People v. Suff, 58 Cal. 4th 1013

Background

Defendant William Lester Suff was convicted by a jury of 12 counts of first‑degree murder, one count of attempted murder, true special‑circumstance findings (multiple murders, lying in wait), and multiple weapon‑use enhancements; the jury recommended death for each murder and the trial court affirmed the sentence.
Victimology and forensic linkage: victims were drug‑using prostitutes killed 1989–1991; common patterns included asphyxiation/strangulation, posing/mutilation, and repeated forensic links (DNA, hairs, fibers, tire and shoe impressions, items from victims found in defendant’s van/worksite or given away).
Key discovery, evidentiary, and pretrial rulings reviewed on appeal included: disqualification of the county public defender’s office for conflicts, denial of change of venue, denial of motions to compel investigatory files and profiles, denial of suppression of evidence from a traffic stop and subsequent searches, and various guilt‑ and penalty‑phase evidentiary rulings (e.g., victim impact, admission of victim photographs, exclusion of certain impeachment/third‑party evidence).
Constitutional claims raised: Sixth Amendment right to counsel (and effective assistance), due process/fair trial claims arising from venue and prosecutorial conduct, Fourth Amendment suppression claims, Brady/ discovery claims, Miranda/Fifth Amendment invocation of counsel, and Eighth Amendment challenges to penalty procedures and victim impact evidence.
The Supreme Court of California affirmed the convictions and sentences, concluding the trial court did not abuse its discretion on the challenged rulings and that any alleged errors were forfeited or harmless.

Issues

Issue	Plaintiff's Argument (People)	Defendant's Argument (Suff)	Held
Removal of public defender’s office for conflict	Disqualification appropriate given numerous prior public‑defender representations of potential witnesses; public interest in avoiding use of privileged confidences	Disqualification violated right to counsel; court should have used narrower screening or allowed waiver	No abuse of discretion; disqualification permissible; any procedural shortcoming harmless absent showing of prejudice
Change of venue denial	Publicity not inflamed to the degree that juror impartiality was impossible; passage of years attenuated prejudice	Extensive pretrial media coverage made fair trial in county unlikely	Denial affirmed: independent review found no reasonable likelihood defendant could not receive fair trial; jurors could be impartial
Suppression of evidence from traffic stop and inventory search	Stop valid for Vehicle Code violation (failure to signal); license/registration checks justified impound and inventory search	Stop was pretextual/unlawful; no signal required at red light or where no vehicle affected; detention/search unduly prolonged	Denial upheld: failure to signal supported stop; discovery of suspended license/expired registration justified impound and inventory search; searches reasonable
Discovery of other‑victim investigatory files and profiler materials	People obliged to disclose Brady material; ongoing investigations may be withheld; court required specificity to permit disclosure	Withholding investigatory files and profiler deprived defense of material potentially exculpatory and of ability to pursue third‑party culpability	No abuse of discretion: defendant failed to show requisite specificity or plausibly identify exculpatory material; ongoing‑investigation privilege and relevancy/discretionary limits justified denial
Admissibility of postarrest prostitute murders evidence (third‑party culpability)	Irrelevant or inadmissible; lacked unusual/specific indicia linking to charged crimes	Evidence that similar murders continued post‑arrest would rebut prosecutor’s suggestion killings stopped and support third‑party theory	Exclusion proper: postarrest killings lacked distinctive, signature similarities and were not probative of identity; not admissible third‑party evidence
Admission of impeachment re: lead detective’s indictment/termination	Prosecution needed to present its witness; impeachment evidence would require prolonged mini‑trial and was of limited value	Jury should know lead detective had been indicted/terminated to assess credibility	Trial court did not abuse discretion under Evid. Code §352; admission would have consumed undue time and was cumulative
Miranda/Fifth Amendment invocation of counsel and later statements	Waiver was knowing; defendant’s conditional/commentary asking if he was being charged should be treated as invocation; later statements should be suppressed	Defendant’s precondition was ambiguous/conditional so officers were not required to cease; later unambiguous invocation was respected and those statements were excluded	Majority: invocation was ambiguous (conditional), so interrogation could continue; later clear invocation (“I better get a lawyer now”) ended questioning and those admissions were excluded; concurrence would have suppressed more but found any error harmless
Admission of victims’ photos and victim impact evidence at penalty phase	Photos and multiple impact witnesses relevant to help jurors keep track and show loss; victim impact admissible	Photographs and extensive victim impact risk emotional prejudice inflaming jury toward death	Admission affirmed: photographs were neutral and helpful; 16 impact witnesses not excessive given 12 victims; evidence not so inflammatory as to render penalty unreliable

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial‑interrogation warnings and waiver standards)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (suspect must unambiguously invoke right to counsel to terminate questioning)
Wheat v. United States, 486 U.S. 153 (U.S. 1988) (trial court discretion to refuse conflict waivers when risk of adverse effect is substantial)
Charlisse C. v. Superior Court, 45 Cal.4th 145 (Cal. 2008) (procedures and burdens when disqualifying an entire public defender’s office)
People v. Noriega, 48 Cal.4th 517 (Cal. 2010) (standard of review and counsel‑disqualification principles)
People v. Redd, 48 Cal.4th 691 (Cal. 2010) (traffic stops and Fourth Amendment review standards)
People v. Gonzalez, 34 Cal.4th 1111 (Cal. 2005) (ambiguous invocation of counsel during interrogation not sufficient to stop questioning)
People v. Farley, 46 Cal.4th 1053 (Cal. 2009) (change of venue analysis; media publicity and attenuation over time)
People v. Rogers, 46 Cal.4th 1136 (Cal. 2009) (admission of victim photographs to aid jury identification and manage complexity)