People v. Masters
62 Cal. 4th 1019
| Cal. | 2016Background
- 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)
