People v. Lawson

CourtCalifornia Court of Appeal
DecidedFebruary 13, 2025
DocketB332399
StatusPublished

This text of People v. Lawson (People v. Lawson) 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. Lawson, (Cal. Ct. App. 2025).

Opinion

Filed 2/13/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

THE PEOPLE, B332399

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. BA499123) v.

AQUIL QADIR LAWSON,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Los Angeles County, Mark S. Arnold, Judge. Affirmed. Marilee Marshall, 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, Zee Rodriguez and Charles S. Lee, Deputy Attorneys General, for Plaintiff and Respondent. ____________________________ The goal of the California Racial Justice Act of 2020 (Racial Justice Act; Stats. 2020, ch. 317) is to “eliminate racial bias from California’s criminal justice system” and “ensure that race plays no role at all in seeking or obtaining convictions or in sentencing.” (Stats. 2020, ch. 317, § 2, subd. (i).) In passing the Act, the Legislature recognized that racial bias “persists” in our criminal justice system “because courts generally only address racial bias in its most extreme and blatant forms.” (Id., § 2, subd. (c).) The Act acknowledges that “all persons possess implicit biases” that “impact the criminal justice system,” and these biases “tend to disfavor people of color.” (Id., § 2, subd. (g).) In this case, defendant Aquil Qadir Lawson appeals from his conviction for murder. Defendant, who is black, contends the trial court’s evidentiary rulings emphasized defendant’s criminality while minimizing that of his white victim. Defendant argues these rulings were motivated by the trial court’s implicit racial bias, thus violating Penal Code section 745, a provision of the Racial Justice Act. We conclude the rulings challenged by defendant were ordinary evidentiary rulings based on relevance and do not demonstrate implicit racial bias under the Racial Justice Act’s preponderance-of-the-evidence standard. We affirm.

BACKGROUND Defendant shot and killed Madison Rose Weiss as she sat in her car. The People by information charged defendant with murder, alleging a firearm enhancement under Penal Code section 12022.5, subdivision (a) as well as circumstances in aggravation under California Rules of Court, rule 4.421. At trial, defendant admitted shooting Weiss, but contended he did so in self-defense.

2 1. Pretrial motions in limine In advance of trial, the prosecution moved to admit videos, photographs, and chat exchanges from defendant’s Instagram account. The prosecution represented that defendant made “several admissions related to the murder” in his Instagram posts, as well as “admissions related to his propensity for violence.” The prosecution further represented that in the posted photos, defendant was dressed in the clothing and jewelry he wore at the crime scene. At the hearing on the motion, the prosecution noted defendant was “a music artist” and the prosecution wished to avoid problems with recent amendments to the Evidence Code limiting evidence of artistic expression in criminal trials. The court asked if defendant “rap[ped] about killing” Weiss. After discussion as to the specific content of the Instagram posts the prosecution wished to introduce, the court stated, “Well, if it relates to this particular incident, then I think rap lyrics are admissible. But if they’re just general rap lyrics about violence or . . . his general feelings about women and violence, I don’t think that’s relevant. I think it’s precluded by [the Evidence Code amendments].” After further discussion, the prosecution stated it would limit the Instagram evidence in its case-in-chief to five of defendant’s statements on Instagram related to the shooting, and the defense stated it had no objection to the admission of that evidence. The prosecution also successfully moved to exclude certain evidence from trial. First, the prosecution moved to exclude text messages between Weiss and a third party concerning production of counterfeit COVID-19 vaccination cards. In those messages, Weiss stated, “I do too much illegal shit already lmfao let’s keep

3 it safe as possible.” The third party then described a plan to produce the counterfeit cards, including obtaining the necessary supplies, to which Weiss did not respond. The prosecution contended the evidence was irrelevant and inadmissible under Evidence Code sections 352 and 1101, subdivision (b). The court noted that if Weiss were a testifying witness, her involvement in counterfeiting vaccination cards might be relevant to her credibility, but because she was deceased, the evidence was not relevant. Second, the prosecution moved to exclude reference to the death of Ozana Smith-DaSilva, whom defendant referred to as “Lizzle.” The prosecution described Smith-DaSilva as “a close friend of defendant’s” and a friend of Weiss as well. The prosecution averred that Smith-DaSilva’s death was determined to have resulted from an accidental drug overdose. Defendant was the one who discovered her body at an Anaheim hotel, and when interviewed by police, he described Smith-DaSilva as his “soulmate” and discussed how her death impacted his mental health. The prosecution was unaware of any admissible evidence linking Weiss to DaSilva’s death, and therefore requested to exclude any reference to her death at trial absent a showing of relevance and admissibility. The court tentatively granted the motion to exclude this evidence as irrelevant. The court stated this was without prejudice to the defense making a showing of relevance at trial, which the court would “certainly listen to.” Third, the prosecution moved to exclude evidence of a backpack containing a loaded firearm discovered the day after the shooting on a rooftop three blocks from the crime scene. The prosecution stated it was unaware of any known tie between, on the one hand, Weiss, the defendant, or the charged crime, and on

4 the other hand, the building where the backpack was found, the individual who found the backpack, or the individual to whom the firearm was registered. The prosecution contended the evidence should not be admitted absent a showing of relevance. After confirming with the prosecution that the discovered gun was not the gun used in the charged crime, the court granted the motion to exclude the evidence. Fourth, the prosecution moved to exclude references to or evidence of Weiss’s activity as a sex worker, including cell phone messages, text messages, and internet activity. The prosecution asserted Weiss had never been arrested or convicted of prostitution, and the evidence of her engagement in sex work should not be admitted without a showing of relevance and admissibility. The court agreed that purported sex work by Weiss was not relevant and granted the motion.

2. Evidence at trial The following summary is limited to the evidence admitted at trial relevant to the issues on appeal.

a. Relevant prosecution evidence Weiss owned a clothing brand called Opium Rose. On cross-examination, defendant admitted he engaged in unemployment fraud and pay loan protection fraud. The prosecution presented the following evidence from defendant’s Instagram account: A photograph of defendant had writing on the bottom stating, “623 God’s Fearless.” A police detective testified defendant had the number 623 tattooed between his eyebrows. A video posted a few hours after the shooting depicted defendant stating, “That’s a new pakkk. Shit smell like roses.”

5 Text scrolling across the video repeated this statement. The detective testified “pakkk” is slang for a dead body. A screenshot contained text stating, “You exposed yaself goofy. Once you done crossed da takers da wrong way, you won’t make it alive.

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Related

People v. Dalton
441 P.3d 283 (California Supreme Court, 2019)
People v. Doolin
198 P.3d 11 (California Supreme Court, 2009)

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Bluebook (online)
People v. Lawson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-lawson-calctapp-2025.