People v. Steele
California Supreme Court
47 P.3d 225 (2002)
Steele was charged with first-degree murder. Steele presented evidence that he suffered from mental issues because of traumatic experiences in the Vietnam War and head injuries. Steele presented expert testimony regarding post-traumatic stress disorder (PTSD) and how it applied to Vietnam veterans. Part of the testimony concerned how certain sounds could trigger flashbacks, like the sound of a helicopter. Steele also presented evidence that a police helicopter flew over his home on the night of the murder. Additional expert testimony was presented on brain-electrical activity mapping, which showed abnormalities in Steele’s brain. The jury convicted Steele of first-degree murder and returned a verdict for the death penalty. Steele then moved for a new trial based on juror misconduct. Steele presented declarations of two jurors in support of the motion. The declarations stated that the jurors did not believe the judge’s instructions regarding life without parole and believed Steele might be released on parole. The declarations also said that four jurors discussed their experience in the military and in Vietnam, and that those jurors’ input factored into the decision that Steele did not suffer from PTSD or any problem with his brain. The trial court refused to consider the portions of the declarations regarding the jurors’ subjective state of mind. The trial court did consider the portions of the declarations dealing with statements made by other jurors, but the trial court determined that those statements were not improper. The trial court denied the motion for a new trial. As a death penalty case, the matter was automatically appealed to the California Supreme Court.
Rule of Law
Holding and Reasoning (Chin, J.)
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