California Supreme Court

The People, Plaintiff and Respondent v. Anthony Aranda, Jr., Defendant and Appellant

August 27, 201255 Cal. 4th 342

Summary

The court held that omitting the standard reasonable-doubt instruction did not violate federal due process as to voluntary manslaughter because other instructions connected the beyond-a-reasonable-doubt standard to murder and its lesser included offenses. The omission violated federal due process as to the gang offense, but the error was subject to harmless-error review and was harmless beyond a reasonable doubt because the record showed the jury must have applied the correct standard. The failure to define reasonable doubt was state-law error, but it was harmless under the applicable state-law standard. Justice Kennard, concurring in part and dissenting in part, agreed on the instructional-error rulings but would have found the gang-offense error prejudicial and affirmed its reversal.