People v. Sandoval

Summary

The court affirmed Sandoval's convictions and death judgment in all material respects but reversed the lying-in-wait special-circumstance finding because the jury was not instructed on the reasonable-inference rule for circumstantial evidence, and the omission was prejudicial as to that finding. The court upheld denial of a warrant-related evidentiary hearing, concluding that Sandoval's allegations of deliberate or reckless omissions were conclusory and immaterial, and rejected his remaining guilt- and penalty-phase claims. The court concluded that the lying-in-wait instructional error did not affect the first degree murder verdict, the other special circumstances, or the penalty verdict.