People v. Griffin
66 Cal. 2d 459, 426 P.2d 507, 58 Cal. Rptr. 107 (1967)
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Rule of Law:
When evidence of a defendant's prior crime is admitted to demonstrate motive, intent, or common scheme, evidence of the defendant's acquittal of that prior crime is also admissible to weaken and rebut the prosecution's evidence.
Facts:
- On December 2, 1961, in Los Angeles, defendant Griffin met Eddie Seay and his friend, and later joined Seay and his live-in partner, Essie Mae Hodson, at the 41st Street Club.
- After the club closed, Griffin asked Seay if he could spend the night at Seay and Essie Mae's apartment, and Seay agreed.
- Later that night, Seay awoke to find Griffin and Essie Mae struggling on a daybed, and Essie Mae told Seay that Griffin had tried to force her to have sexual relations.
- Seay took Griffin downstairs, but Griffin later broke back into the apartment.
- After again going downstairs with Seay, Griffin hit Seay, knocking him down, and then Griffin and Essie Mae were gone.
- Around 7 a.m. on December 3, Alfredo Villasenor found Essie Mae, injured and in shock, in a large trash box in an alley near her apartment, having just seen Griffin leaving the box.
- Essie Mae died the next day in the hospital from head injuries and multiple abrasions, though an autopsy showed no signs of forcible rape or sperm.
- In mid-December, Griffin, having fled to Mexicali, Mexico, allegedly attacked Amanda Encinas, Willie Kerr's live-in partner, by beating her, forcing her to disrobe, and attempting to have intercourse, leading to his arrest for rape.
Procedural Posture:
- Griffin was found guilty of first degree murder and sentenced to death in his first trial.
- On automatic appeal, the California Supreme Court affirmed the judgment.
- The United States Supreme Court reversed the judgment in Griffin v. California, holding that comments and instructions regarding Griffin's failure to testify violated his Fifth Amendment rights, and remanded the case.
- In a second trial, the jury failed to reach a verdict, and a mistrial was declared.
- Griffin's motion to enter a plea of once in jeopardy to the charge of first degree murder was denied by the trial court.
- The case proceeded to a third trial, where a jury found Griffin guilty of first degree murder and fixed the punishment at death.
- Griffin's appeal of this third judgment to the Supreme Court of California was automatic.
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Issue:
Does a trial court err by admitting evidence of a defendant's prior, uncharged crime to prove intent or common scheme, while simultaneously excluding evidence of the defendant's acquittal of that prior crime?
Opinions:
Majority - Traynor, C. J.
Yes, a trial court errs by excluding evidence of a defendant's acquittal of a prior crime when evidence of that crime is admitted by the prosecution to prove intent or common scheme. While competent and admissible evidence of another crime is not rendered inadmissible by an acquittal, the better rule dictates that proof of an acquittal should be allowed to weaken and rebut the prosecution's evidence of the other crime. An acquittal, although not conclusive proof of innocence, provides relevant evidentiary value for the jury to consider when assessing the weight of the 'other crime' evidence. Excluding it is prejudicial, particularly when the 'other crime' evidence is crucial for a felony murder theory. The court rejected the argument that an acquittal is merely hearsay opinion, noting that judgments can have evidentiary value. The error in this case was prejudicial because the evidence of the Mexican crime was crucial to proving an intent to rape for the felony murder theory, and the jury's consideration would have been materially affected by knowing of the acquittal. Therefore, it is reasonably probable a more favorable result would have been reached had the evidence been admitted.
Dissenting - Burke, J.
No, it is not reasonably probable that a more favorable result would have been reached had the evidence of Griffin's acquittal of the Mexican crime been admitted at his trial on guilt. There was overwhelming evidence that Griffin killed Essie Mae Hodson in the perpetration of, or attempt to perpetrate, rape. Evidence of the incident in Mexico several weeks later, indicating a similar plan, scheme, and design, was highly relevant as to Griffin’s illicit motives in introducing himself into the household of an acquaintance. Whether he accomplished his objectives in the Mexican incident by means of rape by force or by inducement was relatively unimportant; it was the bearing the Mexican incident had on his intentions that was significant. The fact that evidence of acquittal was admitted at the penalty trial, and the jury still returned the death penalty, suggests it would have had no effect upon the jury during the guilt phase.
Analysis:
This case clarifies the evidentiary rules regarding 'other crimes' evidence and prior acquittals. It establishes that while the prosecution may introduce evidence of a defendant's prior criminal conduct to prove intent or common scheme, the defense has a corresponding right to present evidence of an acquittal for that same prior conduct. This ruling underscores the importance of a jury receiving complete and balanced information when evaluating such evidence, particularly when intent is a critical element of the charged offense, such as felony murder. The decision reinforces the principle that the potential prejudice of 'other crimes' evidence mandates careful judicial handling and a fair opportunity for rebuttal, impacting how courts approach the admissibility of similar fact evidence in future cases.
