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Murder Conviction Reversed -- SB 1437

People v. Madrigal Court: California Courts of Appeal, Docket: H046577 (Sixth Appellate District), Opinion Date: July 6, 2023. Madrigal was among several men who got out of a van and beat a man, robbing him of $25-30. One attacker stabbed the victim with a knife. The victim died soon thereafter. A jury found Madrigal guilty of first-degree murder and second-degree robbery but acquitted him of participation in a criminal street gang. The court imposed an aggregate term of 100 years to life consecutive to 12 years in prison. Madrigal argued that the retroactive application of Senate Bill 1437, which added elements to the definition of felony murder, required the reversal of the first-degree murder conviction and that after defense counsel subpoenaed audio recordings of the van driver’s jailhouse phone calls, the court erred by refusing to review the calls or release them to the defense. The court of appeal vacated the first-degree murder conviction, conditionally reversed the robbery conviction, and remanded. A rational juror could have a reasonable doubt whether Madrigal was subjectively aware of a grave risk of death when he participated in the attack; it was not impossible for a jury to make the findings reflected in its verdicts without also making the 39 findings that would support a valid theory of liability. The error was not harmless. Once Madrigal showed good cause to release the documents, the court erred by refusing to release them on the ground it could not review them quickly and easily; it is impossible to assess prejudice from the error.

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