People v. Renteria CA2/8
B327157
Cal. Ct. App.Apr 14, 2025Background
- Rosalio Partida and Anthony Renteria, both members of the Tepa 13 gang, were tried and convicted separately for the 2016 first-degree murder of rival gang member Brandon Lopez, who was killed in Inglewood, CA.
- Both were implicated through their own confessions made to undercover agents in jail (Perkins operations), as well as other evidence such as eyewitness testimony, forensic evidence linking the murder weapon and car, and corroborating statements from a fellow gang member, Ramiro Chavez.
- Partida was convicted of first-degree murder and shooting at an occupied vehicle; Renteria was convicted of the same, with an additional firearm enhancement.
- On appeal, Partida challenged the sufficiency of evidence, admissibility of confessions, alleged trial errors (regarding accomplice instructions and witness testimony), and cumulative error; Renteria contested the voluntariness of his confession based on his youth.
- The prosecution cross-appealed to correct mandatory criminal assessments on the defendants' sentences.
- The Court of Appeal affirmed both convictions, ordered minor corrections to the judgments, and rejected all substantive challenges.
Issues
| Issue | Partida’s Argument | Prosecution’s Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for first-degree murder | Evidence insufficient to show premeditation/intent | Substantial evidence of planning, motive, participation, and statements shows intent | Sufficient evidence supported conviction |
| Admissibility of Perkins confessions | Statements should be excluded: Miranda, coercion, prior invocation of silence | Perkins applies: not custodial interrogation or coerced; statements were voluntary | Properly admitted; no Fifth Amendment or due process issue |
| Admissibility of Renteria’s Perkins statements at trial | Confrontation/due process violation; statements were testimonial | Non-testimonial, trustworthy, declarations against interest; admissible | Properly admitted as against penal interest, not testimonial |
| Jury instructions re: accomplices and corroboration | Accomplice status of Chavez and Renteria required corroboration instructions | Statutory/precedent standards not met; status not undisputed or required | No error; instructions properly left to jury determination |
| Admissibility of lay opinion re: Partida’s "pride" | Speculative, irrelevant, improper lay opinion | Relevant and based on direct observation; helps jury understand intent | Properly admitted; within court's discretion |
| Voluntariness of Renteria's confession | Confession was coerced due to youth, peer pressure, informant tactics | Age alone does not compel finding of coercion; confession voluntary | Confession voluntary; no coercion found |
| Correctness of financial assessments | Should allow new hearing on ability to pay under recent case law | Mandatory and can be corrected on appeal; no ability to pay issue shown | Judgments corrected; no remand for ability to pay required |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (Miranda rule re: custodial interrogation/admissibility of confessions)
- Illinois v. Perkins, 496 U.S. 292 (Perkins undercover jail operation exception to Miranda)
- People v. Brown, 31 Cal.4th 518 (Accomplice corroboration rules and hearsay declarations against interest)
- People v. Sanchez, 63 Cal.4th 411 (Intent inferences from circumstantial evidence)
- People v. Fayed, 9 Cal.5th 147 (Voluntariness of confessions; strategic deception permissible)