People v. Canizales

Michael Rafael Canizales (defendant) was a member of a street gang. One day in July 2008, Canizales had a couple of arguments with Denzell Pride, a member of a rival street gang. Later that day, Canizales, KeAndre Winfield, and a few other members of his gang showed up to a neighborhood block party. They brought guns, and Canizales and Winfield opened fire in the direction of Pride, who was standing with Travion Bolden, another member of Pride’s gang, about 100 to 160 feet away. Bolden and Pride fled, and a woman attending the block party was shot and killed. Canizales and Winfield were jointly tried and convicted of her murder as well as the attempted murder of Bolden and Pride, who were not hurt. Evidence at trial suggested that Pride was Canizales’s primary target based on their altercation. In addition, Winfield had implied to a friend that he and Canizales had gone to the party to go after a member of the gang to which Pride belonged. Prior to opening fire, Winfield looked at Pride and yelled in his direction. At the trial, the jury was instructed that if Canizales and Winfield were shooting at a primary target, they were also responsible for attempted murder as to the people within the same area or zone. This meant that the jury could find Canizales guilty of attempting to murder Bolden in addition to Pride, believed to be the primary target. Canizales appealed, arguing that the instruction was in error.