California v. Roberts
Annotate this CaseThirteen-year-old Jessica F.-H. was brutally murdered in a Sacramento County park. Her murder went unsolved until defendant Ryan Roberts' DNA was linked to her belt buckle and cigarette butts found at the scene. Defendant’s DNA had been collected after an unrelated felony arrest more than a year after Jessica’s murder. Although that arrest was supported by probable cause, he was not formally charged in that matter. Based primarily on the DNA evidence, a jury found defendant guilty of murder in the first degree. The jury also found true an enhancement allegation that defendant personally used a deadly and dangerous weapon, a knife. Defendant was sentenced to an aggregate term of 26 years to life. The issue this case presented for the Court of Appeal's review centered on whether using a DNA sample taken from a defendant who was validly arrested for a felony on probable cause but never formally charged, violated the defendant’s federal or state constitutional rights against unreasonable search and seizure or his state constitutional right to privacy. In the published portion of its opinion, the Court concluded defendant’s federal right protecting him against unreasonable search and seizure was not violated. Further, the Court held defendant’s state constitutional rights were not violated, but even if they were, the Truth-in-Evidence provision of Proposition 8 prohibited suppression of the DNA evidence in a criminal trial. In addition to defendant’s search and seizure and privacy claims concerning the DNA evidence, defendant also asserted: (1) the trial court prejudicially erred in restricting the scope of his gang expert’s testimony; (2 the trial court prejudicially erred in precluding the defense from presenting certain demonstrative evidence; (3 the trial court denied defendant due process by refusing to give his proposed pinpoint jury instruction on third party culpability; (4) the cumulative effect of the trial court’s errors warrants reversal; (5) the trial court erred in denying defendant’s motion for a new trial premised on newly discovered evidence; and (6) the trial court erred in concluding a juror did not commit prejudicial misconduct related to statements made on Twitter during the trial. As to the last claim, defendant requested that the Court perform an independent in camera review of the juror’s Twitter account records. After review, the Court found no reversible error and affirmed judgment.
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