People v. Watkins
55 Cal. 4th 999
| Cal. | 2012Background
- Watkins and his cousin robbed multiple victims in July 1990, culminating in the shooting and killing Raymond Shield at the West Covina Holiday Inn; Watkins was convicted of first-degree murder with a robbery-murder special circumstance and of attempted robbery of Shield, plus three other robberies, with firearm enhancements.
- Watkins was tried in Riverside/Los Angeles counties; fingerprint, palm print, and weapon ballistics tied him to the crimes; the gun had an unusually heavy trigger pull.
- Watkins admitted two prior grand theft person convictions; his cousin Lucien Martin was tried separately and received life without parole.
- The prosecution presented extensive physical, ballistic, and circumstantial evidence linking Watkins to all crime scenes; Watkins testified and claimed the Holiday Inn shooting was accidental.
- During penalty, Watkins’ prior violent acts and mitigating evidence were presented; the jury imposed death sentence after a separate penalty trial.
- The California Supreme Court affirmed the judgment in its entirety, upholding the convictions and the death sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether death-qualification voir dire must be sequestered | People rely on due process to ensure impartiality | Watkins contends sequestration was required | No reversible error; open court voir dire was practicable and did not abuse discretion. |
| Whether a juror for cause (J.A.) could be excused for death-penalty views | J.A. would be unable to impose death with a clear conscience | Her views did not show substantial impairment after follow-up | Juror J.A. was substantially impaired and properly excused. |
| Sufficiency of evidence for attempted robbery and the associated special circumstance | Evidence shows intent to rob Shield and overt act behind the truck hood | Evidence insufficient or equivocal to establish act element | Sufficient evidence for attempted robbery and the special circumstance; no acquittal warranted. |
| Sufficiency of evidence for first-degree murder (felony murder and/or premeditation) | Sentence premised on felony murder/robbery context; guilt supported | Killing was accidental; insufficient to prove first-degree murder | Sufficient evidence for first-degree murder under either theory; premeditation found. |
| Consciousness-of-guilt instructions in guilt phase | Instructions properly allowed inference of consciousness of guilt | Knew the instructions could mislead if misapplied | Instructions properly tailored; no reversible error. |
Key Cases Cited
- People v. Thomas, 53 Cal.4th 771 (Cal. 2012) (death-qualification with group voir dire permissible under state law)
- Hovey v. Superior Court, 28 Cal.3d 1 (Cal. 1980) (sequestered voir dire in capital cases preferred but statute changed practice)
- People v. Stewart, 33 Cal.4th 425 (Cal. 2004) (death-penalty voir dire and substitute standard for cause challenges)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for conviction)
- People v. Nakahara, 30 Cal.4th 705 (Cal. 2003) (unanimity and theory distinctions in first-degree murder)
- People v. Moore, 51 Cal.4th 386 (Cal. 2011) (unanimity principles in first-degree murder instructions)
- People v. Avila, 38 Cal.4th 491 (Cal. 2006) (trial court deference to demeanor in juror qualification)
- Brown, (various) (Cal. 2003-2010) (international law and death penalty standards considerations)
- Pulley v. Harris, 465 U.S. 37 (U.S. 1984) (intercase proportionality review not required for constitutionality)