People v. Loy
52 Cal. 4th 46
| Cal. | 2011Background
- Defendant Eloy Loy was convicted of first degree murder with a special circumstance for killing Monique Arroyo, a 12-year-old, while engaged in a lewd act on a child under 14.
- Evidence showed Loy entered Monique's bedroom at night, sexually assaulted her, killed her by asphyxiation, and hid her body in a vacant lot about half a mile away.
- DNA and fiber analysis linked some physical evidence to Loy, including a bloodstain in his car trunk and fibers on a comforter used to cover the body; palm print on Monique's doorframe was found.
- The defense argued Loy was not involved; the state introduced prior sexual offenses (Ramona M. and L.S.) under Evidence Code 1108 to prove disposition and identity.
- During penalty, testimony from Monique's family emphasized the impact of her death; Loy's relatives testified to his character and background.
- The trial court admitted earlier sexual offense evidence, and the jury was instructed it could infer disposition to commit similar offenses but still must find guilt beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Caldwell error during jury selection | Prosecutor comments during selection could mislead jurors about responsibility. | Such Caldwell error undermines jurors' sense of responsibility for sentencing. | No Caldwell error; context shows instructions preserved responsibility and directed by penalty-phase instructions. |
| Admission of other crimes evidence under 1108 | Uncharged sexual offenses are highly probative and properly admitted to show disposition and identity. | Admission risks prejudice and could circumvent beyond-reasonable-doubt standard. | Court did not abuse discretion; 1108 permissible and properly balanced under 352; evidence admissible. |
| Victim's statement admissibility (hearsay) | Monique's statements to Sara Minor were spontaneous and admissible as not hearsay for truthful purposes. | Statement could be hearsay and violates confrontation rights; potential risk of error. | Assumed error; harmless beyond reasonable doubt under Chapman/Watson analysis. |
| Faulkner maggot-date testimony foundation | Expert could rely on method and related data to date maggot deposition. | Foundation for sample collection date was not proven; testimony relied on hearsay. | Error in overruling foundational objection; harmless beyond reasonable doubt; confrontation rights largely not violated. |
| CALJIC 2.50.01 instruction on prior offenses | Disposition evidence properly informs jurors under 1108 and related instructions. | Instruction could allow conviction based solely on prior sexual offenses. | Overall instructions viewed together did not permit conviction solely on prior offenses; no due process violation. |
Key Cases Cited
- Caldwell v. Mississippi, 472 U.S. 320 (U.S. Supreme Court 1985) (Caldwell error concerns misreading jurors’ sentencing responsibility)
- Darden v. Wainwright, 477 U.S. 168 (U.S. Supreme Court 1986) (juror responsibility in sentencing context)
- People v. Moon, 37 Cal.4th 1 (California Supreme Court 2005) (appellate review of Caldwell-type issues in juror instruction)
- People v. Falsetta, 21 Cal.4th 903 (California Supreme Court 1999) (authority on 1108 and admissibility of uncharged sexual offenses)
- People v. Story, 45 Cal.4th 1282 (California Supreme Court 2009) (guidance on 1108 and balancing; probative value vs prejudice)
- People v. Britt, 104 Cal.App.4th 500 (California Court of Appeal, 2002) (purpose and limits of 1108 in sex-offense prosecutions)
- People v. Reliford, 29 Cal.4th 1007 (California Supreme Court 2003) (prior offenses and reasonable-doubt framework; 1108 analysis)
- People v. Orellano, 79 Cal.App.4th 179 (California Court of Appeal 2000) (pre-1999 CALJIC 2.50.01 structure; admission cautions)
- People v. Regalado, 78 Cal.App.4th 1056 (California Court of Appeal 2000) (instructional handling of prior offenses and reasonable-doubt pairing)
- People v. Gutierrez, 45 Cal.4th 789 (California Supreme Court 2009) (confrontation clause and harmless-error framework)
- People v. Redd, 48 Cal.4th 691 (California Supreme Court 2010) (preservation and confrontation-rights analysis for hearsay)