People v. Sattiewhite
59 Cal. 4th 446
Cal.2014Background
- Defendant Christopher Sattiewhite was convicted of rape, kidnapping, and murder of Genoveva Gonzales; a special circumstance finding for murder during rape and kidnapping was true, and he personally used a firearm during the murder.
- The jury returned a death verdict and the trial court denied motions for new trial and modification; the automatic appeal followed under § 1239, subd. (b).
- Gonzales’s body was found near Oxnard after being shot multiple times at close range; the evidence suggested the victim was carried to the ditch and deprived of consented sexual activity.
- Defendant’s activities the night before and the morning of the murder involved abducting Gonzales, with co-defendants Rollins and Jackson; Rollins testified to the group’s acts and defendant’s involvement, including shooting Gonzales.
- The gun used in the murder was traced to a handgun defendant had purchased the morning of the murder; ballistics linked the gun to the weapon used in the crime.
- During the penalty phase, the prosecution introduced prior-crime evidence at Oxnard Beach and victim-impact testimony; defense raised issues regarding competency and various instructional challenges later on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competence to stand trial | Defense argued a section 1369 competency trial was warranted based on evidence of mental disability. | Sattiewhite contends the trial court should have suspended proceedings for a formal competency hearing. | No error; no substantial evidence mandated a competency trial; pretrial report supported competence. |
| Batson/Wheeler claim | Prosecutor reused a peremptory strike against the sole African-American juror. | The strike was racially motivated; trial court erred by not properly analyzing prima facie case. | First-stage ruling affirmed; independent review applied to race-based discrimination; no reversible error given the record. |
| Autopsy and crime scene photographs | Photographs were highly prejudicial and cumulative against the probative value. | Photographs were irrelevant or unduly prejudicial. | Court did not abuse its discretion; photographs were probative of malice, premeditation, and corroboration. |
| Accomplice corroboration | Rollins’s testimony required corroboration under §1111; corroboration supported conviction. | Insufficient corroboration; constitutional concerns under Jackson v. Virginia. | Sufficient corroboration and proper jury question; no due process violation. |
| Instruction on kidnapping and consent | CALJIC 9.56 correctly stated the law on consent and asportation. | Inadequate or misleading on knowledge of true nature of the act; could mislead jury. | Instruction acceptable; no reversible error in the context of the full instruction scheme. |
Key Cases Cited
- People v. Lewis, 43 Cal.4th 415 (Cal. 2008) (standard for competence-related rulings and Batson-related standards applied to prima facie showing)
- People v. Hawthorne, 46 Cal.4th 67 (Cal. 2009) (Batson first-stage analysis where prosecutor states reasons; record examined for credibility)
- Johnson v. California, 545 U.S. 162 (U.S. 2005) (guides stage three analysis in Batson framework)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (discrimination in juror peremptory challenges)
- People v. Mills, 48 Cal.4th 158 (Cal. 2010) (Batson analysis; first-stage finding not dispositive without considering prosecutor’s reasons)
- People v. Tate, 49 Cal.4th 635 (Cal. 2010) (notice of murder theory need not be pled; jury instruction sufficiency)
- People v. Riccardi, 54 Cal.4th 758 (Cal. 2012) (Batson reasoning and stages of inquiry)
- People v. Romo, 44 Cal.4th 386 (Cal. 2008) (standard for penalty-phase evidentiary considerations)