California v. QuintanillaAnnotate this Case
A jury convicted Rene Quintanilla, Jr., of one count of first degree murder, one count of possession of a firearm by a prohibited person, and one count of child abuse likely to produce great bodily harm or death.1 For murder, the jury further found that Quintanilla intentionally and personally discharged a firearm causing great bodily injury or death. The trial court sentenced Quintanilla to prison for an indeterminate term of 50 years to life, consecutive to a determinate term of six years. On appeal, Quintanilla contended the trial court made several prejudicial errors in the admission of evidence during trial. In addition to his evidentiary challenges, Quintanilla argued for reversal based on the prosecutor's alleged misconduct in adducing testimony regarding the witnesses' opinions regarding Quintanilla's relationship with the victim that the trial court excluded from evidence during an in limine hearing. The Court of Appeal concluded the trial court prejudicially erred in admitting the victim's out-of- court statements pursuant to Evidence Code section 1390. Accordingly, although this case involved a horrific and tragic killing, the Court concluded the trial court's erroneous evidentiary rulings required reversal and remand for further proceedings.