People v. Cook CA4/1, D077072

Background

Defendant Timothy Cook rented a house where victim Omar Medina lived in a detached backyard room; Medina disappeared after a September 30, 2017, call and was later found dead in a 55‑gallon drum recovered from San Diego Bay.
Autopsy: Medina died of homicide from 66 stab wounds to head, torso, and arms.
Surveillance, receipts, and witnesses placed Timothy and co‑defendant Derrick Spurgeon transporting a large white cylindrical object by boat on October 11, 2017, and Timothy was seen cleaning/demolishing the house afterward.
Investigators recovered circumstantial physical evidence: Timothy’s DNA on a back‑door swab and on swabs from carpet pieces from the boat; a kitchen knife with blood (insufficient DNA for analysis); cleaning supplies, a tan pillowcase like the one in the drum, and landfill/boat receipts linked to Timothy/associates.
Statements and phone records: Timothy exchanged tense messages with Medina shortly before disappearance, lied about his whereabouts afterward, and allegedly made stabbing motions and admissions to a relative; a jailcall reported Spurgeon saying he “threw a body in the ocean.”
Procedural posture: jury convicted Timothy of second‑degree murder and a weapon enhancement; trial court imposed a total sentence of 56 years to life (Three Strikes and enhancements). The Court of Appeal affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to support murder conviction	Evidence—videos, phone/location data, DNA, purchases, cleaning/disposal conduct, admissions—supports murder with malice	Too many gaps; prosecution’s chain of inference rests on speculation about who actually killed Medina	Affirmed: circumstantial and direct evidence was sufficient; jury reasonably inferred Timothy committed the killing
Admission of blood spatter found Dec 13 search	Relevant to thoroughness of investigation and cleaning activity; probative value outweighs prejudice	Irrelevant, untimely discovery, not shown to be human blood, and unduly prejudicial under Evid. Code §352	If error, harmless under People v. Watson given overwhelming evidence of guilt; no reversal
Exclusion of proffered third‑party culpability evidence	(People) Proffered leads were speculative and lacked direct/circumstantial link to actual perpetrator; exclusion warranted under Hall and §352	(Timothy) Evidence (E.G.’s hostility, witnesses seeing others near barrel/marina) could raise reasonable doubt and impeach investigation	Affirmed: trial court did not abuse discretion—proffered evidence too speculative and risked mini‑trials; Hall requires linking third party to perpetration
Consciousness of guilt instructions (CALCRIM 362, 371)	Properly instructed jury on use/limits of false statements and attempts to hide evidence; non‑argumentative	Instructions duplicative of circumstantial evidence instructions, argumentative, or invite impermissible inferences	Affirmed: instructions proper and consistent with Supreme Court precedents; not unduly argumentative or impermissible
Cumulative error	N/A	Aggregate of claimed errors rendered trial fundamentally unfair	Rejected: errors were either not demonstrated or harmless; case not closely balanced

Key Cases Cited

People v. Hall, 41 Cal.3d 826 (third‑party culpability evidence need only be capable of raising a reasonable doubt; courts balance under Evid. Code §352)
People v. Watson, 46 Cal.2d 818 (harmless‑error standard for non‑constitutional errors)
People v. Doolin, 45 Cal.4th 390 (Evid. Code §352 abuse‑of‑discretion framework; undue prejudice defined)
People v. Page, 44 Cal.4th 1 (upholding consciousness‑of‑guilt instruction and rejecting claim it is argumentative)
People v. Howard, 42 Cal.4th 1000 (rejecting argument that consciousness‑of‑guilt instructions invite irrational inferences)
People v. Redmond, 71 Cal.2d 745 (standard for overturning verdict for insufficiency of the evidence)
People v. Knoller, 41 Cal.4th 139 (definition and discussion of malice for murder)