People v. Daniels, 221 Cal. Rptr. 3d 777

Background

Defendant David Scott Daniels (self-represented at trial) was convicted after a court (bench) trial of multiple murders, robberies, carjacking, vehicle theft, and related enhancements; the superior court imposed two death sentences among other consecutive terms.
Daniels discharged counsel, filed a Faretta form, and repeatedly waived his right to counsel and to a jury for guilt, special-circumstance findings, and penalty; he declined advisory/standby counsel and presented no defense at guilt or penalty phases.
The trial court conducted oral colloquies addressing dangers of self-representation and asked Daniels if he understood he was waiving jury trial; Daniels repeatedly answered that he did.
The record contains no signed written jury-waiver form, no detailed explanation on the record of jury mechanics (e.g., 12 jurors, unanimity, hung jury), and no indication that counsel had discussed jury mechanics with Daniels before he discharged counsel.
The California Supreme Court plurality concluded Daniels’s penalty-phase jury-waiver was invalid (requiring reversal of the death sentence); a divided court addressed whether the guilt-phase and special-circumstance jury waivers were knowing and intelligent and whether other waivers (counsel) were valid.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Faretta (waiver of counsel)	People: court adequately advised; waiver was voluntary, knowing, intelligent	Daniels: court failed to meaningfully inquire into understanding and complexities of capital trial	Waiver of counsel held valid — colloquies and signed Faretta warnings sufficient (court satisfied Lopez factors)
Waiver = "slow plea" / §1018 (guilty by conduct)	People: trial was adversarial; defendant put state to its proof; inaction is not a guilty plea under §1018	Daniels: by waiving counsel and jury and presenting no defense, he effectively pleaded guilty without counsel’s consent	Waiver not a §1018 violation; defendant’s inaction did not convert trial into forbidden guilty plea; no Eighth/Fourteenth reliability violation found
Validity of jury-trial waiver (guilt, special circumstances, penalty)	People: oral colloquies and defendant’s repeated affirmations (and prior criminal experience) show knowledge; no rigid script required	Daniels: record lacks affirmative evidence he understood jury mechanics (12 jurors, unanimity, hung jury); self-representation made court duty to ensure understanding greater	Divided: Majority (per curiam) and several justices find guilt/special-circumstance waivers valid; plurality (Cuéllar, joined by Liu in part) finds waivers — at least penalty waiver — not knowing/intelligent and reverses death sentence; overall result: death judgment reversed due to invalid penalty-phase jury waiver; remand for further proceedings
Legality of death sentence for second-degree murder (count 21)	People: sentence stands?	Daniels: death for second-degree murder is unauthorized	Death sentence for second-degree murder vacated; remand to reflect 15 years-to-life as correct sentence

Key Cases Cited

Faretta v. California, 422 U.S. 806 (U.S. 1975) (right to self-representation and requirements for valid waiver)
Collins v. People, 26 Cal.4th 297 (Cal. 2001) (waiver of jury trial must be knowing, intelligent, and voluntary; totality-of-circumstances review)
Sivongxxay v. People, 3 Cal.5th 151 (Cal. 2017) (recommended advisements; basic jury mechanics suggested for colloquy)
Barnum v. People, 29 Cal.4th 1210 (Cal. 2003) (limits on court-imposed prophylactic advisements to pro se defendants)
Chadd v. People, 28 Cal.3d 739 (Cal. 1981) (policy concern behind counsel-consent requirement for capital pleas)
Godinez v. Moran, 509 U.S. 389 (U.S. 1993) (competence standard for waiving counsel/guilty plea)
Patton v. United States, 281 U.S. 276 (U.S. 1930) (importance of jury trial and careful scrutiny in accepting waiver)
Rose v. Clark, 478 U.S. 570 (U.S. 1986) (complete deprivation of jury trial is structural error requiring reversal)