History
  • No items yet
midpage
People v. Masters
62 Cal. 4th 1019
| Cal. | 2016
Read the full case

Background

  • Masters was convicted of first-degree murder of Sergeant Burchfield, conspiracy to commit murder and assault on prison staff, with a true finding on the special circumstance; the death penalty was imposed.
  • The murder occurred in San Quentin where Masters and other BGF inmates plotted to attack guards; weapons were inmate-made and linked to BGF members.
  • Willis, a key witness, testified about the conspiracy and provided notes in Masters’s handwriting; other inmates corroborated portions of the plan.
  • The defense challenged Willis’s identification and sought pretrial lineup opportunity; issues also involved severance from codefendants and the admissibility of coconspirator notes.
  • During the trial, prosecutors introduced extensive gang-related evidence about the BGF; Masters sought to present expert prison-culture testimony and challenged admissibility of unadjudicated offenses and other evidence.
  • The court ultimately affirmed the death judgment, rejecting challenges to identification procedures, immunity decisions, evidentiary rulings, and penalty-phase procedures.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Pretrial lineup rights and identification test Masters claims Willis’s identification was unreliable due to lineup denial. Masters asserts denial of lineup prejudiced his defense. No prejudicial error; identity credibility presented at trial.
Joinder and severance of co defendants Proffered statements by uncharged accomplices would contaminate trial of Masters. Severance required to protect codefendants’ rights. Denial of severance proper; no gross unfairness.
Immunity for witnesses (Richardson) Immunity should be granted to compel testimonial evidence. Judicial immunity authority is limited; prosecutors not obligated. No judicial or prosecutorial misconduct; immunity denied.
Admissibility of Richardson and Drume statements Statements against interest would bolster defense against Willis’s testimony. Statements unreliable and not trustworthy. Exclusion proper; statements inadmissible hearsay or unreliable.
Admission of BGF philosophy and unadjudicated offenses BGF philosophy and unadjudicated crimes contextualize conspiracy and motive. Some evidence unduly prejudicial; relevance limited. Evidence properly admitted; no reversible error; First Amendment rights not violated.

Key Cases Cited

  • People v. Abel, 53 Cal.4th 891 (2012) (timeliness and scope of pretrial lineup considerations)
  • Watson, 46 Cal.2d 818 (1956) (Watson standard for prejudice from evidentiary error)
  • Smith (GOV Virgin Islands), 615 F.2d 964 (3d Cir. 1980) (prosecutorial use immunity limits and proper remedies)
Read the full case

Case Details

Case Name: People v. Masters
Court Name: California Supreme Court
Date Published: Feb 22, 2016
Citation: 62 Cal. 4th 1019
Docket Number: S016883
Court Abbreviation: Cal.