People v. Thomas
211 Cal. App. 4th 987
Cal. Ct. App.2012Background
- Thomas and Satterwhite, half brothers, were charged with seven counts including two first-degree murders, three counts of attempted murder, and two counts of shooting at an occupied vehicle, with gang and firearm enhancements alleged.
- Special circumstances alleged for the murders included intentional discharge of a firearm from a motor vehicle and multiple murders; the defendants were alleged to be principals and gang members.
- Following joint trial with separate juries, both Thomas and Satterwhite were found guilty on all seven counts; murders deemed first-degree and the attempted murders premeditated and deliberate.
- Thomas’s sentence included two life terms without parole plus a long aggregate term; Satterwhite received 196 years to life, initially calculated as multiple consecutive terms.
- An unpublished prior opinion reversed some enhancements for Thomas and affirmed Satterwhite’s judgment, then a petition for rehearing led to Miller v. Alabama-based reconsideration for Satterwhite.
- The court ultimately vacated Satterwhite’s 196-to-life sentence and remanded for resentencing in light of Miller, affirmed Thomas’s judgment as modified, and remanded for correction of sentencing minutes, abstracts, and restitution orders.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Miller applicability to Satterwhite’s sentence | Satterwhite argues Miller requires resentencing or relief. | State contends Miller applies and allows re-sentencing discretion. | Sentence vacated and remanded for resentencing under Miller. |
| Voluntariness of postarrest admissions | Thomas asserts his postarrest statements were involuntary. | State contends statements were voluntary under totality of circumstances. | Admissibility upheld; statements not involuntary. |
| Invocation of right to silence by Satterwhite | Satterwhite claims his post-Miranda silence invocation should suppress admissions. | State contends the remark was not an unambiguous invocation. | Statement not an unambiguous invocation; admissions properly admitted. |
| Enhancements and restitution on Thomas's counts | Enhanced terms were improperly imposed or should be stricken; restitution may require correction. | State agrees some enhancements were erroneous and restitution attribution needs correction. | Strikes certain enhancements; orders restitution corrections; remand for overall sentencing adjustments. |
| Satterwhite’s sentence as the functional equivalent of LWOP | Court should not treat 196-to-life as permissible under Miller's framework for juveniles. | Miller permits tailored LWOP in rare juvenile homicide cases. | Remand for resentencing consistent with Miller; ruling acknowledges Miller’s framework. |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. Supreme Court 2012) (mandatory LWOP for juveniles violates Eighth Amendment; allows discretion in rare cases)
- Caballero v. Superior Court, 55 Cal.4th 262 (Cal. 2012) (reflects Miller application in California context and guidance on Miller timing)
- Dykes v. Superior Court, 46 Cal.4th 731 (Cal. 2009) (totality-of-circumstances test for voluntariness of confessions)
- People v. Williams, 49 Cal.4th 405 (Cal. 2010) (treatment of expressions of frustration vs. invocation of right to silence)
- People v. Jennings, 46 Cal.3d 963 (Cal. 1988) (clarifies when a statement constitutes invocation of Miranda rights)