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California Supreme Court Remands Guards’ Overturned Murder Convictions In Detainee Death At Santa Clara County Jail

On May 31, 2023, the Supreme Court of California vacated and remanded to the Court of Appeal a decision handed down in August 2022, overturning the second-degree murder convictions of three guards who fatally beat a mentally ill detainee in the Santa Clara County Jail. 

Home to Silicon Valley, the county is one of the most prosperous on the planet – the median home price hit $1.8 million in July 2023 – yet that concentration of wealth does not necessarily trickle down to the treatment of the mentally ill in its detention facilities nor does it guarantee well-managed and constitutional conditions of confinement.

When he died on August 26, 2015, Michael Tyree, 31, was being held at the jail on charges of petty theft and violating probation for misdemeanor drug possession. He was under the supervision of the county Superior Court’s mental health court when he was picked up. But he was placed in the general jail population instead of the acute psychiatric ward – despite a booking classification that indicated he was at risk for suicide. 

As PLN previously reported, Tyree died after a violent attack for which three guards got 15-years-to-life sentences in 2018. [See: PLN, Aug. 2018, p.62.] The guards – Jereh Lubrin, Matt Farris and Rafael Rodriguez – blamed an accidental fall for Tyree’s extensive injuries to his spleen, small bowel, face, skull, liver, and front and back sides of his body. The jury didn’t buy that and convicted the three after being instructed to consider two second-degree murder theories: 1) that the defendants acted with malice aforethought or 2) that a person in their position would have known that murder was a “natural and probable consequence” of the assault.

The conviction was overturned in August 2022, however, when the state Court of Appeal agreed with the guards’ attorneys that the primary legal theory of “natural and probable consequences” had been invalidated by state legislation passed in 2018. It said the law should be applied retroactively and reversed the conviction.

The Palo Alto Weekly reported that “during the appeal the state Attorney General’s Office argued that the jury was also instructed with a still-valid theory of second-degree murder liability — implied malice murder — and any error arising from the trial court’s instructions on the natural and probable consequence theory was harmless.” The Court of Appeal, however, went on to deny the Attorney General’s petition for a rehearing. That led to the petition for the hearing before the state’s highest court. Its decision was promised sometime after “consideration and disposition of a related issue in another case.”

On October 12, 2022, the California Supreme Court granted the petition by state Attorney General Rob Bonta (D) seeking to reinstate the guards’ overturned convictions. Defendant Farris then moved to dismiss the review on May 26, 2023. Five days later, the high Court issued its decision, pointing the Court of Appeal on remand to another supreme court decision about the natural and probable consequences theory, In re Lopez, 14 Cal. 5th 562 (2023). In that case, the high court said what mattered was not the theory presented to the jury but whether jurors made findings to show they relied upon it, so the Court of Appeal should conduct its analysis in that fashion. See: People v. Lubrin, No. S276249, 2023 Cal. LEXIS 2976.

The Santa Clara County Sheriff’s Office has been in the news for troubling issues in recent years. A federal judge found the jail was violating the civil rights of its prisoners in 2019; the former sheriff was found guilty of corruption and willful misconduct in 2021; even its social media presence called into question the department’s professionalism, with a 2022 Valentine’s Day tweet urging people with outstanding warrants to turn themselves in as a Valentine’s Day gift to their significant other. The county has also taken financial hits for settlements in several cases, including $3.6 million paid to settle an excessive use of force claim filed by Tyree’s family in 2016. [See: PLN, Jan. 2018, p.26.] 

Additional sources: CBS News, KRON, Palo Alto Weekly