People v. Huynh
212 Cal. App. 4th 285
Cal. Ct. App.2012Background
- Huynh convicted of first degree felony murder with two special circumstances tied to sodomy and oral copulation of Williams; DNA, semen, fibers, and tire-track evidence connected Huynh to the crime scene and the victims.
- Williams’s death autopsy showed undetermined cause; alcohol and benzodiazepine were implicated as contributing factors but not sole cause.
- Jeremiah R., a separate assault victim, provided crucial DNA and SART-examination evidence linking Huynh to the sexual assaults during intoxicated encounters.
- Evidence included Huynh’s lifestyle/declarations about drugging young men, motel/Adelita’s transactions in Tijuana, and matching physical evidence (clothing, blanket, tire tracks) to Huynh’s minivan.
- The defense challenged the corpus delicti and certain evidentiary and instructional issues; the trial court’s rulings are reviewed on appeal for sufficiency and instructional adequacy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of corpus delicti/cross-evidence for criminal agency | Huynh argues corpus delicti not proved due to undetermined autopsy | People asserts multiple independent and circumstantial factors show criminal agency | Sufficient evidence supports criminal agency |
| Substantial evidence linking sodomy/oral copulation to Williams | Insufficient linkage of semen and alive status to acts | Evidence including semen, DNA, and circumstances show guilt | Substantial evidence supports both sodomy and oral copulation convictions |
| Causation instructions in felony-murder context | Requests CALCRIM 730/240-like causation instructions warranted | Single-perpetrator felony murder does not require those causation-specific instructions | No error: standard felony-murder causation framework applied; additional instructions not required |
| Sixth Amendment confrontation via surrogate nurse testimony | Nelli’s testimony violates Crawford/Melendez-Diaz by relying on Kawachi's out-of-court findings | Photographs/expressions treated as non-testimonial objective facts; primary purpose not prosecutorial | Not a violation; surrogate testimony permissible under current Sixth Amendment standards |
| Notice/second-degree murder instruction | Entitled to second-degree murder instruction as lesser included | Evidence supports only first-degree felony murder; no substantial evidence of implied malice | No error; special circumstances and felony-murder findings establish first-degree murder; if any error, harmless |
Key Cases Cited
- People v. Towler, 31 Cal.3d 105 (Cal. 1982) (corpus delicti and inference of criminal agency despite inconclusive autopsy)
- People v. Kraft, 23 Cal.4th 978 (Cal. 2000) (corpus delicti and evidentiary sufficiency principles)
- People v. Jacobson, 63 Cal.2d 319 (Cal. 1965) (foundation may be laid by evidence creating reasonable inference of criminal agency)
- People v. Thompson, 50 Cal.3d 134 (Cal. 1990) (continuous transaction concept in felony murder)
- People v. Cavitt, 33 Cal.4th 187 (Cal. 2004) (felony-murder causation framework for inherently dangerous felonies)