People v. Wilson

Summary

The court affirmed defendant's second death judgment, holding that retrial of the penalty phase did not violate double-jeopardy protections because the original death judgment was reversed for trial error rather than an acquittal or insufficient evidence. The court also rejected defendant's due-process, counsel-conflict, substitute-counsel, death-penalty-statute, and restitution challenges. Assuming defendant could raise a retroactivity challenge under amended murder statutes on direct appeal, the court held any alternative-theory error harmless beyond a reasonable doubt because the verdicts and evidence necessarily established major participation in kidnapping and reckless indifference to human life.