California v. Fultz
Annotate this CaseIsaac Zafft was fatally shot when a marijuana greenhouse in which he was sleeping was being robbed. In 2014, Nathan Philbrook and Daniel Devencenzi stole marijuana from multiple marijuana farms and greenhouses Philbrook’s wife, Amber N., helped locate on Google Earth. In July, Philbrook invited defendant Finley Fultz to a marijuana theft with him and Devencenzi. Philbrook and defendant drove to California from Nevada in defendant’s truck and Devencenzi followed in his truck. Philbrook entered the greenhouse’s back door, while Devencenzi stayed outside the back door and, according to Philbrook, defendant walked to the front of the greenhouse. Zafft awoke to the sound of Philbrook’s presence and saw the laser sight attached to Philbrook’s AR-15 style handgun. Zafft ran out the front door of the greenhouse where defendant was located. Defendant shot five times, hitting Zafft. The group fled back to Nevada. Upon their return to Nevada, defendant admitted to Amber he delivered the fatal shots, and Philbrook made statements inculpating defendant as the shooter. During the pendency of defendant’s, Devencenzi’s, and Philbrook’s joint criminal prosecution, Devencenzi and Philbrook pled guilty in exchange for reduced sentences. The prosecution failed to inform defendant that those bargains were offered as package deals, contingent on both Devencenzi and Philbrook accepting the plea bargains and fulfilling the bargains’ terms for either to benefit. The prosecution also failed to inform defendant the offers were contingent upon Philbrook and Devencenzi including in a written factual statement that they and defendant participated in a robbery and defendant killed Zafft. When making those bargains, Devencenzi and Philbrook agreed to be interviewed by the prosecution, which the prosecution failed to audio record. Finally, the prosecution continued its investigation of the case against defendant during trial and did not disclose material it intended to use against him until shortly before it was to be offered into evidence. Based on the government’s conduct throughout the investigation and trial, the trial court made several credibility findings rejecting the prosecution’s innocent explanations for the constitutional violations. The trial court then dismissed the case against defendant finding there was no possibility he could receive a fair trial considering the nature of the evidence against him and the violations surrounding his accomplices’ pleas and interviews. The Court of Appeal concluded the trial court's finding was made in error: because the record demonstrated the trial court believed a fair trial could be had in the absence of the "Medina" error, it was appropriate to reverse the judgment and remand the matter to the trial court to "again tailor relief to neutralize the taint resulting from the prosecutor’s other misconduct."
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