People v. Contreras CA2/2
B321051
Cal. Ct. App.Jun 6, 2025Background
- The case involves the 2001 murder of 13-year-old Jacqueline P., who was abducted, sexually assaulted, and shot by members of the MS-13 gang in Los Angeles.
- Santos Grimaldi, Melvin Sandoval, and Rogelio Contreras were indicted in 2012 for Jacqueline's murder, with various gang and firearm enhancements.
- The first trial resulted in convictions for codefendant Palacios and a mistrial for the three appellants; retrial began in 2020, resulting in convictions for all three appellants, but with differing degrees of murder.
- Grimaldi and Sandoval were convicted of first-degree murder with special circumstances and sentenced to life without parole plus 25 years for firearm enhancements; Contreras was convicted of second-degree murder and sentenced to 40 years to life.
- The appellants raised numerous issues on appeal, including pre-charging delay, exclusion of evidence, jury instructions, sufficiency of the evidence, and sentencing errors.
Issues
| Issue | Defendants’ Argument | People’s Argument | Held |
|---|---|---|---|
| Pre-charging delay | Delay prejudiced defense as key witness died | Delay justified; no substantial prejudice shown | No actual prejudice; delay justified, conviction upheld |
| Grand jury exculpatory evidence | Indictment defective—prosecution withheld exculpatory information | Evidence omitted was inadmissible or speculative, not prejudicial | No substantial prejudice; indictment stands |
| Jury instructions (conspiracy/felony murder) | Instructions allowed conviction on invalid theory of liability | Instructions, read as a whole, properly directed jury to valid theories | No instructional error; not reasonably likely jury used legally invalid theory |
| Third-party culpability instruction | Failure to instruct jury allowed wrongful conviction; focused blame improperly | Existing reasonable doubt instructions sufficient; additional instruction duplicative/confusing | No error or prejudice; instruction not required |
| Admission/exclusion of evidence | Evidence of post-crime behavior & prior interviews mishandled; prejudicial | Evidence relevant to credibility; hearsay rules followed; rule of completeness not triggered | No abuse of discretion or due process violation |
| Prosecutorial misconduct | Failure to clarify witness inconsistencies created false testimony | Inconsistencies do not equal falsity; defense had chance to cross-examine | No misconduct; no due process violation |
| Sufficiency of evidence/Accomplice testimony | Alicia was an accomplice; her testimony uncorroborated, witnesses unreliable | Evidence against Grimaldi corroborated; jury resolved conflicts in testimony | Sufficient evidence; Alicia not accomplice as matter of law |
| Sentencing credits | Abstracts of judgment incorrectly stated credit days | N/A | Judgment modified to correct credits, otherwise affirmed |
Key Cases Cited
- People v. Alexander, 49 Cal.4th 846 (Cal. 2010) (Pre-charging delay and due process analysis)
- People v. Cowan, 50 Cal.4th 401 (Cal. 2010) (Review of prejudice and balancing for pre-charging delay)
- People v. Catlin, 26 Cal.4th 81 (Cal. 2001) (Delay and fair trial due process)
- People v. Chiu, 59 Cal.4th 155 (Cal. 2014) (Natural and probable consequences doctrine in murder liability)
- People v. Tewksbury, 15 Cal.3d 953 (Cal. 1976) (Accomplice defined for corroboration)
- People v. Benson, 52 Cal.3d 754 (Cal. 1990) (Interpretation of jury instructions as a whole)