People v. MacIel
57 Cal. 4th 482
| Cal. | 2013Background
- Maciel convicted of five first-degree murders and multiple-murder/sentencing enhancements; death sentence imposed; automatic appeal under California law.
- Murders occurred April 22, 1995 at 3843 Maxson Rd, El Monte; victims Anthony Moreno, Maria Moreno, Gustavo Aguirre, Laura Moreno, Ambrose Padilla.
- Prosecution theory: Mexican Mafia influence; Cruz, Shyrock sponsorship; defendant allegedly conspired or aided and abetted but not present at the killings.
- Defense claimed alibi: baptismal party; defendant not present at the murders.
- Evidence included Mexican Mafia meetings, sponsor-relationship, heroin exchanges, pages to defendant, and numerous gang-affiliated witnesses.
- Guilt-phase and penalty-phase issues include consular rights, nondisclosure orders, counsel-discharge, evidentiary rulings on prior statements, and juror/disqualification matters.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for conspiracy to murder Moreno | People argues sufficient circumstantial proof of mutual understanding | Maciel contends evidence insufficient to prove conspiracy | Substantial evidence supports conspiracy and aiding-and-abetting theories |
| Consular rights notification claim | Avena/Medellin rights not shown in record; potential habeas relief | Need evidentiary hearing to establish nationality and prejudice | No evidentiary hearing required; consular-rights claim outside record; habeas petition appropriate |
| Nondisclosure orders and defense access to witnesses | Orders justified by safety and need to protect witnesses | Orders infringed confrontation/Discovery rights | Orders valid; defense had adequate avenues to investigate; no Sixth/Constitutional violation found |
| Motion to discharge retained counsel | Court should honor defendant’s right to discharge retained counsel | Discharge would disrupt justice; trial imminent | Court acted within discretion; denial of discharge affirmed |
Key Cases Cited
- People v. Ortiz, 51 Cal.3d 975 (1990) (right to discharge retained counsel presence of no irreconcilable conflict)
- People v. Verdugo, 50 Cal.4th 263 (2010) (standard for discharge of retained counsel; discretion to deny)
- Valdez, 55 Cal.4th 82 (2012) (protective orders; discovery; witness anonymity; adequacy of investigation)
- Mendoza, 52 Cal.4th 1056 (2011) (constitutional review of death-penalty verdicts; written findings not required)
- Dykes, 46 Cal.4th 731 (2009) (death-penalty standard and safeguards against arbitrariness)
- Engelman, 28 Cal.4th 436 (2002) (instruction about juror notification; not per se error)