People v. Williams
56 Cal. 4th 165
| Cal. | 2013Background
- Defendant Corey Williams was convicted of two first-degree murders with special circumstances and firearm enhancements; codefendant Dalton Lolohea was convicted separately and sentenced to life without parole.
- Jury also convicted Williams of two counts of first-degree robbery and one count of first-degree burglary with firearm enhancements stemming from the same incident.
- Death penalty was imposed on Williams; the appeal is automatic under California law.
- Witnesses described the violent robbery/murder spree, including the use of a Glock pistol and the disposal of evidence and money after the crimes.
- Defense challenged various trial decisions, including jury voir dire, admission of a prison-intake statement, self-representation at penalty, and victim-impact evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether W.M. could be excused for cause in a capital case | Williams argues the excusal was improper | Williams contends excusal biased the jury | Affirmed; excusal upheld |
| Whether the prison intake statement was involuntary or Miranda/Massiah-protected | People upholds admissibility under booking exception | Statement was involuntary or derived from custodial interrogation | Admissible; booking exception applies; Miranda/Massiah not violated |
| Whether Williams was properly allowed to represent himself at penalty phase | State allowed Faretta self-representation | Court failed to properly weigh Windham factors | Affirmed; trial court properly granted self-representation |
| Whether victim-impact testimony and related instructions were proper | Victim impact evidence admissible as aggravating factor | Tests of limits on victim impact evidence and instruction were improper | Affirmed; victim-impact evidence properly admitted and instruction affirmed |
Key Cases Cited
- Wainwright v. Witt, 469 U.S. 412 (U.S. 1985) (capital juror may be excused for cause if unable to perform duties)
- Uttecht v. Brown, 551 U.S. 1 (U.S. 2007) (deference to trial court on venire questions and bias)
- People v. Thomas, 51 Cal.4th 449 (Cal. 2011) (limits on appellate review of voir dire and aggravation/mitigation)
- People v. Morris, 192 Cal.App.3d 380 (Cal. Ct. App. 1987) (Miranda booking exception and custodian interrogation distinction)
- Muniz v. Pennsylvania, 496 U.S. 582 (U.S. 1990) (booking exception to Miranda for routine questions)
- In re Miranda v. Arizona, 446 U.S. 436 (U.S. 1966) (Miranda safeguards and custody interrogation concept)
- Payne v. Tennessee, 501 U.S. 808 (U.S. 1991) (prohibition on victim-impact statements exceeding scope of evidence)
- Morris, People v. Morris (Cal. Ct. App. 1987) (booking/interrogation context prior to Muniz/booking exception)
- Pennsylvania v. Muniz, 496 U.S. 582 (U.S. 1990) (establishes routine booking question exception)
- Gomez v. People, 192 Cal.App.4th 609 (Cal. Ct. App. 2011) (confirms booking exception applicability)