People v. Scott
61 Cal. 4th 363
| Cal. | 2015Background
- Defendant Royce Lyn Scott was convicted after jury trial of first-degree murder (special circumstances), burglary, rape, and sodomy for the sexual assault and killing of 78‑year‑old Della Morris; jury returned a death verdict and sentence was affirmed.
- DNA (RFLP) linked semen found on the victim and sheet to Scott; hairs from the scene were consistent with Scott’s pubic hairs.
- Scott pleaded guilty to several separate Palm Springs burglaries committed after the murder; those offenses were admitted at trial for intent and later used in the penalty phase as limited aggravating evidence.
- Trial court excused a prospective juror for cause based on equivocal death‑penalty views; the court denied a Batson/Wheeler challenge to two peremptory strikes of African‑American venire members.
- Scott argued numerous issues on appeal including Batson error, improper joinder/severance, admissibility of other‑crimes evidence, instructional errors, and sentencing/Cunningham claims; the California Supreme Court affirmed.
Issues
| Issue | Scott's Argument | People’s Argument | Held |
|---|---|---|---|
| 1) Challenge for cause of juror B.C. | Trial court wrongly excused B.C. for cause despite her saying she could follow law and weigh aggravating/mitigating evidence. | Court observed demeanor and equivocal answers supporting disqualification. | Affirmed: no abuse of discretion; demeanor + inconsistent answers supported removal. |
| 2) Batson/Wheeler peremptory strikes of two Black jurors (R.C., H.R.) | Strikes were racially motivated; prima facie case established by pattern and defendant’s race. | Prosecutor gave race‑neutral reasons (prior prosecution connection for R.C.; inconsistent, confused death‑penalty answers for H.R.); no prima facie showing. | Affirmed: no Batson error—trial court permissibly found no prima facie case and nondiscriminatory explanations dispelled inference of bias. |
| 3) Joinder/severance of burglary counts with homicide | Joinder prejudiced Scott by spillover of other burglary evidence and inflaming jury; due process violation. | Joinder proper: offenses were of same class and sufficiently connected; evidence cross‑admissible to prove intent; no undue prejudice. | Affirmed: joinder proper; no gross unfairness and limited risk of spillover given strong homicide evidence. |
| 4) Admission of other‑crimes (post‑murder burglaries) under Evid. Code §1101(b) | Admission invited propensity inference and cumulative/prejudicial. | Other crimes shared distinctive similarities (time, neighborhood, method, sliding door) making them probative of intent; limiting instruction given. | Affirmed: admissible for intent; probative value outweighed risk of prejudice; jury instruction limited use. |
| 5) Instructional claims reducing burden of proof | Various CALJIC instructions effectively lowered prosecution’s beyond‑a‑reasonable‑doubt burden. | Precedent rejects such claims; instructions proper as given. | Affirmed: rejected; followed controlling precedent. |
| 6) Sentencing / Cunningham challenge to upper/full consecutive terms | Court relied on judge‑found facts (probation report) to impose upper term and consecutive/full terms, violating Sixth Amendment. | Aggravating facts supporting upper/full consecutive terms were supported by defendant’s prior convictions/parole status (facts exempt from Apprendi/Cunningham); Ice and Black control. | Affirmed: prior convictions and parole/probation history justified upper terms; consecutive term factfinding not barred by Sixth Amendment. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (prohibits race‑based peremptory strikes)
- Wainwright v. Witt, 469 U.S. 412 (trial court deference in death‑qualification voir dire)
- Johnson v. California, 545 U.S. 162 (clarifies Batson three‑step inquiry)
- Hernandez v. New York, 500 U.S. 352 (discusses mootness of prima facie stage when court rules on ultimate issue)
- Miller‑El v. Dretke, 545 U.S. 231 (evaluate prosecutor’s reasons in light of all relevant circumstances)
- Purkett v. Elem, 514 U.S. 765 (nondiscriminatory explanations need only be facially valid)
- Apprendi v. New Jersey, 530 U.S. 466 (facts increasing penalty must be found by jury)
- Blakely v. Washington, 542 U.S. 296 (defines statutory maximum for Apprendi line)
- Cunningham v. California, 549 U.S. 270 (California sentencing scheme and jury‑findings under Sixth Amendment)
- Oregon v. Ice, 555 U.S. 160 (judge fact‑finding permitted for consecutive sentences)
- Snyder v. Louisiana, 552 U.S. 472 (comparative juror analysis to detect pretext in Batson claims)