People v. Miracle
240 Cal. Rptr. 3d 381
| Cal. | 2018Background
- Defendant Joshua Miracle pled guilty to first-degree murder and assault with a deadly weapon, and admitted two special-circumstance and gang-enhancement allegations; at penalty phase the jury returned a death verdict.
- Miracle sought to plead guilty to the capital charge but his appointed counsel refused to consent; he invoked Faretta and the court granted self-representation while appointing advisory counsel (Joe Allen).
- The court authorized an expanded role for advisory counsel, who reviewed discovery, advised Miracle, and expressly consented to the guilty plea; the trial court accepted the plea pursuant to Penal Code §1018.
- At the penalty trial Miracle was heavily restrained in the courtroom (lockbox, waist chain, leg shackles); the court found a manifest need based on a record of violent in-custody incidents and testimony including a recorded cell extraction.
- Miracle raised several claims on appeal: that §1018 precluded receipt of his plea while he appeared pro se (advisory counsel consent inadequate); that visible restraints and denial of writing implements impaired his rights; challenges to California’s death-penalty jury instructions/statute; and challenges to restitution fines.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Miracle) | Held |
|---|---|---|---|
| Whether advisory counsel’s consent satisfies Penal Code §1018 so a capital defendant appearing pro se may enter a guilty plea | Section 1018 permits acceptance of a capital plea only with counsel’s consent; allowing advisory counsel to functionally act as counsel satisfies §1018 and avoids Faretta conflict | §1018’s plain terms require representation by (appointed) counsel; advisory counsel is not the defendant’s counsel and cannot bind defendant’s right to control penalty-phase strategy | Court upheld plea: “counsel” in §1018 can include advisory counsel when the court assigns counsel duties equivalent to appointed counsel and counsel consents after fully advising defendant; plea was knowing and voluntary |
| Whether visible restraints (lockbox, waist/leg chains) and denial of writing instrument violated defendant’s rights or require reversal | Court security interests and defendant’s violent jail history justified restraints; no prejudice shown because independent and extensive evidence of dangerousness existed | Restraints were excessive, interfered with participation and chilled mitigation presentation; visible shackles prejudiced jury | Court ruled restraints appropriate under manifest-need standard; no abuse of discretion and no prejudicial error established |
| Constitutional challenges to California’s death-penalty sentencing instructions and statutory scheme | State’s instructions and §190.3 procedures are constitutional; prior controlling precedents uphold narrowing, burden, unanimity, and instruction formulations | Various federal constitutional challenges (Eighth, Fifth, Sixth, Fourteenth) asserted to instruction phrasing and sentencing mechanics | Court reiterated settled law rejecting the challenges and declined to revisit prior holdings |
| Whether restitution fines should be reduced for inability to pay | Trial court properly imposed fines within statutory range; defendant forfeited challenge by not objecting and did not show inability to pay | Fines exceed statutory-minimum $200 and court failed to consider inability to pay | Forfeiture and lack of record proof of inability to pay: fines affirmed |
Key Cases Cited
- People v. Chadd, 28 Cal.3d 739 (Cal. 1981) (section 1018 requires counsel’s consent to capital guilty pleas; protects against erroneous death sentences)
- People v. Alfaro, 41 Cal.4th 1277 (Cal. 2007) (reaffirming Chadd and evaluating counsel’s refusal to consent to plea in capital case)
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (right to self-representation)
- Deck v. Missouri, 544 U.S. 622 (U.S. 2005) (visible shackling requires an individualized, essential state interest)
- McKaskle v. Wiggins, 465 U.S. 168 (U.S. 1984) (role and limits of standby/advisory counsel for pro se defendants)
- McCoy v. Louisiana, 138 S. Ct. 1500 (U.S. 2018) (counsel cannot concede guilt over defendant’s objection; client controls objective of defense)
- People v. Lomax, 49 Cal.4th 530 (Cal. 2010) (manifest-need standard for courtroom restraints)
- People v. Anderson, 25 Cal.4th 543 (Cal. 2001) (shackling claims and prejudice standard)