People v. Houston
54 Cal. 4th 1186
| Cal. | 2012Background
- Houston was convicted of four first-degree murders with a multiple-murder special-circumstance finding and the deaths sentence; convicted of ten counts of attempted murder, with willful, deliberate, and premeditated findings for those, plus related enhancements and other felonies; sanity trial found sane; automatic death penalty appeal affirmed; major issues involve grand jury conduct, evidentiary admissibility, sufficiency of evidence, jury instructions on insanity, and penalty-phase misconduct.
- Hostage-shooting occurred at Lindhurst High School (1992) with premeditated planning, extensive weaponry, and coercive tactics; defendant claimed Brens’ alleged molestation and school failure as motive, while prosecutors emphasized premeditation and planning.
- Evidence included autopsies, police interrogations, audiotapes, a mission diagram, and writings; confession via videotaped interrogation; defense presented expert psychiatric testimony; prosecution rebuttal emphasized planning, motive, and control during killings.
- Trial court confronted multiple pretrial and trial claims including grand jury irregularities, oath administration, representation of minorities on grand jury venire, and the need for transcription of proceedings, all of which were deemed non-prejudicial or harmless under applicable standards.
- Court declined to reverse based on cumulative error, holding no reasonable possibility the errors affected the outcome; affirmed judgment of death for murder convictions and life sentences for attempted murders.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Grand jury underrepresentation violated rights | Houston claims minority underrepresentation in Yuba County grand juries. | No substantial underrepresentation shown; procedures lawful. | No prejudice; underrepresentation not shown to affect indictment. |
| Oath administration to prospective jurors | Oath may not have been properly administered to all jurors. | Record corrections show proper oath; harmless if incomplete. | Harmless error; no reversal. |
| Sufficiency of evidence for first-degree murder and attempted murder | Evidence shows premeditation, planning, motive. | Some acts may reflect rash impulse, not premeditation. | Evidence supports findings beyond a reasonable doubt. |
| Insanity instruction in sanity trial | CALJIC 4.00 and related language properly defined insanity. | Potential ambiguity about distinguishing right from wrong. | Instructional framing adequate; no error. |
| Prosecutorial misconduct and penalty-phase arguments | Remorse and emotional appeals appropriate mitigation considerations. | Closing comments improperly denigrate defense; improper emphasis on lack of remorse. | Forfeited or harmless; no reversal. |
Key Cases Cited
- People v. Booker, 51 Cal.4th 141 (Cal. 2011) (postconviction grand jury irregularities reviewed for prejudice; death-penalty context)
- Dustin v. Superior Court, 99 Cal.App.4th 1311 (Cal. Dist. Ct. App. 2002) (pretrial grand jury challenges may warrant relief without showing prejudice)
- People v. Carter, 36 Cal.4th 1114 (Cal. 2005) (failure to administer oath; harmless where seated jurors sworn)
- Bright, 12 Cal.4th 652 (Cal. 1996) (premeditation in attempted murder; notice and degrees issues)
- Arias, 182 Cal.App.4th 1009 (Cal. App. 2010) (indictment inadequacy on premeditation addressed similar to Mancebo)
- Mancebo, 27 Cal.4th 735 (Cal. 1995) (issues of notice and related sentencing consequences in attempted murder cases)