People v. Rodriguez
58 Cal. 4th 587
| Cal. | 2014Background
- Defendant Angelina Rodriguez was convicted of first-degree murder of her husband Frank Rodriguez with special circumstances and attempted dissuasion of a witness, leading to a death sentence on automatic review.
- Evidence showed she poisoned Frank with ethylene glycol and oleander after obtaining life insurance on him and on a prior occasion attempted gas-related harm.
- Investigators used surreptitious recordings and ruses to elicit information, including Holloway-related calls and a fictitious middleman to test for preplanning.
- She also murdered her infant daughter Alicia in 1993 by suspected pacifier-related mechanism and later settled a Gerber pacifier lawsuit for $710,000.
- During pretrial and trial, defendant faced restrictive jail conditions and multiple attorney changes, with debates over access to counsel and mental health evaluations.
- The automatic appeal and capital sentence followed after the penalty verdict in 2003.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of deposition testimony as evidence | Rodriguez’s deposition admissible as party admission | Deposition is hearsay and improper without objection | Admissible as party admission under Evidence Code 1220 |
| denial of new court-appointed counsel | Court properly denied replacement; defense had capable counsel | Irreconcilable conflict with counsel; need new attorney | No abuse of discretion; denial affirmed |
| Competence to stand trial | No substantial evidence of incompetence; trial court acted properly | Defendant's mental state required competency hearing | Court did not err; no substantial incompetence required a hearing |
| Confrontation rights and Hall’s statements | Hall’s statements and cross-examination complied with Crawford and prior law | Confrontation rights violated by hearsay statements | No Crawford violation; prior statements admissible; cross-exam adequate |
Key Cases Cited
- People v. Jenkins, 22 Cal.4th 900 (2000) (deference to jail-conditions rulings and hearings honoring detainee rights)
- Marsden, 2 Cal.3d 118 (1970) (right to substitute counsel when irreconcilable conflict exists)
- Crawford v. Washington, 541 U.S. 36 (2004) (reliance on testimonial statements; cross-examination admissibility)
- California v. Green, 399 U.S. 149 (1970) (prior testimony admissible; confrontation implications)