People v. Zaragoza, 1 Cal. 5th 21

Background

In 1999 David Gaines was shot and killed outside his home after a robbery; defendant Louis Zaragoza and his brother David Zaragoza were suspected; David was later found incompetent to stand trial.
Defendant was tried alone, convicted of first-degree murder and robbery, found to have personally used a handgun, and the jury found robbery-murder and lying-in-wait special circumstances; jury returned a death verdict.
Key contested facts: whether one or two perpetrators were involved and which brother was the shooter; prosecution relied on eyewitness reports of two fleeing men, trajectory/forensic evidence, and robbery proceeds (a Pyrex bowl and lid) found in defendant’s residence garbage.
Defense emphasized David’s confessions/inconsistent statements, David’s severe mental impairment, gaps in direct identification of defendant as shooter, and alternative explanations for physical evidence (e.g., sister’s access to items).
On appeal the California Supreme Court found reversible error in the death-qualification process (excusal for cause of a prospective juror based solely on questionnaire answers) but affirmed the convictions and other trial rulings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Death-qualification: excusal of Prospective Juror No. 129 for cause based only on written questionnaire	Juror’s questionnaire showed she could be substantially impaired by moral/religious opposition to death; excusal for cause was proper	Juror’s answers were ambiguous and she expressly said she could set aside personal views and follow law; court should have conducted voir dire before excusing her	Reversed death judgment: excusal was error because written answers did not clearly show inability to follow law and no in-court inquiry was made (de novo review)
Death-qualification: excusal of Prospective Juror No. 16 after voir dire	Juror’s conflicting answers and demeanor showed she was substantially impaired; excusal for cause proper	Juror ultimately said she could follow instructions; answers were ambivalent	Affirmed excusal: court had opportunity to observe demeanor and reasonably found substantial impairment (abuse-of-discretion review)
Batson/Wheeler challenge to peremptory strikes of two Latino jurors	Defendant argued prosecutor used peremptories discriminatorily (both first strikes were Latino)	Prosecutor offered nonracial reasons (juror criminal history, inconsistent views on burden of proof; other juror’s firm religious opposition); reasons dispelled inference of discrimination	Denied Batson/Wheeler: record contained clear nondiscriminatory justifications, so no prima facie case established
Sufficiency of evidence that defendant was involved / was the shooter	People argued circumstantial and forensic evidence, eyewitness accounts of two fleeers, items from robbery in defendant’s garbage, and timeline supported defendant’s participation and shooting	Defendant argued David acted alone and evidence was insufficient to tie defendant to the shooting	Convictions affirmed: viewed in light most favorable to verdict, circumstantial evidence supported inference that two persons were involved and that defendant was present and likely the shooter

Key Cases Cited

Uttecht v. Brown, 551 U.S. 1 (U.S. 2007) (trial court deference in juror death‑qualification matters but limits where ruling rests on voir dire demeanor)
Wainwright v. Witt, 469 U.S. 412 (U.S. 1985) (juror may be excused for cause if views would prevent or substantially impair performance)
Witherspoon v. Illinois, 391 U.S. 510 (U.S. 1968) (exclusion of jurors solely for general opposition to death penalty invalid)
Lockhart v. McCree, 476 U.S. 162 (U.S. 1986) (jurors with strong beliefs may still serve if they will follow law)
People v. Avila, 38 Cal.4th 491 (Cal. 2006) (written questionnaire-based excusals reviewed de novo; clarity required to sustain for-cause strike without voir dire)
People v. Riccardi, 54 Cal.4th 758 (Cal. 2012) (prospective juror may be discharged for cause on questionnaire only if responses clearly show inability to follow law)
People v. Stewart, 33 Cal.4th 425 (Cal. 2004) (burden on proponent of challenge to prove juror impairment)
People v. Duff, 58 Cal.4th 527 (Cal. 2014) (questionnaire ambiguity requires voir dire to resolve juror’s capacity to follow instructions)
Gray v. Mississippi, 481 U.S. 648 (U.S. 1987) (reversal required when death‑qualified jury selected by improper for-cause excusals)
Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (three-step test for racial discrimination in peremptory strikes)
People v. Wheeler, 22 Cal.3d 258 (Cal. 1978) (California counterpart to Batson)
People v. Scott, 61 Cal.4th 363 (Cal. 2015) (application of Batson/Wheeler framework and consideration of record reasons that dispel inference of bias)