People v. Jones
7 Cal. App. 5th 787
Cal. Ct. App.2017Background
- Defendant Tramel Ray Jones (16 at time of offenses) was convicted of second-degree murder (one count) and two counts of attempted premeditated murder, with firearm and gang enhancements; aggregate sentence 80 years to life.
- Facts: shootings occurred Nov 21, 2012 and Feb 12, 2013 (attempts) and June 15, 2013 (murder). Physical evidence tied .40 casings from the first two scenes to a .40 Glock found in defendant’s father’s apartment; blood and clothing linked to the June shooting.
- Jones gave a recorded April 3, 2013 police interview in which he admitted gang membership, being present at the first two shootings, and supplying/returning the gun for those incidents, but denied being the shooter.
- Defense moved to suppress the April 3 statements as involuntary (coercion, deception, implied leniency, threats to his father); defense also raised Batson/Wheeler challenges after the prosecutor used peremptory strikes on three African-American prospective jurors.
- At sentencing the court imposed consecutive and concurrent life-with-parole-term enhancements; defendant challenged the aggregate 80-to-life as the functional equivalent of LWOP for a juvenile and sought Miller-related consideration.
- Court of Appeal affirmed convictions, upheld admission of the April 3 statement, rejected Batson/Wheeler challenge, and remanded for a Franklin determination about whether the record at sentencing adequately preserved youth-related evidence for future youth offender parole review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson/Wheeler: prosecution’s peremptory strikes of African-American jurors | Prosecution: strikes were for race-neutral reasons (youth, single/no children, prior hung jury) and other African-American jurors remained/seated | Jones: pattern of excusing Black jurors showed discriminatory purpose; reasons were pretextual | Court found no prima facie case; prosecutor’s reasons were race-neutral and credible; motion denial affirmed |
| Admissibility of April 3, 2013 statement (Miranda/voluntariness) | Prosecution: ruses and deception permissible; Miranda given and waiver implied; statements voluntary and not caused by promises/threats | Jones: juvenile coerced by false evidence, threats re: father, and implied promise of "a little time in camp" — rendering confession involuntary | Court upheld admission: Miranda waiver valid; totality shows statements voluntary; isolated camp remark and deceptive tactics did not proximately cause involuntary confession |
| Eighth Amendment / Miller challenge to 80-to-life sentence | Prosecution: statutes (§3051, §4801) and consideration of Miller factors at sentencing address youth concerns; sentencing stands | Jones: aggregate term is functional equivalent of LWOP for a juvenile and court failed to develop Miller record | Merits moot under Franklin because juvenile parole statutes provide meaningful opportunity; remand ordered for Franklin determination whether adequate youth-related record was made at sentencing |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (peremptory strikes may not be used to exclude jurors on basis of race)
- People v. Wheeler, 22 Cal.3d 258 (Cal. 1978) (state-law counterpart to Batson)
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (mandatory LWOP for juveniles unconstitutional; court must consider youth-related factors)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (juvenile LWOP for nonhomicide offenses violates Eighth Amendment)
- People v. Franklin, 63 Cal.4th 261 (Cal. 2016) (California: juvenile LWOP functional-equivalent claims mooted by §§3051/4801; remand for record-building when sentencing occurred before Franklin)
- People v. Lenix, 44 Cal.4th 602 (Cal. 2008) (deference to trial court’s evaluation of prosecutor’s stated reasons for peremptory strikes)
- People v. Farnam, 28 Cal.4th 107 (Cal. 2002) (statistical disparities alone may fall short of prima facie Wheeler showing)