From People v. Muhammad, decided Wednesday by the California Court of Appeal, in an opinion by Justice Kenneth Yegan, joined by Justices Arthur Gilbert & Hernaldo Baltodano:
Here we hold that allowing a jury to deliberate during the COVID pandemic is not coercive and does not deprive a defendant of the due process of law.
A jury convicted appellant Kori Muhammad of [murder and other charges]…. The trial court sentenced appellant to a total determinate term of 61 years in prison plus an indeterminate term of 145 years to life…. Appellant murdered four people during a 2017 shooting spree in Fresno. The People charged him with first degree murders and initially sought death penalty. Defense counsel conceded appellant committed the crimes but claimed he did so while suffering from symptoms of paranoid schizophrenia, including auditory, visual, and olfactory hallucinations. His trial took place over 31 days in February, March, and April of 2020.
Defense experts testified how mental illness skewed appellant's perception of his environment and caused him to fixate on racial tensions. Appellant testified and described how shooting white people was part of his divine, preordained mission to establish "a kingdom of infinite peace and progress."
Appellant's trial occurred during the COVID pandemic. The trial court directed jurors to sit farther apart and to isolate themselves as much as possible when they returned home each day after trial. When the defense rested on March 17, the trial court ordered jurors to return for closing argument on March 19 and assured them it would secure a spacious room for deliberations. Counsel and the trial court agreed to distribute an anonymous questionnaire gauging jurors' willingness to proceed during the perceived health crisis. All of the jurors responded that they preferred to finish the trial. Statewide court closures, however, required the trial court to halt deliberations after just one day.
