People v. Rangel
62 Cal. 4th 1192
| Cal. | 2016Background
- On October 7, 1995, Pedro Rangel Jr. (defendant, "Big Pete") and his son ("Little Pete") entered Chuck Durbin’s home where Juan Uribe was visiting; both Uribe and Durbin were killed and Cindy Durbin wounded. Richard Diaz testified against defendant; Rafael Avila fled. Ballistics, statements, and weapons disposal linked defendant to the killings.
- Little Pete made post-crime inculpatory statements to relatives; Mary Rangel (defendant’s wife) made inculpatory statements later related by others; some statements were admitted at trial as declarations against interest and adoptive admissions.
- Defendant attempted to fabricate an alibi (video tape) and concealed weapons; he made inculpatory oral admissions to family members after the murders. An accomplice (Diaz) was convicted and testified; jury found defendant guilty of first-degree murder, multiple-murder special circumstance, and returned a death verdict.
- Defendant raised numerous pretrial, guilt-phase, and penalty-phase claims on appeal, including jury selection (representative cross-section), confrontation clause challenges to hearsay admissions, sufficiency of evidence on premeditation and firearm use, multiple instructional claims, and challenges to exclusion of mitigating/other evidence at penalty.
- The California Supreme Court reviewed procedural forfeiture issues, Crawford confrontation doctrine applicability, sufficiency of evidence for premeditation, instructional and prosecutorial-misconduct claims, and penalty-phase evidentiary rulings, and affirmed the judgment and death sentence.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Rangel) | Held |
|---|---|---|---|
| Representative cross-section/ jury panels | Selection procedure was lawful and random; no systematic exclusion shown | Calling panels in sequence underrepresented Hispanics and deprived fair cross-section | Court: claim forfeited (no timely objection) and in any event no systematic exclusion shown; no statutory randomness violation |
| Challenge to admission of hearsay (Little Pete, Mary Rangel) under Confrontation Clause | Statements were non-testimonial (not to law enforcement) and admissible as statements against interest/adoptive admissions | Admission violated Crawford — testimonial and denied confrontation | Court: Crawford not forfeited; statements were non-testimonial and admissible; no confrontation violation |
| Sufficiency of evidence of premeditation and firearm use | Evidence showed planning, entry to find Uribe, weapons, and defendant fired at Durbin — supports premeditation and firearm findings | Insufficient proof of premeditation for Durbin and no personal firearm use for Uribe | Court: substantial evidence supports premeditation for Durbin; jury rejected personal firearm-use allegation for Uribe but convictions stand |
| Failure to give or modify instructions (flight, manslaughter, accomplice corroboration, intoxication effects) | Court properly instructed; no sua sponte duty to give certain defenses; many claims forfeited or lacked substantial evidence | Trial court should have sua sponte instructed on third-party flight, voluntary/involuntary manslaughter, accomplice caution, and intoxication effects | Court: claims mostly forfeited or without merit; no sua sponte duty where no substantial evidence or where defendant declined certain instructions; any instructional errors harmless |
Key Cases Cited
- People v. Rogers, 39 Cal.4th 826 (discusses fair cross-section test)
- Duren v. Missouri, 439 U.S. 357 (Sup. Ct.) (standard for prima facie fair-cross-section claim)
- People v. Seaton, 26 Cal.4th 598 (no systematic exclusion where panel order was random)
- Crawford v. Washington, 541 U.S. 36 (testimonial hearsay and confrontation-clause principles)
- Ohio v. Clark, 576 U.S. (Sup. Ct.) (primary-purpose test for testimonial statements)
- People v. Bolin, 18 Cal.4th 297 (premeditation inference from circumstances and manner of killing)
- People v. Maciel, 57 Cal.4th 482 (denial of juror discharge reviewed for substantial-evidence support)
- People v. Cudjo, 6 Cal.4th 585 (statements against penal interest and limits on credibility inquiry)