People v. Superior Court (Jones)

In People v. Superior Court (Jones) (1998) 18 Cal.4th 667, the California Supreme Court reviewed the juvenile court's finding of fitness. In that case, two minors with no prior criminal record attempted to rob a store while under the influence of alcohol and drugs and accidentally shot and killed the store owner. The juvenile court found that the minors' inept execution of the crime was evidence of a lack of criminal sophistication, which mitigated the circumstances, and gravity of the offense. The court of appeal reversed the fitness order, and the Supreme Court affirmed the reversal. ( Id. at p. 671.) The Supreme Court determined that the evidence indicating that the shooting was accidental was insufficient to mitigate the gravity of the minors' acts of planning and carrying out a store robbery. The court noted that the evidence also showed that the juveniles planned the robbery, brought along a loaded and cocked gun, and took money from the cash register after shooting the victim in the face. ( People v. Superior Court (Jones), supra, 18 Cal.4th at p. 685.) Further, the court rejected the juveniles' contention that their use of alcohol was a mitigating factor. ( Id. at p. 685.) The evidence showed that the minors "were not impaired to the extent of being unable to plan the robbery . . . and the offense does not appear to have been induced by intoxication." (Ibid.) The court also rejected the minors' subsequent remorse and good behavior as evidence in mitigation of the severity of their crime, because remorse and good behavior do not constitute extenuating or mitigating circumstances. Thus, the Supreme Court found that the record failed to show any evidence of extenuating or mitigating circumstances to lessen the severity of the juveniles' crime. Accordingly, the court reasoned that "no juvenile court could reasonably conclude, based on all of the evidence presented, that these minors had overcome the presumption of unfitness under the criteria of criminal sophistication and circumstances and gravity of the offenses alleged." ( Id. at p. 686.)