People v. Samaniego CA2/4

CourtCalifornia Court of Appeal
DecidedMay 18, 2026
DocketB341640
StatusUnpublished

This text of People v. Samaniego CA2/4 (People v. Samaniego 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. Samaniego CA2/4, (Cal. Ct. App. 2026).

Opinion

Filed 5/18/26 P. v. Samaniego CA2/4 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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(a). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115(a).

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION FOUR

THE PEOPLE, B341640

Plaintiff and Respondent, Los Angeles County Super. Ct. No. BA511590 v.

MIGUEL ANGEL SAMANIEGO,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Los Angeles County, Serena R. Murillo, Judge. Affirmed. Corey J. Robins, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Susan Sullivan Pithey, Senior Assistant Attorney General, Steven D. Matthews and Gary A. Lieberman, Deputy Attorneys General, for Plaintiff and Respondent. Appellant Miguel Angel Samaniego chased a rival gang member, Gabriel Hernandez, into a barbershop that was a stronghold of Hernandez’s gang. Then, while standing at the entrance of the barbershop, Samaniego said the name of his gang into the shop. In response, a different rival gang member, Jack Urzua, exited the barbershop and confronted Samaniego in the parking lot. The two men engaged in an altercation, which escalated into them exchanging gunfire, and ended with Samaniego shooting and killing Urzua. Video footage captured these events, including the shooting, and that footage was played for the jury. The jury convicted Samaniego of first degree murder (Pen. Code,1 § 187, subd. (a)) of Urzua, found true the allegation that Samaniego personally used a firearm in the commission of murder (§ 12022.5, subd. (a)), and convicted him of unlawful possession of a firearm by a felon (§ 29800, subd. (a)(1)). The trial court sentenced him to 25 years to life in state prison for the murder, and stayed sentencing on the firearm use allegation and firearm possession count. On appeal, Samaniego argues reversal is required based on erroneous evidentiary rulings, instructional errors, ineffective assistance of counsel, prosecutorial errors, lack of substantial evidence supporting jury findings, and cumulative error. We affirm.

1 Subsequent unspecified references to statutes are to the Penal Code.

2 BACKGROUND The Opal Street and Varrio Nuevo Estrada (VNE) gangs were rival gangs in Boyle Heights. Samaniego was a member of the Opal Street gang. The victim, Jack Urzua (aka “Scooby”), was a member of VNE, as was Gabriel Hernandez. The shooting that gave rise to Samaniego’s murder conviction occurred on the evening of November 2, 2022, in a strip mall parking lot outside a barbershop that was a VNE stronghold. The government presented to the jury two recordings as evidence of the shooting and the events leading up to it. The first recording is video surveillance footage of the parking lot where the shooting occurred. The second recording is audio of a police interview of Hernandez after Urzua’s homicide. We describe the facts below primarily from these sources. The events leading to Urzua’s death started when Opal Street gang members approached Hernandez in their car while he was riding his bicycle. Someone in the car said to Hernandez, “fuck VNE.” Hernandez responded by saying “fuck you” and saying the name of his own gang. The Opal Street gang members then sped away. Hernandez later rode his bicycle near the barbershop and walked into the establishment. Meanwhile, the Opal Street gang members pulled into the parking lot. Samaniego exited the car, followed Hernandez, and went to the front door of the barbershop but did not enter. While standing in front of the open door, Samaniego called out into the barbershop, “Opal Street.” In response, Urzua went outside and confronted Samaniego. When Urzua exited the barbershop, Samaniego pulled out a gun, pointed it at Urzua, and pushed Urzua up against a pillar. Urzua tried to back Samaniego off of him, then began to walk

3 away. Samaniego followed Urzua and hit him in the head with his gun. At that point, Urzua tried to run away, pulled out his gun, and the men shot at each other. Urzua collapsed and Samaniego drove away. Urzua died from multiple gunshot wounds. The parties stipulated that Samaniego was prohibited by law from possessing a firearm on November 2, 2022, the evening of the shooting. Samaniego did not testify or present witnesses in his defense.

DISCUSSION I. The trial court did not abuse its discretion by limiting the defense’s impeachment of Hernandez, and in any event, the purported errors were harmless Samaniego contends the trial court erred and violated his constitutional rights by precluding impeachment of Hernandez with (1) Hernandez’s pending charges for robbery, which involved possession of a firearm and fleeing from the police; and (2) the facts underlying his two prior felony convictions. We conclude the trial court did not err and that the purported errors were harmless.

A. Additional background Defense counsel sought to impeach Hernandez with the conduct underlying his pending charges for which he was in custody. The prosecutor objected, stating, “even though the use immunity does cover anything he says while on the stand, I don’t

4 believe that there is an evidentiary vehicle for the defense to ask about felonious conduct that has not resulted in a conviction.” Defense counsel responded, “I believe I can inquire as to the underlying conduct. He did have a gun in that case. He was fleeing from the police. It’s two counts of robbery. I think it’s relevant to his veracity[.]” Defense counsel further argued, “[h]e was with two other individuals, . . . demonstrating that he does act in concert with others in his gang. In those cases a gun was held to the clerk’s back, there was a threat that if anybody moved they would be shot.” The court asked, “[a]nd if he denies that?” Defense counsel responded, “[i]f he denies that I would have the [investigating] officers under subpoena . . . . I would ask that I be given the opportunity to obtain the witnesses.” The prosecutor then argued the court should exclude evidence of the pending charges against Hernandez pursuant to Evidence Code section 352, though the government had no objection to asking Hernandez “about his prior convictions” and his “gang-related activity.” Defense counsel noted regarding Hernandez’s vandalism conviction: “[I]t was VNE tagging. He does note his moniker as Demon and that’s why the officers speak with him. And he has a bag with a gun in it.” The court asked defense counsel, “[s]o you want, in addition to the crime, to ask him about Demon, the fact that he’s an active gang member and he had a gun on him at the time?” Defense counsel responded, “[y]es.” The court asked the prosecutor, “Are you opposed to those things?” The prosecutor responded, “No.” The court ruled that defense counsel could not ask Hernandez about his pending charges. The court stated:

5 I think the current charge of the two [robberies] is going down a little bit of a side path that is not entirely pro[ba]tive of [Samaniego’s] credibility and under 352[.] I think it’s an ancillary issue that is covered by the two prior convictions that he does have involving prior use of a gun and the graffiti charge. Especially in light of the fact that [the prosecutor] is not objecting to [defense counsel] asking with regard to the vandalism, his gang membership, his moniker and the fact that he had a gun at the time . . . .

So I’m going to rule that [defense counsel] . . . can’t ask . . . about any of the pending charges. I will also mention what he’s in for.

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Bluebook (online)
People v. Samaniego CA2/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-samaniego-ca24-calctapp-2026.