People v. Beck
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The Supreme Court affirmed, as modified in this opinion, the judgments of the trial court convicting James David Beck and Gerald Dean Cruz of four counts of first degree murder and entering judgments of death based on the murders, holding that certain true findings as to Defendants' convictions of conspiracy to commit murder were unauthorized.
Defendants were convicted of four counts of first degree murder and of conspiracy to commit murder. The jury also found true a multiple murder special circumstance allegation and allegations of personal use of a deadly weapon. The trial court entered judgments of death. The Supreme Court vacated the multiple murder special circumstances true findings as to conspiracy to commit murder, as well as the death sentences imposed for that count, and otherwise affirmed, holding (1) the trial court erred in imposing a death sentence based upon Defendants' conspiracy convictions because conspiracy to commit murder alone cannot make a defendant death eligible; and (2) there was error but no prejudice in some of the trial court's instructions, the prosecutor's argument during the penalty phase, the imposition of the death penalty for the convictions of conspiracy to commit murder, and in the admission of certain testimony, but these errors were not prejudicial when considered individually or cumulatively.
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