People v. Garcia, 129 Cal. Rptr. 3d 617

García was convicted in California Supreme Court of capital murder with special circumstances and related felonies linked to two home invasions in Torrance on May 8–9, 1993; death sentence affirmed on automatic appeal.
Kozak and Finzel homes were burglarized; L. survived a multi-hour hostage and sexual assault; Joseph Finzel was killed.
Evidence included weapon possession, fingerprints/glove marks, stolen jewelry, and ballistics linking Oregon seizure to the crimes.
Guilt phase and penalty phase included extensive testimonial and victim-impact evidence, including a videotaped presentation of L.’s life with Joseph.
Defendant challenged grand jury selection (Castaneda) and trial jury selection (Wheeler/Batson) as unconstitutional; issues also raised about victim impact and various death-penalty safeguards.
Overall, the trial court denied relief; California Supreme Court affirmed the judgment without reversing on the asserted grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Grand jury selection violated equal protection?	Castaneda shows underrepresentation and discrimination.	System was discriminatory and not neutral.	No constitutional violation; process nondiscriminatory.
Trial juror D.G. excused for cause due to death-penalty views?	Witt/Avila allow removal for impairment.	D.G. could follow instructions.	Supported; no error excusing for cause.
Prosecutor's early peremptory strikes of women violated Wheeler/Batson?	Pattern showed bias against women.	No prima facie case; reasons exist.	No prima facie Wheeler/Batson violation; sufficient non-group-specific justifications.
Victim impact evidence admissibility at penalty?	Proper context to illustrate the harm.	Potential for undue prejudice.	Admissible; no reversible error; evidence weighed properly.

Castaneda v. Partida, 430 U.S. 482 (U.S. 1977) (equal protection requires purposeful discrimination show in grand jury selection)
Duren v. Missouri, 439 U.S. 357 (U.S. 1979) (Sixth Amendment fair cross-section; scope for grand juries)
Witherspoon v. Illinois, 391 U.S. 510 (U.S. 1968) (exclude jurors for general objections to death penalty not allowed)
Vasquez v. Hillery, 474 U.S. 254 (U.S. 1986) (fatal error when grand jury selection violates equal protection; reversal per se in some contexts)
Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibition of race-based peremptory strikes; requires neutral justification at stage two)
People v. Wheeler, 22 Cal.3d 258 (Cal. 1978) (state Wheeler standard for jury selection bias against cognizable groups)