People v. Williams
61 Cal. 4th 1244
Cal.2015Background
- Between May 14–20, 1993 Jack Emmit Williams organized a teen gang (“Pimp-Style Hustlers”) and directed multiple robberies, attempted robberies, carjackings, and kidnappings; he provided a .380 handgun to co-defendant Dearaujo.
- Dearaujo shot and killed Air Force nurse Yvonne Los during a carjacking attempt after Williams had instructed him to obtain a car, put the victim in the trunk, and gave him the gun and a face covering.
- Williams was tried (guilt and penalty phases) and convicted on multiple counts including first-degree murder (felony-murder theory via aiding-and-abetting and conspiracy), with findings that a principal was armed; jury returned a death verdict and the trial court denied a motion to modify.
- Post-arrest statements, celebratory conduct, and admissions (e.g., supplying the gun, directing carjackings, awarding “stripes”) were admitted; evidence also showed violent jail conduct by Williams.
- On appeal Williams raised numerous claims (restraints, juror removals, jury instructions including natural-and-probable-consequences and lesser-included offenses, adequacy of responses to jury questions, sufficiency for robbery-murder special circumstance, penalty-phase errors). The California Supreme Court affirmed the convictions and death sentence in full.
Issues
| Issue | People’s Argument | Williams’s Argument | Held |
|---|---|---|---|
| Use of leg restraints at trial | Restraint was justified by jail incidents and was not visible; no prejudice shown | Restraints ordered without manifest necessity; violated rights and Deck presumption | Forfeited by failure to object; no record the jury saw restraints; no prejudice (affirmed) |
| Excusal of Juror No. 12 for misconduct | Dismissal was proper where juror formed and expressed opinions about witnesses and lied to court | Dismissal was abuse of discretion; violated constitutional rights | Court did not abuse discretion; removal supported by record (affirmed) |
| Failure to give lesser-included offense instructions (2d-degree murder, voluntary manslaughter) | No substantial evidence supported those lesser offenses | Trial court erred by not instructing sua sponte | No error — no substantial evidence supporting lesser-included instructions (affirmed) |
| Natural & probable consequences (CALJIC No. 3.02) | Instruction correctly stated law and applied here to aid-and-abet theory | Doctrine unconstitutionally imposes liability for negligence / instruction incomplete | Instruction valid as given; later objective-language revision not required; doctrine constitutional (affirmed) |
| Jury questions on aiding/abetting and conspiracy (responses) | Referral to existing aiding/abetting and conspiracy instructions sufficed | Court’s responses were inadequate/partial and could mislead jury | Responses adequate; no prejudicial error; no partiality shown (affirmed) |
| Dismissal of Juror No. 10 during deliberations | Good cause existed (sleeping, refusing to deliberate, illness); removal proper | Dismissal improper; verdict coerced; jury failed to deliberate anew | Removal not an abuse of discretion; deliberations after reseating alternates were adequate; no coercion shown (affirmed) |
| Sufficiency for robbery-murder special circumstance (major participant + reckless indifference) | Evidence showed Williams was gang leader, armed and directed carjacking, instructed shooting of resisters; he was a major participant with reckless indifference | Williams merely supplied a gun and did not intend or foresee the murder | Substantial evidence supports special-circumstance finding (affirmed) |
| Penalty-phase claims (conflict of interest, victim-impact, instructions, proportionality) | Defense counsel had no actual conflict; victim-impact and instructions were proper; death penalty statute constitutional | Multiple infirmities (conflict, prejudicial victim-impact, inadequate instructions, disproportionality) | Claims rejected: no actual conflict; victim-impact admissible; instructions adequate under precedent; death sentence not disproportionate (affirmed) |
Key Cases Cited
- People v. Duran, 16 Cal.3d 282 (court may restrain a defendant in jury's presence only on manifest necessity)
- Deck v. Missouri, 544 U.S. 622 (1995) (visible shackling during trial can be inherently prejudicial)
- People v. Combs, 34 Cal.4th 821 (trial court’s restraint decisions reviewed for abuse of discretion)
- People v. Manibusan, 58 Cal.4th 40 (shackling harmless if jury did not see restraints)
- People v. Mendoza, 24 Cal.4th 130 (speculation insufficient to require lesser-included instruction)
- People v. Lopez, 56 Cal.4th 1028 (CALJIC No. 2.03 and No. 2.06 on consciousness of guilt are permissible)
- Tison v. Arizona, 481 U.S. 137 (1987) (death penalty permitted for major participant who acted with reckless indifference)
- People v. Estrada, 11 Cal.4th 568 (reckless indifference requires subjective awareness of grave risk)
- People v. Ramirez, 39 Cal.4th 398 (sleeping juror may be excused; court must investigate)
- People v. Wilson, 43 Cal.4th 1 (dismissal of juror reviewed for demonstrable reality supporting disqualification)