Capital Murder Conviction Reversal Case in California
In People v. Hill (1998) 17 Cal.4th 800, defendant's capital murder conviction was reversed because our Supreme Court determined that the entire trial process was unfairly permeated with serious violations of defendant's rights.
The prosecutor repeatedly committed egregious acts of misconduct; there was a serious instructional error affecting an element of the special circumstance allegation; the court impermissibly delegated to the sheriff's department the decision to have defendant shackled in front of the jury; a bailiff testified against defendant and then remained in the courtroom.
Together these errors created a "synergistic effect, rendering the degree of overall unfairness to defendant more than that flowing from the sum of the individual errors." ( Id. at p. 847.)
The prosecutor said the reasonable doubt " 'must be reasonable. It's not all possible doubt. Actually, very simply, it means, you know, you have to have a reason for this doubt. There has to be some evidence on which to base a doubt.'. . . 'There must be some evidence from which there is a reason for a doubt. You can't say, well, one of the attorneys said so.' "
Hill found the statements to be ambiguous and to present an "arguably close" question, but nonetheless found misconduct. (Id. at p. 831.) Whether that single instance of misconduct would have warranted reversal was not addressed; reversal was based on the cumulative effect of misconduct and other errors.