People v. Sandoval
62 Cal. 4th 394
| Cal. | 2015Background
- In April 2000 Ramon Sandoval (age 18) and other Barrio Pobre gang members planned to retaliate against a rival; while positioned on Lime Avenue Sandoval fired an AR-15 into an unmarked police car, killing Detective Daryle Black and wounding Detective Rick Delfín; 28 shell casings were recovered and the AR-15 was found in Sandoval’s home. Sandoval confessed. He was convicted of first‑degree murder, attempted murder, and related offenses; jury found multiple special circumstances including lying‑in‑wait and fixed penalty at death. Appeal is automatic.
- Pretrial, Sandoval moved to suppress the search and his statements, arguing the warrant affidavit omitted material facts about a cooperating witness (Camacho) and sought a Franks hearing; trial court denied the motion.
- At trial the prosecution presented Sandoval’s confession, eyewitness testimony, gang expert testimony (about gang tactics and using long arms to counter police), and evidence of an uncharged prior shooting. Defense emphasized spontaneity, youth, and mitigation evidence.
- The jury was not instructed sua sponte with CALJIC instructions governing the sufficiency of circumstantial evidence for special circumstances (CALJIC Nos. 8.83 / 8.83.1).
- The Court of Appeal reverses only the lying‑in‑wait special‑circumstance finding (on instructional grounds), affirms convictions, and upholds the death judgment as to the remaining special circumstances and penalty phase.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Sandoval) | Held |
|---|---|---|---|
| Denial of Franks hearing / suppression | Warrant affidavit provided probable cause; omissions not material; good‑faith Leon alternative. | Affidavit omitted material adverse facts about Camacho and other leads; Franks hearing required. | Denial affirmed: Sandoval’s allegations were conclusory/assumption‑based and omitted facts were not shown to be material. |
| Admission of gang expert testimony | Expert properly qualified; testimony on gang tactics assisted the jury. | Testimony invaded the jury’s province and supplied impermissible inference of intent. | Admissible: expert opinion on gang tactics is proper and did not state guilt. |
| Failure to give circumstantial‑evidence instruction (lying‑in‑wait special circumstance) | No sua sponte instruction required because direct evidence and confession supported lying in wait. | Trial court had duty to give CALJIC Nos. 8.83/8.83.1 because prosecution substantially relied on circumstantial evidence (gang expert) to prove lying in wait. | Reversed lying‑in‑wait special circumstance: court should have given the circumstantial‑evidence instruction sua sponte; error prejudicial as to that special circumstance. |
| Sufficiency of evidence for first‑degree murder (premeditation) | Prosecution: confession, planning, motive, and manner (28 shots, military style) show premeditation/deliberation. | Defense: killing was spontaneous, impulsive—at most second degree. | Affirmed: substantial direct evidence (confession, planning, manner) supports premeditation and first degree murder. |
Key Cases Cited
- Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (establishes standard for evidentiary hearing when affidavit contains deliberate falsehoods or reckless omissions)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good‑faith exception to exclusionary rule)
- People v. Wiley, 18 Cal.3d 162 (Cal. 1976) (circumstantial evidence instruction required only when prosecution substantially relies on circumstantial evidence)
- People v. McKinnon, 52 Cal.4th 610 (Cal. 2011) (instruction not required when circumstantial evidence simply corroborates or bolsters direct evidence)
- People v. Kurland, 28 Cal.3d 376 (Cal. 1980) (omission rule: affidavit must include material adverse facts that would substantially mislead the magistrate)
- People v. Anderson, 70 Cal.2d 15 (Cal. 1969) (Anderson factors—planning, motive, and manner—for evaluating premeditation/deliberation)
- People v. Prince, 40 Cal.4th 1179 (Cal. 2007) (guidance on admission and limits of victim‑impact audiovisual presentations)