California v. Eddy
Annotate this CaseDefendant Morgan Eddy and the victim often spent time at Lonnie L.’s apartment. At some point, however, Lonnie decided that defendant was no longer allowed in the residence. On the day of the victim’s death, defendant came to the apartment and Lonnie asked him to leave. Defendant initially complied, but shortly after Lonnie left, defendant returned. The victim then told defendant to leave. The victim and defendant subsequently yelled at each other and engaged in aggressive, mutual hand-to-hand combat inside and outside of the apartment, which was observed by multiple individuals. At one point, the victim had defendant pinned on the ground and repeatedly asked defendant if he would leave if the victim let him go. Defendant eventually agreed to leave and the victim went outside. The victim was turning to his right when Joseph S., a neighbor, saw defendant exit the apartment and strike the victim in the abdomen three times with a clenched fist in a sideways motion, consistent with a stabbing. Joseph did not see a weapon but heard sounds consistent with punches connecting. The victim, looking in defendant’s direction with a terrified expression, exclaimed, “You stabbed me!” and fell to the ground. Joseph saw defendant briefly reenter the apartment to grab a bag before fleeing the scene. Joseph did not see defendant discard anything in the apartment. Joseph attempted to pursue defendant after seeing blood on the victim’s shirt. A forensic pathologist testified the victim bled to death as a result of a single stab wound to the lower abdomen, which cut the lower aorta and vena cava. The jury found defendant guilty of first degree murder and found true the special allegation that he had used a knife. At his sentencing hearing, defendant made a Marsden request to replace his counsel, which the trial court denied. The court imposed a sentence of 25 years to life, plus one year for the knife enhancement. The court also imposed various fines and fees and awarded victim restitution, none of which are challenged on appeal. Defendant argued on appeal trial counsel violated his “Sixth Amendment right to choose the objective of his defense by conceding guilt against his express wishes.” The Court of Appeal found that, under McCoy, defendant’s Sixth Amendment rights were indeed violated by his counsel’s actions and found no meaningful basis upon which to distinguish this case from McCoy’s recognition of a defendant’s absolute right to maintain innocence as the objective of his defense. Judgment was reversed and the case remanded for further proceedings.
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