People v. Martinez (1984)

In People v. Martinez (1984) 36 Cal.3d 816, the defendant was convicted of second degree burglary. (Id. at p. 819.) The only evidence against Martinez was a palm print found on a newly painted drill press at the scene. (Id. at p. 822.) One of the employees of the burgled business testified he had painted the drill press the day before the burglary. (Id. at p. 819) After trial, a defense investigator located a witness who could offer testimony the drill press was painted up to two weeks before the burglary. (Id. at pp. 820-821.) The California Supreme Court concluded that although the jury may not have believed the second employee, that employee's testimony was exculpatory and may have raised a reasonable doubt, particularly in light of the limited evidence supporting the defendant's conviction. (Id. at pp. 823-824). The court thus held the trial court abused its discretion in not granting a new trial motion. (Id. at p. 827.)