People v. Turner CA4/3
G062590
| Cal. Ct. App. | Aug 27, 2024Background
- Christopher Turner pleaded guilty to attempted murder and aggravated assault charges, admitting intent to kill and acts committed on behalf of a criminal street gang.
- He was sentenced to 17 years based on his guilty plea and factual admissions regarding the attacks.
- Following changes in California law, Turner filed a petition for resentencing under Penal Code section 1172.6, which enables relief for people convicted of certain murder-related offenses under disallowed doctrines.
- Turner argued at his evidentiary hearing that the court applied the wrong legal standard and improperly admitted his confession made to police.
- The trial court denied the resentencing petition, relying on Turner’s plea, factual admissions, and confession.
Issues
| Issue | Turner's Argument | State's Argument | Held |
|---|---|---|---|
| Standard Applied at Hearing | Trial court used wrong legal standard at evidentiary hearing | Any error was harmless; Turner was sole perpetrator | Affirmed; error, if any, was harmless |
| Admissibility of Confession (Miranda) | Confession to police should have been excluded due to Miranda violation | Miranda does not apply at resentencing (leniency) proceedings | Affirmed; no Miranda violation at resentencing |
Key Cases Cited
- People v. Watson, 46 Cal.2d 818 (Cal. 1956) (establishing harmless error standard for state law error)
- Chapman v. California, 386 U.S. 18 (1967) (federal harmless error standard)
- Miranda v. Arizona, 384 U.S. 436 (1966) (requiring warnings for custodial interrogations used in criminal prosecution)
- People v. Bland, 28 Cal.4th 313 (Cal. 2002) (specific intent required for attempted murder; implied malice insufficient)