timely objection; meritless in substance—no evidence prosecutor knew letter was false; isolated arguments do not require reversal. |
| Trial instructions (motive; adoptive-admission; consciousness of guilt) | Instructions given were proper and consistent with precedent; adoptive-admission instruction helped jury evaluate letter. | Motive instruction shifts burden; consciousness/adoptive-admission instructions are argumentative or unconstitutional. | Court rejected challenges—followed settled California authorities and found no reversible error. |
| Granting fourth penalty trial under §190.4(b) | Retrial was proper; court properly exercised discretion weighing nature of crime, prior juror votes, mitigation record and absence of prejudice. | Fourth penalty trial was unfair/harassing, unprecedented; absence of new prosecution evidence should bar another retrial. | Court affirmed: no abuse of discretion—court balanced factors, rejected economic or harassment objections, and declined to import §1387 limitations. |
| Exclusion of family testimony about opposing death penalty | Prosecution: excluded testimony was either execution-impact evidence (inadmissible) or not character-based mitigation. | Family testimony showing they did not want defendant executed bears on character/mitigation and should be admitted. | Court held execution-impact evidence inadmissible; family testimony admissible only to the extent it relates to defendant’s character; any exclusion was harmless beyond a reasonable doubt. |
Key Cases Cited
- Delaney v. Superior Court, 50 Cal.3d 785 (Cal. 1990) (framework for balancing newsperson shield law against defendant’s needs)
- People v. DeHoyos, 57 Cal.4th 79 (Cal. 2013) (standard for reviewing adoptive-admission foundational findings)
- People v. Lucas, 12 Cal.4th 415 (Cal. 1995) (judge’s role in preliminary fact hearings under Evid. Code §402)
- People v. Carter, 30 Cal.4th 1166 (Cal. 2003) (CALJIC No. 2.71.5 instruction—trial court not required to give it sua sponte)
- People v. Bennett, 45 Cal.4th 577 (Cal. 2009) (execution-impact evidence is not admissible mitigation)