People v. Doyle

Summary

Justice Liu's dissent argues that the court should have ordered briefing and decided whether Doyle knowingly and intelligently waived his constitutional right to a jury trial. The dissent contends that decades of California decisions require affirmative record evidence of an informed waiver rather than a presumption based merely on representation by counsel, and that Doyle's unusually sparse colloquy did not provide such evidence. It also urges consideration of more specific waiver procedures by the Judicial Council or Legislature. Justice Liu, dissenting, would have ordered briefing rather than dismissed review.