People v. Thomas, 54 Cal. 4th 908

Keith Tyson Thomas was convicted of first degree murder and related crimes in connection with Francia Young’s killing, along with kidnapping, robbery, rape, and sodomy, plus a separate robbery, assaults on police, and felon-in-possession counts related to Sebrena Flennaugh's case.
A pivotal accomplice was Henry Glover, Jr.; the jury found true firearm-enhancement allegations and special circumstances tied to Young’s murder and the related offenses.
Young’s murder occurred December 9–10, 1992 in the Oakland/Point Richmond area; evidence included a gunshot to the head at close range and DNA/PM tests on vaginal/anal samples with specific rarity profiles.
Defendant gave multiple statements to Hayward/Oakland police with Miranda waivers; the police later reinitiated questioning after he had previously invoked counsel in a different case, leading to a contested Edwards v. Arizona issue.
During penalty, the prosecution introduced unadjudicated prior incidents and victim-impact testimony; the defense presented mitigating history including abuse and developmental issues, plus expert testimony.
Glover was tried separately; after multiple trials, Thomas received a death sentence for Francia Young’s murder, with concurrent terms for related offenses and life-with-possible-parole for kidnapping.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Edwards waiver and reinitiation of questioning	State's inquiry after invocation was permissible under Edwards to pursue Francia Young crimes.	Reinitiation violated Edwards; questions about Young crimes were barred after counsel was requested.	No Edwards violation; later statements were admissible and properly admitted.
Removal of the Public Defender’s Office	Severing counsel due to conflict protected confidences and did not prejudice trial.	Complete disqualification violated rights and caused prejudice.	Removal was proper and harmless; no prejudice shown.
Identification of defendant by Silvey-White	Lineup was not unduly suggestive; reliability weighed under totality of circumstances.	Lineup unduly suggestive due to lineup composition and prelineup cues.	Identification admitted; lineup not unduly suggestive; reliability weighed.
Personal firearm-use allegations and actual killer theory	Prosecutor properly argued that Thomas was the killer based on his statements.	Inconsistent theories about killer and firearm use prejudiced trial.	Harmless beyond a reasonable doubt; inconsequential to guilt/penalty.
Penalty-phase instructional errors	Standard penalty instructions were properly tailored to the record.	Court failed to give standard direct/circumstantial evidence and weighing instructions.	Errors were harmless under both state and federal standards.

Edwards v. Arizona, 451 U.S. 477 (U.S. Supreme Court, 1981) (once counsel invoked, police may not initiate interrogation about other offenses absent counsel)
Miranda v. Arizona, 384 U.S. 436 (U.S. Supreme Court, 1966) (mandatory warnings and rights-based interrogation framework)
Doyle v. Ohio, 426 U.S. 610 (U.S. Supreme Court, 1976) (post-arrest invocation of rights and silence cannot be used to impeach later statements)
Maryland v. Shatter, 559 U.S. 120 (U.S. Supreme Court, 2010) ( Edwards presumption not universal; context-specific balancing of coercion risk)
Connecticut v. Barrett, 479 U.S. 523 (U.S. Supreme Court, 1987) (provision for assessing suggestiveness and reliability of identification procedures)
People v. Noriega, 48 Cal.4th 517 (Cal. 2010) (state-court rule on counsel removal due to conflicts and harmless error standard)
People v. Fauber, 2 Cal.4th 792 (Cal. 1992) (mitigation vs. evidentiary prejudice balancing in capital cases)
People v. Carey, 41 Cal.4th 109 (Cal. 2007) (non-unanimous/unadjudicated aggravating evidence and proportionality considerations)
People v. Lewis, 43 Cal.4th 415 (Cal. 2008) (harmlessness standard for instructional error in penalty phase)
People v. Carter, 30 Cal.4th 1166 (Cal. 2003) (preservation and handling of error in capital sentencing)
People v. Ochoa, 19 Cal.4th 353 (Cal. 1998) (mitigation evidence and trial court discretion)
People v. Avena, 13 Cal.4th 394 (Cal. 1996) (mitigation and aggravation balancing in capital sentencing)