People v. Manibusan, 58 Cal. 4th 40

Defendant Joseph Kekoa Manibusan was convicted by a jury of two counts of first degree murder, and one count each of attempted murder, aggravated mayhem, and second degree attempted robbery; special circumstances included multiple murder, drive-by murder, and felony murder, plus firearm enhancements.
The jury already returned a death verdict for the two murder convictions, which the trial court affirmed after denying automatic modification under Penal Code section 190.4, subdivision (e); appellate review is automatic.
Most guilt-phase evidence centered on events in Monterey County the night of Jan. 31–Feb. 1, 1998, including two homicides (Mathews and Olivo) and a fatal shooting of Aninger; Olivo survived with brain injuries.
During penalty phase, victim-impact evidence was presented, along with extensive prior-conduct evidence and defendant’s history of methamphetamine use and violence; defense presented 23 witnesses about his background and upbringing, while the prosecution rebutted with an expert on methamphetamine influence.
Juror No. 58 claimed safety concerns after a private observer tied to the defense family, leading to a voir dire and later request to remove her from the penalty phase; trial court conducted limited inquiries and declined to discharge her.
The Court of Appeal upheld the trial court’s rulings on juror bias, jury conduct claims, and the handling of jury questions, and affirmed the death judgment, rejecting multiple challenges to the trial process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror bias inquiry sufficiency	Manibusan argues the court should have conducted a second inquiry after the foreperson’s switch request.	Additional facts showed fear of retaliation; court’s silence violated due process.	No abuse of discretion; no new facts showing good cause to discharge
Juror discussions about defendant’s failure to testify	Discussions violated defendant’s rights by revealing his silence to jurors.	Testimony about deliberations revealed prejudicial stigma.	No reversible error; limits on admissibility of juror deliberations applied
Discriminatory peremptory challenges	Prosecution struck jurors based on race/gender; prima facie shown.	Peremptories lacked race/gender-neutral justification; systematic discrimination.	Court’s Batson analysis upheld; no reversible error given reasons were credible
Aggravated mayhem sufficiency	Evidence supported Willover’s and defendant’s intent to maim the victim permanently.	No substantial evidence of specific intent to maim; conviction for aggravated mayhem improper.	Aggravated mayhem affirmed; concurrence in part dissents on sufficiency
Use of electric stun belt during trial	Belt used without manifest necessity; possible prejudice.	Waived; no juror observed the belt; harmless error if any.	Waived; any error harmless given absence of juror awareness

People v. Dykes, 46 Cal.4th 731 (Cal. 2009) (jury-misconduct evidentiary standards; hearsay limitations)
People v. Hedgecock, 51 Cal.3d 395 (Cal. 1990) (standard for post-verdict evidentiary hearings on misconduct)
People v. Jones, 57 Cal.4th 898 (Cal. 2013) (circumstantial evidence standard; sufficiency review)
People v. Lenix, 44 Cal.4th 602 (Cal. 2008) (peremptory challenges; race-neutral justification standard)
Whalen, 56 Cal.4th 1 (Cal. 2013) (voir dire; evenhandedness in death-penalty questioning)
Sears, 62 Cal.2d 737 (Cal. 1965) (accomplice liability and must show specific intent to mayhem)
Santana, 56 Cal.4th 999 (Cal. 2013) (close-range firearm impact supporting intent to maim)
Park, 112 Cal.App.4th 61 (Cal. App. 2003) (evidence of intent to maim; related mayhem doctrines)