People v. Streeter
54 Cal. 4th 205
| Cal. | 2012Background
- Streeter was convicted of first-degree murder with torture and lying-in-wait special-circumstances.
- Penalty-phase retrials occurred after initial deadlock; the second penalty trial resulted in a death sentence.
- Guilt-phase evidence showed a prolonged assault on Yolanda Buttler, culminating in gasoline pouring and arson that caused lethal burns.
- Yolanda Buttler died 10 days after the fire from pulmonary failure due to thermocutaneous burns; extensive burns affected most of her body.
- The defense argued lack of intent to kill or torture; the prosecution argued premeditation, torture, and lying-in-wait supported death eligibility.
- The Court of Appeal affirmed the judgment, rejecting numerous challenged issues and finding no reversible error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson-type jury-selection claim | Hawthorne: no prima facie showing | Streeter: multiple African-American jurors struck | No prima facie case; no discriminatory purpose inferred |
| Marsden substitution at penalty phase | Counsel adequately represented state interests | Counseling conflict impaired representation | No abuse of discretion; substitution not required |
| Admission of photographs, burns testimony, ambulance tape | Evidence clarified pain and malice | Evidence prejudicial and cumulative | Admissible; trial court properly weighed probative value vs. prejudice |
| Sufficiency of evidence for torture murder and lying-in-wait | Evidence shows intent to kill with torture and concealment | Defendant lacked intent to kill; defenses emphasized heat of passion | Substantial evidence supports all theories of first-degree murder and corresponding special-circumstances |
| Penalty-phase instruction 8.88 omission harmless | Weighing guidance adequately conveyed by other statements | Omission misled jurors about weighing process | Harmless error; no substantial likelihood of misdirection |
Key Cases Cited
- Batson v. Kentucky, 466 U.S. 79 (U.S. 1986) (prohibition on race-based peremptory challenges)
- Johnson v. California, 545 U.S. 162 (U.S. 2005) (prima facie Batson standard for discrimination)
- People v. Hawthorne, 46 Cal.4th 67 (Cal. 2009) (state cross-section jury rights; Batson/Wheeler application)
- People v. Cole, 33 Cal.4th 1158 (Cal. 2004) (admissibility of photographs and burn-victim evidence in torture context)
- People v. D’Arcy, 48 Cal.4th 257 (Cal. 2010) (evidence of torture and victim's pain; intent to torture)