People v. Hart CA2/4

CourtCalifornia Court of Appeal
DecidedJanuary 14, 2025
DocketB331688
StatusUnpublished

This text of People v. Hart CA2/4 (People v. Hart CA2/4) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Hart CA2/4, (Cal. Ct. App. 2025).

Opinion

Filed 1/14/25 P. v. Hart CA2/4 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FOUR

THE PEOPLE, B331688 (Los Angeles County Plaintiff and Respondent, Super. Ct. No. BA480579)

v.

JERALD HART,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Henry J. Hall, Judge. Affirmed. Nancy L. Tetreault, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Susan Sullivan Pithey, Assistant Attorney General, Noah P. Hill, Supervising Deputy Attorney General, and Thomas C. Hsieh, Deputy Attorney General, for Plaintiff and Respondent. INTRODUCTION Defendant Jerald Hart appeals from a judgment sentencing him to life without parole after a jury found him guilty of special circumstance first- degree murder. He contends: (1) the trial court erred by failing to exclude a recorded statement allegedly procured in violation of his Miranda1 rights; (2) the prosecutor and investigating detective violated the Racial Justice Act (RJA) by invoking racial stereotypes; (3) the coroner’s testimony about the victim’s injuries was inadmissible hearsay; and (4) admission of the coroner’s testimony violated his Sixth Amendment right to confrontation. Defendant also asks that we independently review the in camera record of the Pitchess2 hearing, and we have done so. We affirm the judgment.

FACTUAL BACKGROUND I. Prosecution’s Evidence On April 9, 1980, firefighters responded to C.B.’s home on Brighton Avenue in Los Angeles after smoke was reported coming from the roof. When firefighters entered the home, they found C.B. dead on her bedroom floor. She was 79 years old at the time. Her body “from the torso up was heavily burned, incinerated,” and “it was only her lower extremities that were recognizable and were relatively undamaged.” She was naked from the waist down. There was a “crucifix protruding out from her mouth,” and blood on her “vaginal area” as well as her thigh. Razar marks were apparent on her leg. The house appeared to have been ransacked. In the kitchen, an American flag and yardstick were on the floor, and there was a pool of blood.

1 Miranda v. Arizona (1966) 384 U.S. 436.

2 Pitchess v. Superior Court (1974) 11 Cal.3d 531. 2 There was also blood on the kitchen wall, cabinets, and rug. A three-inch circular hole was cut out of the wire mesh of C.B.’s back screen door, apparently to gain access to the latch. A “rape kit” was collected from C.B.’s body. Latent fingerprints were lifted throughout the home, including a fingerprint from the back screen door. After processing the prints, there were no viable matches. Although multiple blood samples were taken, testing for DNA did not exist at the time. Law enforcement canvased the neighborhood and investigated similar cases. Despite police efforts to find a suspect, the matter became a cold case, that is, unsolved but inactive. In 2018, Detective Ross of the Los Angeles Police Department was assigned this cold case. He requested certain evidence screened for blood as well as processed the fingerprint evidence. The fingerprint lifted from the back screen door of C.B.’s home matched defendant’s, which was stored in a federal database. Based on this match, a DNA reference sample was taken from defendant. Defendant’s DNA matched the sperm recovered from C.B.’s vaginal swab from the rape kit. As for the blood evidence, some of the DNA samples were too small to determine a match while other samples matched with C.B. only. Detective Ross then determined that defendant lived across the street from C.B. on Brighton Avenue at the time of her death. He was 19 years old at the time. Detective Ross and his partner subsequently met with defendant at his home (now) in Louisiana. Defendant confirmed he used to live on Brighton Avenue with his parents. He gave detailed responses about various neighbors. For example, he recalled that “Mr. and Mrs. Jones” lived in a nearby house. They died, their daughter continued to live there, but then lost the house. A Latino family moved in and made defendant tamales.

3 Defendant said he had another neighbor named Pat, who he “mess[ed]” around with, but she was too aggressive for him. He also stated he had a girlfriend named Yolanda who lived in the neighborhood. Yolanda’s brother had caught them in bed. When asked if he knew C.B., defendant replied that he never associated with her but knew she had a husband. Defendant did not know her race or her husband’s. All he could recall was that her husband had a “old big ’56 Chevy.” Defendant had no recollection of a house in the neighborhood catching fire. Detective Ross then showed defendant a photograph of C.B. Defendant stated he did not recognize her or have any contact with her, and had never been inside her house. Defendant emphatically stated that he was telling the truth. Despite being told his sperm was found in C.B.’s vagina, defendant did not change his responses. When asked, defendant denied killing or raping C.B. The arson investigator testified that four separate fires were intentionally set throughout C.B.’s house. He opined that the person who started the fire intended to conceal or destroy evidence and prevent identification of himself as the suspect. Dr. Eugene Carpenter conducted the autopsy of C.B. in 1980. At the time of trial, Dr. Carpenter was deceased. Dr. Raffi Djabourian, a deputy medical examiner at the Los Angeles County Coroner’s Office, reviewed Dr. Carpenter’s autopsy report and related documents. He confirmed a “cloth type gag” and crucifix were lodged in C.B.’s mouth, and C.B.’s body was burned postmortem. Dr. Djabourian testified C.B. had injuries to her vaginal area and a laceration on her anal area. Specifically, there was “swelling of the labia of the external genitalia” and perineum. There was also a two inch bruise at the top of the labia of the vagina. These injuries were indictive of sexual trauma and occurred prior to her death. C.B. had some fractures on the left side of her ribcage in four

4 areas and one on the right side of her ribcage. She had some scrapes and bruising on her back and near the back of the right knee as well as in the hip area. Dr. Djabourian opined C.B.’s cause of death was the “combined effects of asphyxia and blood loss due to suffocation and blunt force trauma with a possible contributory factor of strangulation.” The manner of death was homicide.

II. Defense Evidence Defendant testified in his own defense. In 1970, he moved with his family to Brighton Avenue. Defendant denied raping, beating, or killing C.B. or burglarizing her home. Defendant first interacted with C.B. when he was 19 years old. He had helped C.B. with her groceries and brought them inside through her back door. They drank wine together and then he left. Shortly thereafter, defendant and C.B. struck up a friendship. Defendant did work on her porch and they would drink wine together. During one interaction, C.B. “reached over and grabbed [his] penis.” C.B. then took defendant in her bedroom and tried to have sex with him but defendant refused and he left her house. Defendant continued to come over to C.B.’s house to do handy work. At a later date, C.B. “groped” defendant again and they went into her bedroom. C.B. was naked from the waist down and defendant “pulled out [his] penis and . . .

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People v. Hart CA2/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hart-ca24-calctapp-2025.