People v. Metoyer CA4/3, G062772

Defendants Marius Reno Metoyer and Carl Dashawn Johnson, members of the Edgemont gang, were convicted of first-degree murder and attempted premeditated murder after a 2018 gang-related shooting at a mall in Moreno Valley, California.
The incident involved rival gang members; one victim, Reyes, was killed and another, Christopher, was wounded, but the prosecution could not prove whose shots caused Reyes's death.
The jury found several gang enhancements true, including special circumstances tying the crimes to furtherance of gang activity, resulting in life without parole sentences for both defendants.
On appeal, defendants challenged evidentiary rulings, sufficiency of the evidence, adequacy of statutory pleadings, adverse jury instructions, and sentencing enhancements.
The Court of Appeal affirmed in part, but reversed Johnson's murder conviction due to insufficient evidence under the sole causation theory given to the jury and reversed both defendants’ convictions for attempted premeditated murder due to improper notice of the premeditation allegation.
The case was remanded for resentencing of both defendants; all other aspects of the conviction were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Attempted Premeditated Murder Pleading	Notice was sufficient due to amended complaint and initial mutual request for jury instruction	Insufficient notice—premeditation was not properly pled in the operative charging documents	Reversed premeditation findings/life sentences—notice was insufficient
2. Sufficiency of Evidence for Johnson’s Murder Conviction	Causation could be inferred from both shooting at victim	Jury could not determine which defendant caused the death (direct causation only theory provided)	Reversed Johnson's murder conviction (insufficient evidence under given instruction)
3. Admission/Bifurcation of Gang Evidence	Gang evidence was necessary for enhancements and motive	Overly prejudicial; should have been fully bifurcated or excluded	No abuse—gang evidence was highly relevant; only required partial bifurcation
4. Exclusion of Photos of Victim with Guns	Proper exclusion; not relevant to events of the night; prejudicial	Their admission would support self-defense or habit evidence	No abuse—photos irrelevant without evidence victim was armed that night

People v. Houston, 54 Cal.4th 1186 (Cal. 2012) (section 664’s pleading requirement ensures notice for aggravated attempted murder)
People v. Bright, 12 Cal.4th 652 (Cal. 1996) (due process right to enhanced punishment notice)
People v. Anderson, 9 Cal.5th 946 (Cal. 2020) (importance of fair notice in pleading enhancements)
People v. Kunkin, 9 Cal.3d 245 (Cal. 1973) (criminal convictions on theories not presented to jury improper)
People v. Cole, 33 Cal.4th 1158 (Cal. 2004) (may not instruct jury on unsupported legal theory)
People v. Hernandez, 33 Cal.4th 1040 (Cal. 2004) (gang evidence admissible for motive)