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People v. Storrs CA3
C087437
| Cal. Ct. App. | Jul 7, 2021
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Background:

  • On November 10, 2016, at a Stockton recycling center the victim agreed to help E.S. redeem recyclables; while doing so defendant approached and stabbed the victim.
  • Autopsy showed four sharp-force injuries: two fatal stab wounds penetrating the left chest (one severing the subclavian artery) and two superficial incised wounds; victim had no defensive wounds and bled to death.
  • Surveillance and witness testimony placed defendant at the scene, allegedly “creeping” toward the victim, wearing gloves, and later waving a folding knife; police recovered a folding knife (2.5" blade) with the victim’s DNA but no conclusive DNA from defendant.
  • Defendant was convicted by a jury of first degree murder and a personal-weapon enhancement; he was sentenced to 76 years to life after court found prior serious felony strikes.
  • On appeal defendant challenged the sufficiency of the evidence to prove premeditation and deliberation; the Court of Appeal affirmed.

Issues:

Issue Plaintiff's Argument (People) Defendant's Argument (Storrs) Held
Whether there was legally sufficient evidence of premeditation and deliberation to support first degree murder Circumstantial evidence supports premeditation: defendant armed himself, was observed “creeping,” wore gloves, attacked by surprise, and inflicted multiple clustered, vital-area stab wounds Evidence at best circumstantial; no proven motive, no direct proof of planning, killing could have been an impulsive attack — reduce to second degree murder Court affirmed: viewing evidence in prosecution’s favor, jury reasonably inferred planning and deliberation from being armed/creeping/gloves, lack of defensive wounds, clustered fatal neck/chest stabs, so substantial evidence supports first degree murder

Key Cases Cited

  • People v. Anderson, 70 Cal.2d 15 (1968) (sets out planning-motive-manner framework for premeditation review)
  • People v. Jennings, 50 Cal.4th 616 (2010) (standard of review for sufficiency-of-evidence claims)
  • People v. Maury, 30 Cal.4th 342 (2003) (circumstantial evidence can support convictions; appellate courts must accept reasonable inferences)
  • People v. Bloom, 48 Cal.3d 1194 (1989) (state of mind evidence is often circumstantial and sufficient)
  • People v. Pearson, 56 Cal.4th 393 (2013) (premeditation involves prior thought; deliberation involves weighing of considerations)
  • People v. Casares, 62 Cal.4th 808 (2016) (Anderson framework is descriptive aid, not exclusive test)
  • People v. Morales, 10 Cal.5th 76 (2020) (method and lack of defensive wounds can support inference of deliberation)
  • People v. Prince, 40 Cal.4th 1179 (2007) (clustered stab wounds support inference of deliberate killing)
  • People v. Lewis, 46 Cal.4th 1255 (2009) (wounds to vital areas can indicate a reasoned decision to kill)
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Case Details

Case Name: People v. Storrs CA3
Court Name: California Court of Appeal
Date Published: Jul 7, 2021
Docket Number: C087437
Court Abbreviation: Cal. Ct. App.