People v. Garcia

115 P.3d 1191, 31 Cal. Rptr. 3d 541, 36 Cal. 4th 777, 2005 Cal. Daily Op. Serv. 6641, 2005 Daily Journal DAR 9079, 2005 Cal. LEXIS 8226
CourtCalifornia Supreme Court
DecidedJuly 28, 2005
DocketS124003
StatusPublished
Cited by16 cases

This text of 115 P.3d 1191 (People v. Garcia) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Garcia, 115 P.3d 1191, 31 Cal. Rptr. 3d 541, 36 Cal. 4th 777, 2005 Cal. Daily Op. Serv. 6641, 2005 Daily Journal DAR 9079, 2005 Cal. LEXIS 8226 (Cal. 2005).

Opinions

Opinion

GEORGE, C. J.

It has been established under California law for more than a century that when a trial court authorizes a jury to view the scene of an alleged crime during a criminal trial, the defendant and his or her counsel have a right to be present during the jury view. (People v. Bush (1886) 68 Cal. 623, 631-634 [10 P. 169].) The issue presented by this case is whether, when a jury has visited the crime scene during the presentation of evidence at trial and, after jury deliberations have begun, requests and is permitted to revisit the crime scene, the defendant and his or her counsel similarly have the right to be present at the jury’s return visit to the crime scene.

The trial court in this case ruled that defendant and his counsel have no such right and authorized the jury to revisit the crime scene while barring defendant and his counsel from being present during the return visit. The Court of Appeal, in a two-to-one decision, upheld the trial court’s ruling. In reaching its conclusion, the majority in the Court of Appeal analogized a jury’s revisit to the crime scene to a jury’s reexamination of an exhibit in the jury room during deliberations, at which a defendant and defense counsel have no right to be present. The dissenting justice in the Court of Appeal disagreed with the majority’s analogy, finding that a jury’s revisit to a crime scene differs significantly from its examination of an item of physical evidence in the jury room, because there is a substantially greater risk that a return visit to a crime scene will result in the jury’s receipt of new or improper evidence. Because of this risk, the dissenting justice considered it essential that defendant and his or her counsel have the right “to be present to observe what occurs on the scene, to ascertain for themselves whether new [782]*782evidence has been taken (or has simply emerged), and to witness the occurrence of any irregularities.” We granted review to consider the issue.

As we shall explain, we agree with the dissenting Court of Appeal justice, the Honorable Maria P. Rivera, that when a trial court permits a jury to revisit a crime scene after the jury has begun deliberations, the defendant and his or her counsel have the right to be present and observe what occurs during the jury revisit. As discussed, post, not only does a return visit to a crime scene during jury deliberations create a substantially greater risk that the jury will be exposed to new or improper evidence than when the jury is permitted to examine a trial exhibit in the jury deliberation room, but even when a jury during deliberations requests to examine a trial exhibit or exhibits, the defendant and his or her counsel have the right, under the governing California statute, to be present when the court identifies what exhibit or exhibits are to be given to the jury, in order to ensure that the jury is not exposed to improper evidence. A defendant has no less right to be present and to be assisted by counsel at a jury’s return visit to the crime scene—both to observe and ensure that the jury is not exposed to new or improper evidence, and to be timely informed of any question that may be posed by a juror to the court during the revisit.

Accordingly, we conclude that the Court of Appeal erred in upholding the trial court’s ruling barring defendant and defense counsel from being present during the jury’s revisit to the crime scene. Because in this case the particular location from which the fatal shotgun blasts were fired was a strongly contested issue that was a significant aspect of the defendant’s defense at trial and was potentially relevant not only to the identity of the shooter, but also to the charged lying-in-wait theory of first degree murder and the lying-in-wait special-circumstance allegation, and because the jury’s request during deliberations to revisit the crime scene indicates that the jury likely had lingering questions regarding the location of the shooter, we further conclude that the trial court’s error in excluding defendant and defense counsel from the jury’s return visit cannot be found harmless. Accordingly, we shall reverse the judgment of the Court of Appeal with directions to remand the matter for a new trial.

I

This case arises out of the shotgun murder of Deborah Gregg in November 1998. Gregg lived in a trailer in a rural part of Morgan Hill in Santa Clara County. Her body was found behind her trailer adjacent to a fence that divided her property from a ranch owned by defendant Roy Lopez Garcia. The prosecution charged Garcia with the crime, maintaining that Garcia, motivated by a series of property disputes that had arisen between the two adjoining property owners between May and November 1998, had lain in [783]*783wait and had shot Gregg while concealed in the bushes or trees that grew in the border between the two properties. A jury ultimately found Garcia guilty of first degree murder and found true a special circumstance allegation that he had committed the murder while lying in wait. (Pen. Code, §§ 189, 190.2, subd. (a)(15).)1 The prosecution did not seek the death penalty.

The following factual summary is taken largely from the Court of Appeal’s thorough description of the evidence presented at trial.

In May 1998, Garcia acquired the Sleepy Valley Ranch, which was adjacent to Gregg’s property. The 250-acre ranch contains no buildings or water wells but has a large spring and creek. The creek forms the approximate boundary between the ranch and an adjacent rural subdivision of homes, including a parcel owned by Gregg. Garcia, who lived with his family in Gilroy and owned a successful carpet business as well as a substantial amount of real property, planned to raise cattle on the ranch located in Morgan Hill.

Gregg, who was employed as a therapist in a mental health clinic in San Jose, lived alone in her trailer on a parcel located at the end of Sleepy Valley Road, a dirt road that once had been paved but had fallen into disrepair and that provided Gregg’s only access to her property. Gregg’s trailer was located on a comer of her lot and was separated from the nearby creek by a fence.

When Garcia purchased Sleepy Valley Ranch there was some question— initially raised by the seller of the property—whether Gregg’s trailer, the fence near the creek, and a well used by Gregg encroached upon the ranch property. At the time of the sale, Garcia and the seller commissioned a survey of the ranch property. The engineer who conducted the survey informed Garcia that based upon his survey, he believed that Gregg’s trailer and well were located on Gregg’s own property. Despite the engineer’s findings, however, Garcia continued to believe that Gregg’s trailer and well encroached upon his property.

The main access road to the homes located in the subdivision adjacent to Garcia’s ranch, Armsby Lane, is a private road maintained by fees paid by the members of a road association made up of approximately 50 households. Gregg was an active member of the road association, but the prior owner of the Sleepy Valley Ranch never had been a member and never had paid to maintain Armsby Lane. Spur roads off of Armsby Lane—such as Sleepy Valley Road—were also private roads and were maintained by the individual homeowners served by the spur roads.

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Cite This Page — Counsel Stack

Bluebook (online)
115 P.3d 1191, 31 Cal. Rptr. 3d 541, 36 Cal. 4th 777, 2005 Cal. Daily Op. Serv. 6641, 2005 Daily Journal DAR 9079, 2005 Cal. LEXIS 8226, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-garcia-cal-2005.