California Court Upholds Prisoners’ Convictions for Fatal Jail Beating
by Derek Gilna
By all accounts, the Theo Lacy jail in Orange County, California is a dangerous place, one where prisoners have organized into race-based groups known as “CARs” that “tax” other prisoners by meting out punishment or discipline. Some guards have been accused of failing to prevent and even condoning the prisoner-on-prisoner violence.
In September 2006, prisoners at the jail focused their attention on John D. Chamberlain, who had been arrested for possession of child pornography. Chamberlain was beaten to death by a group of other prisoners amid evidence that several guards had condoned his and other beatings. [See: PLN, May 2013, p.50].
Five prisoners were charged with and convicted of second-degree murder in connection with Chamberlain’s death: Miguel Angel Guillen, Jared Louis Petrovich, Garrett Eugene Aguilar, Stephen Paul Carlstrom, Jr., and Raul Villafana. Defense attorneys attempted to have the charges dismissed based on outrageous government misconduct by jail deputies who failed to prevent the fatal assault.
The California Court of Appeal affirmed the convictions, holding there was no evidence that jail staff had “engaged in outrageous government conduct that impacted a protected right and prevented [defendants] from receiving a fair trial.” The Court acknowledged that Theo Lacy deputies had “engaged in abhorrent conduct and were derelict in their duties,” but found they did not manufacture the incident, did not create the “CAR” system and did not engage in behavior that warranted dismissal of the charges.
The defendants also unsuccessfully argued that the trial court had erred by excluding potentially exculpatory evidence regarding sheriff’s department procedures, as well as certain evidence that three deputies had created an atmosphere of fear that reduced the defendants’ culpability and cast reasonable doubt on whether or not they had the mental state required to establish second-degree murder.
Further, the Court of Appeal rejected an argument that the trial court had erred by not offering an instruction to the jury regarding voluntary manslaughter. The appellate court ruled that a killing committed with malice in the commission of an inherently dangerous assaultive felony is not voluntary manslaughter, and the trial court was not required to issue such an instruction.
Finally, the Court of Appeal held that a failure to have the jury re-deliberate after an alternate juror was seated was rendered moot by the fact that after failing to reach a verdict on first-degree murder, the jury then re-deliberated and reached a verdict on second-degree murder. See: People v. Guillen, 227 Cal. App. 4th 934 (Cal. App. 4th Dist. 2014), review denied.
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Related legal case
People v. Guillen
|Cite||227 Cal. App. 4th 934 (Cal. App. 4th Dist. 2014)|
|Level||State Court of Appeals|