People v. Linton
56 Cal. 4th 1146
Cal.2013Background
- Defendant Daniel Linton was convicted of Melissa Middleton's 1994 murder, with special-circumstance findings and a death verdict; other charges included prior assault, burglary, and rape-related acts.
- Middleton home entry occurred after defendant had care-taking duties; there was no forced entry and keys were later found in defendant's possession.
- DNA and physical evidence linked defendant to the crime (DNA on Melissa's underpants; Melissa's DNA on underwear; fingernail DNA from Melissa compatible with defendant).
- Defendant gave multiple statements: an initial bedroom interview (covertly recorded) and a later police-station interview after Miranda advisements; the defense asserted coercion and promise of leniency, which the court rejected.
- Defense argued panic attack/panic-related memory gaps; experts testified to neuropsychological impairment and potential suggestibility during interrogation; prosecution presented pathologists supporting strangulation via cord and manual methods.
- Penalty phase featured victim-impact evidence and mitigation witnesses; Mercado third-party culprit evidence was excluded; overall, court upheld the death sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the bedroom interview violated Miranda or voluntariness. | People-Linton argues the bedroom interview was custodial and coerced Miranda waiver. | Linton contends interrogation was custodial coercion** and that leniency promises tainted waiver. | Miranda waiver valid; statements voluntary; no custodial violation established. |
| Whether the police interrogation strategies rendered the later statements involuntary. | People argues totality of circumstances supported voluntariness. | Linton asserts coercive tactics and promises of leniency tainted subsequent admissions. | Voluntariness supported; no improper coercion proven. |
| Whether the trial court properly refused Dr. Leo and Mitchell as penalty-phase witnesses and limited Dr. Whiting's testimony. | State contends evidence of coercion/falsity of confession not sufficiently proven; Dr. Leo/Mitchell not needed. | Leo/Mitchell would illuminate lingering-doubt defenses; Whiting's testimony limited appropriately. | Court did not abuse discretion; Leo/Mitchell excluded; Whiting limited; no denial of penalty defense. |
| Whether exclusion of Mercado third-party evidence at penalty phase violated due process. | Evidence suggesting another intruder could negate lingering-doubt. | Mercado evidence relevant to mitigating lingering doubt. | Exclusion proper; evidence insufficiently linked to the crime and outweighed by confusion risk. |
| Whether the victim-impact and prosecutorial-argument portions of the penalty trial violated due process. | Victim-impact evidence and closing arguments are constitutionally permissible in penalty phase. | Victim-impact and rhetoric crossed into improper prejudice. | Victim-impact evidence permissible; closing-argument comments not reversible error. |
Key Cases Cited
- People v. Williams, 49 Cal.4th 405 (Cal. 2010) (standard for evaluating Miranda waiver and voluntariness)
- People v. Hamilton, 45 Cal.4th 863 (Cal. 2009) (guilty-plea/mitigation evidentiary standards in penalty phase)
- People v. D’Arcy, 48 Cal.4th 257 (Cal. 2010) (analysis of death-penalty procedures and mitigating factors)
- Payne v. Tennessee, 501 U.S. 808 (U.S. 1991) (limit on victim-impact evidence; admissibility in capital sentencing)
- United States v. Hall, 93 F.3d 1337 (7th Cir. 1996) (limits on use of social-science testimony in federal trials)