People v. Wright CA3
C096970
| Cal. Ct. App. | Sep 19, 2024Background
- Keyshawn Yvain Wright was convicted of second degree murder and being a felon in possession of a firearm after a fatal shooting at the apartment of his former partner, L.W.
- The incident occurred after Wright forcibly entered L.W.'s apartment late at night, where another of her partners, Alex S., was present with a firearm.
- Evidence at trial was conflicting about who shot first, but the jury credited testimonies indicating Wright shot Alex without justification.
- The trial court sentenced Wright under California’s “Three Strikes” law to 70 years to life (but orally pronounced 45 years to life for murder plus a consecutive 25 years to life for firearm enhancement).
- Wright moved for a new trial, challenging exclusion of certain text messages as evidence of the victim's violent character and sought correction of the judgment record regarding a bodily injury enhancement and other clerical errors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence re: lack of self-defense | Evidence shows defendant murdered Alex | Evidence insufficient; he acted in self-defense | Evidence supports verdict; no self-defense justified |
| Exclusion of victim’s character for violence evidence | Texts not evidence of violent character | Texts proved victim's violent propensity | No abuse; texts did not show violent propensity |
| Correction of great bodily injury enhancement record | No need; not sentenced on enhancement | Should strike all references from record | No correction needed; court orally struck it |
| Correction of abstract of judgment | Needs correction to reflect oral sentence | Needs correction for clarity regarding sentences | Correction ordered as to sentence terms and entries |
Key Cases Cited
- People v. Edwards, 57 Cal.4th 658 (re: sufficiency of the evidence standard for appellate review)
- People v. Minifie, 13 Cal.4th 1055 (self-defense doctrine and its requirements for reasonableness and imminent threat)
- People v. Lindberg, 45 Cal.4th 1 (role of jury in assessing witness credibility and appellate deference)
- People v. Alvarez, 14 Cal.4th 155 (standard for admitting or excluding evidence and abuse of discretion)
- People v. Mitchell, 26 Cal.4th 181 (oral pronouncement of judgment controls over discrepancies in court records)