People v. Dung Dinh Anh Trinh, 59 Cal. 4th 216

Trinh was convicted of three counts of first degree murder with special circumstances, one count of attempted murder, and firearm enhancements for shootings at West Anaheim Medical Center and nearby hospital-related locations.
Guilt phase evidence showed Trinh killed Mustaffa, Rosetti, Robertson and attempted Salvador; motive linked to perceived mistreatment of his mother Mot.
Defense presented caregiver burnout, cultural and family-structure context, and trauma as mitigation; mental state contested but guilt found beyond reasonable doubt.
Penalty phases: two hung juries, third jury returned a death verdict; victim-impact testimony and new/old penalty-phase evidence were presented.
Pretrial, Trinh sought recusal of the Orange County DA; court denied, appellate review affirmed no abuse of discretion.
On appeal, Trinh challenges multiple trial court rulings and the constitutionality of California’s death penalty scheme; the court affirms in full.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Recusal of the DA's office	Rackauckas had a conflict coalescing from his father’s hospitalization.	Conflict required recusal under §1424; stock public policy biased prosecution.	No abuse of discretion; no independent conflict proven.
Heat of passion instruction	Instruction pinpointed provocation from victim; standard wrongly limited.	Instruction correct but pinpoint helpful to defense.	Pinpoint instruction should have been given; error harmless.
Written copies of instructions	Right to written copies CALJIC 2.60/2.61; omission harmed due process.	Oral instructions suffice; omission is harmless and statutory right to written copies is satisfied by request.	Omission harmless; no due process violation.
Third penalty trial (life without parole)	Retrial undermines due process and equal protection.	Statutory scheme (190.4) allows retrial; not unconstitutional as applied.	Retrial authorized; no constitutional violation; not an abuse of discretion.
Batson/Wheeler discrimination in juror N.V.	Prosecutor struck N.V. for race; prima facie case shown.	Proffered race-neutral reasons credible; no discriminatory intent established.	No Batson violation; record supports race-neutral reasons; trial court erred in relying on non-record assumptions but ruling stands.

Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibition against race-based peremptory challenges)
Wheeler, 22 Cal.3d 258 (Cal. 1978) (California rule prohibiting race-based peremptory challenges)
Haraguchi v. Superior Court, 43 Cal.4th 706 (Cal. 2008) (section 1424 conflict standard and recusal review)
People v. Gamache, 48 Cal.4th 347 (Cal. 2010) (recusal review standard; deference to trial court discretion)
Purkett v. Elem, 514 U.S. 765 (U.S. 1995) (burden-shifting framework for Batson challenges)
People v. Williams, 56 Cal.4th 165 (Cal. 2013) (discusses standardless discretion in death-penalty scheme; constitutional considerations)
In re Anderson, 69 Cal.2d 613 (Cal. 1968) (equal protection/due process in death-penalty discretion context)