People v. Meza CA4/3, G063579

Defendant Cristian Gabriel Meza, along with other gang members, restrained, beat, and ultimately transported fellow gang member Frery Coronel to a remote location, where Meza repeatedly stabbed and choked him to death.
The prosecution charged Meza and six codefendants in the killing; some codefendants pleaded guilty and testified against Meza at trial.
At trial, the jury convicted Meza of first degree murder and found true special circumstances of both kidnapping and torture murder.
The main legal challenge on appeal concerned whether there was sufficient evidence to support the torture special circumstance (requiring proof of intent to inflict cruel/extreme pain for revenge, extortion, persuasion, or another sadistic purpose).
The appellate court reviewed the evidence, including medical testimony about Coronel’s many nonfatal wounds, testimony about the sequence of assault, and circumstantial evidence of motive.
The court affirmed the conviction and special circumstance findings, upholding a sentence of life without parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for torture-murder	Evidence showed deliberate, repeated infliction of nonfatal wounds plus binding/isolating victim and revenge motive	Prosecution failed to prove Meza had specific intent to cause extreme pain for revenge	Sufficient evidence supports jury finding of torturous intent
Inference from circumstantial and medical evidence	Medical/autopsy evidence and context allow inference of intent to inflict pain	Inferences do not specifically show Meza’s intent beyond intent to kill	Circumstantial evidence plus Meza’s statements and actions sufficiently show sadistic intent
Motivation for killing (revenge vs. other motives)	Evidence and context (gang orders, retention of wallet) indicate revenge was motive	No evidence Meza personally acted with revenge/sadistic purpose	Jury could reasonably infer revenge as motive given totality of facts
Jury instruction on torture special circumstance	Jury was properly instructed on required findings for torture-murder special circumstance	Not challenged as improper (procedural; included for issue mapping)	Properly instructed—no reversible error found

People v. Streeter, 54 Cal.4th 205 (Cal. 2012) (jury may infer torture intent from circumstances and victim's condition)
People v. Elliot, 37 Cal.4th 453 (Cal. 2005) (victim’s awareness of pain not required for special circumstance)
People v. Mincey, 2 Cal.4th 408 (Cal. 1992) (focus is on defendant’s torturous intent)
People v. Bemore, 22 Cal.4th 809 (Cal. 2000) (intent to inflict extreme pain can be inferred from circumstances and nature of wounds)
People v. Crittenden, 9 Cal.4th 83 (Cal. 1994) (nonfatal injuries constitute evidence of torturous intent)
People v. Proctor, 4 Cal.4th 499 (Cal. 1992) (manner of killing relevant to intent to torture)
People v. Hajek and Vo, 58 Cal.4th 1144 (Cal. 2014) (evidence of multiple nonfatal wounds supports sadistic intent)