People v. Murphy CA2/7
B330286
| Cal. Ct. App. | Jul 23, 2025Background
- Defendants Jaquan Murphy and Markey Lamont Smith, both Hoover gang members, were convicted by a jury for a gang-related shooting, including first degree murder, multiple counts of attempted murder, and conspiracy to commit murder after two incidents in April 2019 in Main Street Crip territory.
- The convictions were primarily based on testimony from accomplice Rayshawn Dale, surveillance footage (including evidence linking Murphy’s Ford Fusion to both shootings), and corroborative cellphone location analysis placing the defendants near the crime scenes.
- Murphy and Smith challenged the admissibility of gang evidence, the sufficiency of corroborating evidence for accomplice testimony, alleged prosecutorial Brady violations, and raised issues about Confrontation Clause and ineffective assistance of counsel.
- Smith’s incriminating statements to a jailhouse informant during a "Perkins operation" were admitted at trial; Murphy’s counsel did not object or seek to exclude these statements.
- The trial court admitted limited gang evidence to show motive and context; both defendants received lengthy prison sentences (Murphy: 100 years to life plus two life terms; Smith: 75 years to life plus one life term and eight months).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of Gang Evidence | Evidence necessary to show motive and context for shootings | Unduly prejudicial; not needed to prove elements of charged crimes | Properly admitted to prove motive; no abuse of discretion |
| Corroboration of Accomplice Testimony | Testimony corroborated by independent evidence (car, cell data) | Insufficient corroboration; only links to gang not the crime itself | Testimony sufficiently corroborated by other evidence |
| Brady Violation (Disclosure of Exculpatory Evidence) | All evidence presented at trial; nothing suppressed | Failure to disclose other drivers of Ford Fusion prejudiced defense | Claim forfeited; no ineffective assistance shown |
| Admission of Co-defendant's Jailhouse Statements | Smith’s statements to informant were non-testimonial | Admission of statements violated Confrontation Clause (Aranda-Bruton) | Not testimonial; no Bruton/Confrontation Clause violation |
| Sufficiency of the Evidence | Jury verdict supported by record (physical & circumstantial) | No direct evidence tying defendants to shootings | Substantial evidence supported convictions |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose exculpatory evidence to the defense)
- Miranda v. Arizona, 384 U.S. 436 (1966) (protects against self-incrimination during interrogation)
- Bruton v. United States, 391 U.S. 123 (1968) (Confrontation Clause bars use of co-defendant confessions at joint trials)
- Richardson v. Marsh, 481 U.S. 200 (1987) (statement admissibility depends on redaction and non-facial incrimination)
- Illinois v. Perkins, 496 U.S. 292 (1990) (statements to undercover informant are generally not protected by Miranda)