People v. Fernandez
In People v. Fernandez (1990) 219 Cal.App.3d 1379, 1387, appellant's co-defendant was willing to waive his privilege against self-incrimination and testify on behalf of appellant but the co-defendant's counsel objected to his client making such a waiver and the trial court acquiesced in counsel's objection.
The Court of Appeal held "a defendant's right to testify on behalf of his codefendant is . . . of such fundamental importance that it overrides his attorney's control of the proceedings." (Fernandez, 219 Cal.App.3d at p. 1387.)
The court reasoned whether the co-defendant's counsel agreed or disagreed with his client's decision to testify, the co-defendant was the holder of the privilege and was entitled to knowingly and voluntarily waive it.
Therefore, "the trial court erred in precluding appellant from calling co-defendant as a witness." (Fernandez, 219 Cal.App.3d at p. 1388.)
In Fernandez, appellant made no offer of proof as to the co-defendant's expected testimony.
Houston's counsel only made a bare assertion Young "offered to give testimony that would exculpate Houston of the charges" and "would favor Houston and would exonerate him."
This was clearly an inadequate showing Young's testimony would have been favorable to the defense.