People v. Jones
51 Cal. 4th 346
| Cal. | 2011Background
- Albert Jones was convicted of two first-degree murders of James and Madalynne Florville with personal use of a deadly weapon, plus special-circumstance findings for robbery- and burglary-murder and a multiple-murder allegation; his penalty was death after a separate penalty trial.
- Prosecution alleged a December 13, 1993 Florville home invasion by Jones and A.J., a 15-year-old, involving hog-tying, stabbing, and property theft; witnesses described a neighborhood clique led by Jones who discussed robberies and used intimidation.
- Arroyo, a 14-year-old eyewitness, testified Jones and others drove to the Florville home, with time estimates and lighting conditions debated at trial; latex gloves linked to the crime were found, and glove evidence tied to Jones’s group.
- Defense challenged lighting, misstatements by the prosecutor, and other acts to impeach witnesses; rebuttal evidence on time of death and lighting was presented; a) timing disputes were addressed by expert testimony.
- At penalty, the prosecution presented evidence of other crimes including the 1985 Vernon robbery and the 1992 Delano robbery; defense presented deputies’ testimony about Jones’s conduct in prison; Batson/Wheeler issues were raised about peremptory challenges to African-American jurors, with the trial court accepting race-neutral explanations that the appellate court affirmed, albeit with a dissent.
- The court denied Jones’s motion to view the crime scene, admitted Vernon robbery evidence for intent, admitted latex-glove related evidence, and excluded videotapes showing lighting conditions for potential impeachment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson/Wheeler racial-bias claim | Jones (P) claims three African-American jurors were struck on race | Jones (D) argues pretextual, race-based strikes | No reversible error; race-neutral explanations credible |
| Admission of Vernon robbery to prove intent | Prosecution used Vernon to show intent to rob | Evidence inflamed prejudice; weak similarity | Within court’s discretion; probative for intent, not prejudicial |
| Admission of latex-glove classroom evidence | Glove evidence connects A.J. to crime | Irrelevant or prejudicial | Within discretion; probative linkage with limited prejudice |
| Exclusion of videotape lighting evidence | Tapes could impeach Arroyo on natural lighting | Tapes accurately reflect lighting conditions | Exclusion proper; tapes would mislead jurors; discretionary |
| Penalty-phase admission of uncharged Delano robbery | Evidence supports aggravation | Insufficient to prove beyond reasonable doubt | No error; evidence adequate; weighing proper |
Key Cases Cited
- People v. Lenix, 44 Cal.4th 602 (Cal. 2008) (reaffirmed deferential review of Batson I inquiry and credibility of race-neutral explanations)
- Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (emphasized considering all circumstances in Batson analysis; demeanor evidence not dispositive)
- Miller-El v. Dretke, 545 U.S. 231 (U.S. 2005) (comparative juror analysis; pretext concerns must be supported by record)
- People v. Cleveland, 32 Cal.4th 704 (Cal. 2004) (peremptory challenges cannot be race-based; one strike based on race is improper)
- People v. Kelly, 42 Cal.4th 763 (Cal. 2007) (admission of other-crimes evidence requires sufficient similarity for purpose; discretion of trial court on 352 balancing)